Arizona Registrar of Contractors (ROC)
1700 W. Washington Street, Suite 105 Phoenix, AZ 85007 RE: Update to Contractor Licenses Relative to Solar Dear Ms. Verdugo, Per our conversation in May, AriSEIA submits the following suggestion for updating the contractor licenses applicable for solar. Solar installations (both photovoltaic and hot water) require a mixture of electrical, roofing, structural steel, and mechanical skills. The current Arizona contracting license classifications leave certain ambiguous and unambiguous gaps relative to how the solar industry operates across the residential, commercial, and utility-scale segments, and it is understood that certain solar projects are often direct-contracted by a customer for scope outside of a license classification i.e., a commercial solar carport being installed by a C-11, or a residential solar system being installed by an R-11 when including roofing repairs. To streamline licensure requirements and provide a path to comply with Arizona ROC rules without acquiring multiple licenses, we recommend the creation of a standalone “Solar Contractor” classification. The goal is that the license allows for self-performance of electrical work (and interconnection) of solar systems, installation on rooftops or structures (with requisite limitations on self-performance re: roofing, carpentry, or structural steel), and subcontracting of relevant trades (electrical, underground, roofers, mechanical, structural steel, etc.). In essence, the license would blend K/B-1 subcontracting with C/R-11 self-performance capabilities. The classifications could be further delineated into “Residential Solar Contractor,” “Commercial Solar Contractor,” or “Utility Scale Solar Contractor.” For example, California is one state that has already taken this step to align contracting classifications with the growing solar industry via the C-46 Solar Contractor classification.[1] This license appears to cover both residential and commercial segments.[2] We encourage the ROC to consider such an update and would be more than happy to discuss this matter further. Sincerely, Autumn Johnson Executive Director AriSEIA 520-240-4757 autumn@ariseia.org [1] California Department of Consumer Affairs, Contractors State License Board, C-46 – Solar Contractor, available here https://cslb.ca.gov/About_Us/Library/Licensing_Classifications/C-46_-_Solar.aspx. [2] Overview of the subject matter knowledge applicable to this license is available here https://www.cslb.ca.gov/Resources/StudyGuides/C46StudyGuide.pdf.
0 Comments
Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007-2996 RE: Salt River Project (SRP) Coolidge Expansion Project Certificate of Environmental Compatibility (CEC), Docket No. L-00000B-21-0393-00197 Chairman O’Connor and Commissioners, The Arizona Solar Energy Industries Association (AriSEIA) filed joint comments opposing the SRP CEC on March 11, 2022. That filing is attached, as is a filing from the Solar Energy Industries Association (SEIA) on March 14, 2022. None of the underlying reasons for our opposition have been resolved and we remain opposed to SRP’s Application to Amend Decision 78545, filed on June 14, 2023. First, we are concerned with how quickly this application was filed and then docketed for an open meeting. We received notice of this filing at 4:30 pm on June 14th. We received notice of it being on the revised June open meeting agenda at 10:06 am on June 15th, which is only six (6) calendar days before the open meeting and three (3) business days before the open meeting. This is an inadequate amount of time for interested parties to respond and a vote should not be taken at the June 21st open meeting. Further, SRP has clearly known about this arrangement much longer than other interested stakeholders, which is reflected in the fact that their supporters had ample warning to file supportive comments in the docket. This is not the case and a significant disadvantage for those in opposition. Finally on this topic, it is worth noting that almost all of their letters in support are the same organizations that supported granting the CEC before any proposed settlement. Therefore, their support is not contingent on the settlement or anything that has happened since the CEC was filed in 2021. Second, none of the underlying reasons why AriSEIA opposed the CEC in the first place have been addressed. SRP first proposed the Coolidge Expansion Project two years ago in the summer of 2021. One of our largest complaints was that SRP made the decision to invest nearly $1 billion dollars in almost 1 GW of new gas at the Coolidge Generating Station with no competitive bidding process in violation of their own Integrated Resource Plan (IRP). It has been two years and SRP has issued multiple all-source requests for proposals (ASRFPs) since and they have still not solicited or made public any bids to substantiate this project or its massive cost. There is simply no legitimate reason why SRP could not have done so in the last two years. It is highly unlikely that this