Leaders Highlight How Arizona Solar Businesses, Nonprofits, and Consumers Can Benefit from the Inflation Reduction Act & Infrastructure Investment and Jobs Act
(TUCSON, AZ) – Today, Tucson Council Member Kevin Dahl joined Frank Velásquez Jr., Board President of The Drawing Studio, Inc.; Tamora Muir, Tucson Resident and Rooftop Solar Homeowner; Adrian Keller, Arizona Program Director, Solar United Neighbors of Arizona; Robert Neifert, Director of Business Development, Solar Gain Inc. and Co-Chair of the Arizona Solar Energy Industries Association’s (AriSEIA) Public Policy Committee to highlight the incredible opportunities to grow Arizona’s clean energy economy, made possible by the solar grants and incentives included in the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA). Speakers shared how these investments will cut energy costs for Arizona families, create clean energy jobs, and help grow Arizona’s clean energy economy. Southern Arizona residents and businesses will benefit from any number of investments outlined in the IRA. These new incentives will help families switch to cheaper, cleaner electricity by offering tax credits cutting 30% off the cost of rooftop solar. Experts estimate that an additional 150,000 Arizona households will install rooftop solar panels specifically because of the investments in the IRA. The IIJA and IRA will also allow for greater adoption of solar by nonprofit organizations, as well as rural and economically disadvantaged populations. “Even as the clean energy industry has exploded in our state, a lot of Arizonans have been left out,” said Tucson City Council Member Kevin Dahl of Ward 3. “But new solar incentives include a 30% tax credit off the cost of installation, and another 30% for stand-alone battery installation. This will be transformative for all Tucson homeowners and nonprofits, especially those previously priced out.” In addition to low-income households, the new incentives also address a previous gap in benefits for nonprofits. The IRA bill includes $20 billion allocated for nonprofit organizations to implement projects that cut pollution and energy costs. The bill also includes $7 billion for tribes, municipalities and nonprofits to install rooftop or community solar energy in disadvantaged communities. “The Drawing Studio is a great example of how nonprofits can better help our communities thanks to clean energy investments,” said Frank Velásquez Jr., Board President of The Drawing Studio Inc. and Founder of 4 Da Hood. “The direct pay assistance will allow us to go solar, and lower energy costs mean more resources dedicated to our programming that lift up Arizonans.” The IRA also increases funding for the Rural Energy for America Program (REAP), which provides grants and loans to farms and small businesses in rural America that invest in clean energy technologies like solar. “SUN has already helped thousands of Arizonans save money on their electric bills thanks to solar co-ops, and we’re very excited that the IRA incentives will allow us to expand our reach to both urban and rural communities,” said Adrian Keller, Arizona Program Director, Solar United Neighbors of Arizona. “Solar Gain is excited for these IRA investments and expects the solar industry to grow following its passage. Having federal, state, and local solar rules change every year or two has presented challenges in the past. The 10-year IRA horizon dramatically improves our business planning and growth outlook, “ said Robert Neifert, Director of Business Development, Solar Gain Inc. and Co-Chair of the Arizona Solar Energy Industries Association’s (AriSEIA) Public Policy Committee. “The most important changes are the tax credit reverting to 30%, and the incentive adders - Domestic Content, Low Income, and Energy Communities. For the Low Income Adder and Energy Communities, new guidance just came out in the last few weeks, but it seems many Tucson and surrounding area projects will benefit from the new bonus incentives.” AriSEIA is helping Arizonans go solar by helping improve the state, local, and utility policies. We’ve been able to score big wins with Arizona Public Service, Tucson Electric Power, Salt River Project, and the Arizona Corporation Commission, as well as meeting with co-ops and local governments to remove roadblocks and bring the latest technology advancements to Arizona. With some members of Congress seeking to undermine these critical investments, speakers all shared the urgent need for continued bold climate action. The event concluded with speakers urging the Biden administration to finish the job on climate and implement solutions for pollution to help slash climate pollution in half by 2030. Watch a recording of the event HERE.
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Eloy City Council
595 N. C Street Eloy, AZ 85131 RE: Opposition to Revision of the City’s Zoning of Solar Generating and Storage Facilities Dear Mayor and Council Members, 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 urge you to not revise the City’s Adopted Zoning Map to restrict solar and storage development. Pinal County has very serious air quality and water quantity challenges. Increased deployment of renewable energy can help alleviate both problems. Solar has no point source emissions and lower lifecycle emissions than fossil fuels. It also uses less water in operations and in its lifecycle than most other electricity generating technologies. Further, solar and storage have the opportunity to greatly benefit Eloy and Pinal County economically. A 25-year fiscal impact summary for a single project reflects the potential to bring in more than $2 million to the City, $12.5 million to the County, and nearly $17 million to the local school districts. That’s a total positive fiscal impact of nearly $32 million from a single project. Further, new companies are relocating to Arizona everyday and many of them are doing so to help meet their clean energy goals. The national Solar Energy Industries Association (SEIA) tracks clean energy procurement on behalf of businesses in their Solar Means Business Report and the numbers are staggering. Please reject the staff proposal. Certainly, do not exclude ongoing projects that have been engaging with the City in good faith from any potential “solar zone.” Any changes should only apply to prospective projects. Instead of blanket restrictions, please review each project on its own merits. Also, please reject the separation requirement as it will needlessly prevent important clean energy development. I have attached some information on the number of jobs attributable to solar in Arizona, the water usage of solar (operations and lifecycle), and the lifecycle emissions of different electricity generating resources. Sincerely, Autumn T. 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 and other Solar Stakeholders filed a response to ACC Staff's memorandum calling for comment on five areas of community solar to be resolved in a March policy statement by Commissioners. This is in addition to the various litigated proceedings. You can see the full filing at the link above.
AriSEIA filed the direct testimony of our two experts today in the Tucson Electric Power rate case. We are focusing on community solar and battery storage programs for residential and commercial customers. The testimony and exhibits exceed 400 pages. You can view the entire filing at the button above. TEP is due to file their response on February 15th.
AriSEIA filed expert witness testimony in the currently pending TEP rate case focusing on why the Commission should deny TEP's request to increase their return on equity (ROE). Additionally, several other parties filed testimony about items other than rate design on January 11th. You can view the docket here.
Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: Arizona Public Service (APS) E-32 L SP Tariff, Docket E-01345A-22-0281 Madam Chair and Commissioners, Pursuant to Decision No. 78317,1 APS was ordered to engage with stakeholders, namely the Arizona Solar Energy Industries Association (AriSEIA) and the Solar Energy Industries Association (SEIA), to redesign the E-32 L SP (Storage Pilot) rate tariff to increase customer adoption of the 35 MW commercial pilot program. AriSEIA appreciated the opportunity to provide constructive feedback and generally guide the tariff design process towards a solution that creates value for APS and the adopting customers. Throughout the duration of 2022, AriSEIA met monthly with APS and reiterated that rate optionality and investment certainty are key components of behind-the-meter energy storage adoption as not all customer loads are created equal, and few customers are able to benefit from existing tariffs using 15-minute interval demand charges. To that end, we collaborated with APS on the proposed volumetric, time-of-use (TOU) rate including a substantial differential between on-peak and off-peak rates which de-risks the customer’s energy storage investment in terms of achieving monthly savings while creating grid support during the utility’s coincident peak periods. Our assessment of the new rate tariff is that it will encourage participation in the pilot energy storage program through market-competitive payback opportunities. This rate tariff may also provide a foundation to develop more value-stacking opportunities for utilities such as distributed virtual power plants or similar grid-response programs. While the proposed E-32 L SP pilot revisions are a significant step in the right direction, we believe that further alignment with APS’ true coincident on-peak demand periods is important to creating an equitable program. To this end, we issued our recommendation to APS to limit the on-peak hours to Monday through Friday in lieu of across all seven (7) days of the week as the weekend load and marginal prices are typically much lower and do not merit the same TOU price differential. We look forward to continuing to work with APS as this program evolves. Thank you for considering these comments and we encourage you to adopt this rate in the first quarter of 2023 and to continue promoting more grid-interactive programs for customer-sited distributed energy resources. Respectfully, Autumn Johnson Executive Director AriSEIA 520-240-4757 autumn@ariseia.org John Mitman President, Board of Directors AriSEIA 480-251-2934 john@ariseia.org 1 Arizona Corporation Commission, Decision 78317, November 9, 2021, available here https://docket.images.azcc.gov/0000205236.pdf?i=1670984264693. Goodyear and Oro Valley Selected by the Department of Energy for $15K Solar Adoption Program12/8/2022 Goodyear and Oro Valley have been selected by the NREL, the National Laboratory funded by the Department of Energy, as one of 12 communities nationwide to adopt the innovative solar permitting platform SolarAPP+. Through the program, the two cities are eligible to receive $15,000 if SolarAPP+ is adopted successfully.