Commission would allow Arizona Public Service (APS) or Tucson Electric Power (TEP) to do similarly with no competitive bidding process. Third, the statutes that permit the CEC review clearly state that the Commission shall consider the cost of the facilities when determining to grant the CEC. SRP has never provided a rate impact analysis regarding this project. We simply do not know how much it will cost ratepayers. Further, SRP has not docketed any data that reflects the total cost of the project nearly two years later. If the project was $1 billion in 2021, how much does it cost now with 1) significantly increased interest rates, 2) millions of dollars in negotiated concessions, and 3) the dramatic increase in fuel prices we have seen in both TEP and APS fuel adjustor dockets, as well as the increase SRP’s board also voted to pass recently for their own fuel adjustor? It is not prudent to only include capital costs. Any resource acquisition should also include the operations and maintenance (O&M) costs for that plant/resource, as ratepayers pay the total cost. It is simply imprudent to grant this CEC now. SRP should complete its currently pending IRP (called Integrated System Plan or ISP by SRP) process to determine what resources are needed and when and then should issue an ASRFP like every other utility in the state to determine the best project at the lowest cost. If the winning proposal is for a thermal resource, SRP should apply for a CEC, as required. There is no reason for the Commission to deviate from a process it would require of TEP and APS for SRP, certainly not for a CEC that has already been denied twice by this Commission and lost in court, as well. Attached are two letters filed in opposition in March of 2022. As the Commission makeup has changed since, please review them. Please do not vote on the SRP’s CEC application to amend at the June open meeting and when you do vote, please vote no. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org AriSEIA coauthored an article today in PinalCentral on a pending anti-solar ordinance currently being considered in Eloy, AZ. Local renewables opposition is a huge impediment to the clean energy transition and means we will continue to rely on fossil fuels for electricity. Read the full article above and contact Eloy's city council in opposition.
AriSEIA filed direct testimony on rate design today in the APS rate case. The testimony covered a BYOD/VPP program proposal, a recommendation to disallow cost recovery for APS' uncompetitive microgrid program, rate design changes to several commercial storage rates, a change to how demand charges work for commercial customers installing EV chargers, a robust critique of APS' solar cost of service study, and community solar.
Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: In the Matter of the Five-Year Review of the Rules of Practice and Procedure before the Power Plant and Transmission Line Siting Committee, Arizona Administrative Code Title 14, Chapter 3, Article 2, Docket No. ALS-00000A-23-0063 Chairman and Commissioners, We appreciate the opportunity to weigh in on changes to the Line Siting rules. Below you can find our joint recommendations regarding changes to R14-3-201 through 220. We Recommend Changes to All Requirements to File Written Copies of Documents and/or Mail Documents. Numerous provisions of the rules require filing hard copies of documents and/or mailing documents. We recommended that all of these sections be updated to permit electronic filing and to remove all requirements to file any print copies. If for some reason a print copy is required, such as an exhibit that may not lend itself well to a print version, only one print copy should be required. Further, service should be permissible via electronic means and should not require mailing. R14-3-217 may be entirely unnecessary given this change. We Recommend Updating Outdated Language. There is no reason that the presiding officer should be presumed to be male. The language should be updated to remove personal pronouns. If this is not possible, alternating pronouns or using something like “s/he” or another generic term would be suitable. Recordings of the Proceedings Should Also be Available on the Arizona Corporation Commission’s “Live” Page for Streaming and for Archived Recordings. All Line Siting proceedings, including meetings and hearings, should be available to watch from the Commission’s “Live” page and a recording of all meetings and proceedings should also be available as an archived video on the same page. We recommend creating a tab for “Line Siting” on the archive portion of the webpage. The Rules Should Allow That Hearings Be Held at State Buildings Other Than the Capitol and That Notice Should Be Provided Electronically. R14-3-208(B)(2) says hearings can be held at the State Capitol in Phoenix. We recommend an option to hold the hearing in Phoenix, but think the Commission and other state buildings should also be an option for hearings. Further, public notice should be provided by