“We’re excited to see NREL’s announcement and the fact that residential solar is receiving its time in the spotlight here in these two cities,” said Autumn Johnson, Executive Director of the Arizona Solar Energy Industries Association (AriSEIA). “Syncing this program with the community’s burgeoning solar market validates all the hard work that AriSEIA and other advocates continue to do. Both in our market and across the country, ensuring that consumer interest is met with efficient permitting processes can really help ensure the solar industry continues to shine.” SolarAPP+ is an online platform that instantly issues permits for code-compliant residential rooftop photovoltaic (PV) and battery systems. As many consumers and local jurisdictions know, permitting can often slow the process for residential solar and battery installations. Current permitting delays are estimated to increase solar cost by $7,000 per project. With the convergence of increased consumer interest in solar installation and federal legislative momentum, clearing this potential bottleneck of long review timelines and complicated permitting applications is imperative. SolarAPP+ provides local governments, installers and homeowners with a streamlined process to more quickly achieve clean power generation from the sun. SolarAPP+ has already approved more than 10,000 permits across jurisdictions, including successful programs in Arizona, California, Illinois and Texas. Since SolarAPP+ provides an immediate permit for those communities vetted and determined to be eligible, projects have been installed about two weeks faster under the program. Regional Clean Hydrogen Hub Develops in the Desert Southwest
Energy leaders focused on developing low carbon economies in Arizona, the Navajo Nation, and Nevada have joined forces to develop a regional clean hydrogen hub in the Southwest. The Center for an Arizona Carbon Neutral Economy, first introduced in May 2022, is collaborating with partners in Arizona, the Navajo Nation, and Nevada to launch the Southwest Clean Hydrogen Innovation Network, or “SHINe”. On November 7, as its first step in developing the hub, SHINe submitted a concept paper to seek federal funding from the U.S. Department of Energy (“DOE”) for key clean hydrogen-focused initiatives including production, processing, storage, and delivery systems, community benefits, and other enabling infrastructure. Once fully operational, SHINe will help support DOE’s vision of a regional clean hydrogen hub that provides clean energy for the hard to abate carbon emissions in the transportation, industrial, and electricity sectors while maintaining a reliable and resilient electric grid. SHINe will also work to create economic development opportunities in the region. “A regional clean hydrogen hub focuses on developing a network of hydrogen producers, consumers and local connective infrastructure,” said Ellen Stechel, AzCaNE’s Executive Director. “The SHINe network includes salt cavern storage, heavy duty transportation, and distribution technologies that will help accelerate the use of clean hydrogen as a source of low carbon energy powering the economy.” In September, the DOE announced that up to $7 billion is available to fund the development of six to ten U.S.-based regional clean hydrogen hubs. Regional clean hydrogen hubs funding was outlined as part of President Biden’s Infrastructure Investment and Jobs Act, otherwise known as the Bipartisan Infrastructure Bill, which authorized up to $8 billion for at least four regional clean hydrogen hubs. These hubs are meant to help communities across the country benefit from clean hydrogen investments, quality jobs, and improved energy security. When coupled with other public and private investments in new clean hydrogen production, the hubs are expected to accelerate a nationwide clean hydrogen network and economy. Arizona, the Navajo Nation, and Nevada are in the nation's sunniest region, with significant available undeveloped land and abundant clean energy resources. Arizona also has the nation’s largest nuclear power plant producing 100 percent carbon-free electricity, and energy providers committed to reducing carbon dioxide emissions. Arizona also has world-class universities, established clean energy and clean hydrogen companies, and a healthy environment for innovation and start-ups. The Navajo Nation is one of the largest tribes in the U.S., has a land base larger than West Virginia, and is transitioning to a clean energy economy. Nevada is an early investor in clean hydrogen infrastructure, which will be necessary to integrate more hydrogen-fueled vehicles. These resources, along with the region’s proximity to California, will contribute to decarbonizing the region and ultimately the entire U.S. SHINe includes more than forty member organizations with expertise and operations throughout the region, including cities, clean energy companies, gas producing companies, non-profits, transit companies, universities, utilities, and others including the following:
THE SOLAR COALITION’S EXCEPTIONS AND PROPOSED AMENDMENT TO STAFF’S MEMORANDUM AND PROPOSED ORDER
DOCKET NO. E-00000A-22-0103 The signatories listed below appreciate the opportunity to continue their close involvement in the development of Arizona's community solar program and offer these Exceptions and Proposed Amendment to support the Commission as it decides how to move forward in the Arizona Public Service (APS) territory. This docket presents the Commission with an opportunity to provide savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. The signatories have been committed to participating in the working group discussions and docketing information to assist in the Commission’s consideration of a proposal for implementation of a community solar program, as envisioned in Commission Decision 78583 (May 27, 2022). The signatories have come together and presented a comprehensive community solar proposal to the Commission on August 26th based on vast experience in community solar programs around the country. The signatories represent a diverse range of interests and the program proposal submitted encompasses a consensus agreement among all fourteen (14) parties represented at the time of filing, was responsive to the directives in Commission