means other than filing in the newspaper. Direct outreach to residents within a specific vicinity should be provided, as well as electronic notice via social media, email, radio, etc. should be utilized. The Rule Should Expressly Allow Intervenors to Issue Data Requests. R14-3-211 should be updated to expressly indicate that intervening parties may issue data requests, along with the response time for responses. We Recommend Requiring That a Free Read-Only Version of the Transcript Be Provided to all Intervenors and the Public. Procedural orders for Line Siting already require applicants to provide a read only copy of the hearing transcript to be publicly available on the applicant’s website. R14-3-212 should be updated to reflect this and the transcript should also be available on the Commission’s website, not just the applicant’s website. We Recommend “Days” be Clarified as Calendar or Business Days. R14-3-215 should clearly specify if the Committee is using business days or calendar days to calculate deadlines or time periods provided under the rules, as well as what happens if the final day falls on a non-business day. We Recommend Ex Parte Communications Be Treated More Seriously. R14-3-220(D) should be updated to require disclosure of any ex parte communications received by a member of the Committee, as well as a requirement to recuse oneself, should the Member have initiated or responded to the ex parte communication with anything other than a notice that such communication was prohibited. Thank you for considering our recommendations to this important update to the Line Siting rules. Respectfully, Patrick Woolsey Sierra Club Environmental Law Program patrick.woolsey@sierraclub.org Autumn Johnson Arizona Solar Energy Industries Association (AriSEIA) autumn@ariseia.org BLM Yuma Field Office
Attn: Erica Stewart 7341 E. 30th Street, Suite A Yuma, AZ 85365 RE: Solar Variances Dear BLM Staff, The Arizona Solar Energy Industries Association (AriSEIA) is an Arizona based nonprofit, focusing on policies that advance the adoption of solar, storage, and electrification. We are active at all levels of government in the state and represent organizations throughout the clean energy economy. I am writing to encourage BLM to continue moving forward with the solar variance process for the proposed solar projects located in Mohave County. Solar and storage systems benefit surrounding communities in several ways. First, Arizona continues to struggle with water quantity challenges. Solar development and operation of solar facilities does not require large amounts of water compared to other land uses. Using these lands for solar development can help alleviate some of Arizona’s water quantity challenges. Second, the use of clean energy reduces emissions and can improve air quality. Third, the proposed projects should not adversely impact local ecosystems. All three of the proposed projects plan to protect and preserve the natural habitat. Local wildlife and vegetation will still be protected on these lands and can also be used for solar facilities. Along with positive local impacts, the use of solar and storage benefits the entire nation, making public lands a particularly suitable place to develop these facilities. Air quality is a national and global issue; therefore, the emissions reductions achieved from transitioning to the use of more clean energy resources has widespread benefits. The deployment of solar energy also increases energy security throughout the United States. Overall, solar development on public lands will have long term benefits for both surrounding communities and the nation. Please continue to consider and analyze the three solar projects for future development on BLM lands. These include White Hills Solar, Mineral Park Solar, and Leo Solar. AriSEIA supports renewable energy development on public lands. BLM and the solar companies involved should continue to be diligent in their analyses and take the steps necessary to evaluate the suitability of these projects. I have also attached some information on the water usage of solar (operations and lifecycle), the lifecycle emissions of different electricity generating resources, and solar development rates in Arizona and accompanying economic benefits. Sincerely, Autumn Johnson, Executive Director AriSEIA 520-240-4757 autumn@ariseia.org Figure 1 Life cycle water use for electricity generation: a review and harmonization of literature estimates. J Meldrum et al 2013 Environ. Res. Lett. 8 015031 Figure 2 Water Impacts of High Solar PV Electricity Penetration, NREL/TP-6A20-63011, September 2015 (operational water usage) Figure 3 Life Cycle Greenhouse Gas Emissions from Electricity Generation: Update, NREL, 2021 AriSEIA filed a reply brief today in the Tucson Electric Power (TEP) rate case focusing on mechanisms to improve the use of storage for residential and commercial customers to benefit the grid widely. TEP has ignored and attempted to delay any such programs throughout the proceeding and for several years prior to the case.
AriSEIA filed its opening brief in the TEP rate case on May 26th highlighting our recommendations on the revenue requirement (including return on equity (ROE) and common equity ratio), as well as rate design (including community solar, a bring your own device/virtual power plant proposal, tariff re-designs for R-TECH and LGST-SP, and ending the distributed generation (DG) meter fee).
Arizona Corporation Commission
1200 W Washington St. Phoenix, AZ 85007 RE: Proposed Changes to the Public Comment Process, Docket No. AU-00000A-16-0141 Chairman O’Connor and Commissioners: Please consider the following comments on the Arizona Corporation Commission’s (ACC) pursuit of modifying how it considers public comment and implements a version of Robert’s Rules of Order for Thursday’s Staff Open Meeting. We wish to express our concern about the Commission’s vote during the May 1st Staff Open Meeting to keep these proposed changes private and away from public viewing. While keeping sensitive information confidential is reasonable, shielding proposed rule changes or procedures that will determine how everyday Arizonans participate at the Commission is not. We recognize that the proposed changes are meant to guide the operations of the ACC. However, that operation has a compelling public interest, and the document should be widely available. The commissioners are elected, and the ACC is considered a public agency for purposes of the public records law, open meeting law, and other provisions intended to ensure transparency and accountability. The ACC must allow meaningful opportunities for public comment. Not doing so would run contrary to the ACC's mission and leave commissioners to hear overwhelmingly from those monopolies it is charged to regulate. Those monopolies have disproportionate resources to lobby the ACC, and public comment is a critical counterbalance. Considering these concerns, we offer feedback on the proposed rule changes released upon a public records request below: Rule 2. Requiring that people register in advance to provide public comment will severely limit participation by everyday Arizonans, everyday ratepayers, who are most affected by the ACC's decisions. It is challenging enough already for them to participate in these processes, but this would make it even more so. Sometimes people do not know if they can get time off work ahead of time. They may only understand how an item affects them once they hear more about it. Frequently, last-minute amendments can alter agenda items and significantly change a proposal; individuals may want to respond to that as well. Rule 3. As nonprofits, some of which have a significant membership base, we represent individual ratepayers, people who cannot otherwise be at the ACC, whose voices would not be heard if we did not speak up for them. Curtailing our participation and our opportunity to address important issues before the ACC will also silence their voices. It is inappropriate to require various stakeholders or individual entities, such as nonprofits, to designate a spokesperson. Different organizations cannot speak for each other and, even if they were, the ACC needs to hear various perspectives on the issues before it, even if the recommendations are consistent. Requiring the designation of a spokesperson devalues individual experiences and perspectives and further disadvantages those that disagree with the utilities, which have far more power and resources in these matters. Rule 4. Public commenters should be granted a minimum of three minutes to speak. Again, there should not be a deadline to sign up to speak as long as the item has not been concluded, and as the rule is drafted now, the public comment period could be shorter than three minutes. Time limits should only be utilized when necessary due to the significant length of an agenda item. Otherwise, this rule only serves to limit public voices. Rule 6. Further, no public comment should ever be limited to one minute. That is not a meaningful amount of time to convey important and often complex information. See our comments above on Rule 2, as well. Rule 7. As long as an individual wishes to comment and the item has not concluded (i.e., voted on or completed and the next item is called), those who wish to speak but have not been afforded their three minutes should be permitted to speak. Talking to ACC staff should also not be prohibited. Staff represent the ACC as stakeholders in various proceedings, and communication should be encouraged among stakeholders not limited. As has been discussed at several meetings, Staff also need more resources and capacity. Commissioners have mentioned the number of empty positions multiple times. Therefore, stakeholders should be able to engage with Staff should there be an inadvertent error or miscommunication. It is also imperative that stakeholders have the opportunity to reply to comments made by the utilities, Staff, or Commissioners during a proceeding. Limiting a stakeholder’s comments to three minutes with no opportunity to reply makes the conversation more likely to be one-sided with the utilities offered numerous opportunities to speak. The ACC’s processes and procedures already make it difficult for many average Arizonans and most of the ratepayers to participate. The rules you have before you now will not facilitate their participation but will only make it more difficult. We ask that you not vote on changes to the public comment process on the May contingency date and instead post these proposed changes to the docket so that all stakeholders and at least some of the larger public have the opportunity to review and file comments and any changes be addressed at an Open Meeting, not a Staff Meeting, so that they also have the opportunity to speak. We recommend a 30-day time period between posting the proposed changes and any vote. Support for Arizona Public Service (APS) and Tucson Electric Power (TEP)’s Request for an Extension of Integrated Resource Plan (IRP) Filing Deadline
The Joint Signatories, all members of APS and/or TEP’s IRP Advisory Council, write to support APS and TEP’s request to extend the deadline for filing their IRPs from August 1st, 2023, to November 1st, 2023, contingent on timely access to the modeling software and training. The APS and TEP Resource Planning Advisory Councils (RPAC) comprise a diverse group of stakeholders and community representatives the RPACs have been providing input to APS and TEP on their next IRP on behalf of residential and business customers, local governments, public schools, the limited-income community, and the solar and environmental community, among others. We have been meeting monthly since the spring of 2021 for APS, and the fall of 2022 for TEP, to share perspectives and provide input to help both utilities chart a long-term integrated resource plan that maintains reliable, affordable electric service through a balanced, flexible resource mix, which also advances sustainable outcomes. Meetings have addressed topics vital to developing a comprehensive, integrated resource plan, such as load forecasting, existing resource fleet and transmission systems, technology options and costs, and environmental impacts. During these meetings, stakeholders have been invited to listen, offer feedback, and pose questions. Participants have also been encouraged to present their own views. All meeting materials, agendas, and summaries are publicly available on APS and TEP’s RPAC websites. Also, pursuant to the Commission’s Decision 78499, APS and TEP are preparing to provide access to modeling licenses for RPAC members so that they will have the ability to conduct their own modeling analysis to better inform and provide feedback to the final IRP scenarios. However, APS and TEP have not yet provided RPAC members with the model licenses or data necessary to start the modeling efforts. Because the three months remaining before the August 1st deadline is not enough time to give this process the due diligence it deserves, a three-month extension to November 1st, 2023, is justified. This new engagement model provides value to the Commission, APS, TEP, and other stakeholders by:
Because this is the first time this kind of advisory structure with modeling access has been implemented, ensuring that all RPAC participants have a solid understanding of various complex energy issues is essential. As such, many of the RPAC’s initial meetings have focused on education and information sharing. While these educational sessions have been valuable and necessary, the RPAC members have yet to receive the modeling licenses or modeling data and have not begun reviewing and providing input on the dozens of modeled IRP portfolios that APS and TEP produce. Approving APS and TEP’s request to extend the deadline for the filing of their IRPs from August 1st, 2023, to November 1st, 2023, and providing RPAC members access to the modeling license no later than May 2023, would enable the completion of this vital work. This deadline extension should be contingent on the utilities timely providing license access and training. The extension should require APS and TEP to provide access to the model and the requisite training within 30 calendar days of the decision. Thank you for considering our comments, and we encourage the Commission to discuss this matter during the May Contingency Open Meeting date on May 11th. |
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