Decision 78583 and to the questions raised during working group meetings, was based on sound compromise, and was tailored to Arizona’s regulatory environment. Unfortunately, Staff’s Memorandum and Proposed Order does not meet the requirements contained in Commission Decision 78583. After six (6) months of robust discussions and dozens of filings in this proceeding, Staff has not provided any substantive policy recommendations on the programmatic elements specified in Commission Decision 78583. Instead, Staff suggests that a substantial portion of the program details be moved to an evidentiary hearing process, which could lead to some elements being significantly delayed. This is not what the Commission directed. Six (6) months ago, the Commission discussed the process of developing a community solar program in detail and decided that this docket and the working group format was the appropriate pathway to create a program proposal on which to vote. The Commission directed Staff to put forth a proposal for implementation in advance of the November 2022 Open Meeting and further specified that the proposal should become effective within six (6) months of Commission approval. An evidentiary hearing would only serve to delay the implementation of a community solar program and needlessly increase the investment of time and resources from participants, Staff, and the Commission. Moreover, because a hearing process would trigger the Commission’s ex parte rules, such a proceeding would limit the Commission’s ability to discuss key program elements with the diverse range of stakeholders, which has been a key benefit throughout the working group process. An evidentiary hearing is simply not required to construct a workable community solar program. Additionally, Staff’s Memorandum and Proposed Order references only Arizona Public Service’s (APS) program proposal. As discussed in the signatories’ response to the APS proposal filed on October 7, 2022, the APS proposal will not result in competitive third-party development of community solar projects and, as such, restricts benefits that would be created for APS customers and should be disregarded. As detailed in The Potential Economic and Fiscal Impacts of Community Solar in Arizona report prepared by the Seidman Research Institute at Arizona State University, the benefits of community solar investment extend beyond subscribers to the program, to the entirety of the state. The rollout of three hundred (300) MW of community solar each year for ten (10) years (study Scenario #6) would contribute over five (5) billion dollars to state Gross Domestic Product (GDP), result in the creation of more than fifty-eight (58) thousand job years of total employment, and nearly four (4) billion dollars in labor income over a study period of thirty-five (35) years. Commission approval of the APS program proposal, as written, would deny these benefits to Arizonans across the state. Simply put, APS’s proposal is not community solar. The signatories have dedicated significant time and resources to help develop a program proposal pursuant to Commission Decision 78583 that includes program design elements based on successful community solar programs across the country and is responsive to feedback raised by parties participating in the working group. However, Staff’s Memorandum and Proposed Order does not reference the signatories proposal, despite the comprehensive and robust information that the signatories have continued to submit in this proceeding. The lack of discussion or consideration of any components of the signatories’ proposal is notable given that only two program proposals have been made in this proceeding – one by APS and one by over a dozen diverse signatories. Herein, the signatories offer Exceptions and a Proposed Amendment to the Staff’s Memorandum and Proposed Order. See Attachment A for the Proposed Amendment. The signatories offer the Proposed Amendment in an effort to assist the Commission in devising a community solar program that is consistent with the intent of Decision 78583 and the months-long discussions in the community solar stakeholder workshops. The participants to those proceedings spent considerable time and resources in those workshops, including the utilities and Commission Staff, and should not be made to duplicate the effort in an entirely new proceeding. The signatories thus urge the Commission to reject Staff’s proposal and adopt the Proposed Amendment, which balances the key program requirements that must be included for successful implementation and operation of the program. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: Support for Approval of a Distributed Demand-Side Resource (DDSR) Aggregation Tariff and Service Schedule, Docket No. E-01345A-22-0143 Madam Chair and Commissioners, Vote Solar, Solar United Neighbors, and the Arizona Solar Energy Industries Association (AriSEIA) urge you to approve the Arizona Public Service (APS) Company DDSR Aggregation Tariff, as amended by the Sunrun Proposed Amendment Number 1 (Amendment No. 1[1] and collectively, the DDSR Aggregation Tariff or Tariff).[2] Arizona is poised to continue to lead the adoption of demand side resources, including distributed battery storage, which benefits all customers. This DDSR Aggregation Tariff will reduce costs for all APS ratepayers, reduce peak capacity needs, and increase reliability and resilience by compensating aggregators for leveraging emerging technologies such as battery storage. The growth and declining cost of distributed storage technology creates a critical opportunity to leverage these customer-sited resources to provide grid benefits. APS’ innovative DDSR Aggregation Tariff is an important step towards realizing a more modern and resilient grid, and now is the time to begin leveraging the grid benefits it will provide. The Lawrence Berkeley National Laboratory (LBNL or the LBNL Report),[3] a third-party evaluator engaged by the Arizona Corporation Commission (Commission), found that participation in this program is likely to be higher than ever because of the investment tax credit (ITC) available for stand-alone storage and other solar incentives available under the Inflation Reduction Act (IRA).[4] If approved, this Tariff will result in actual projects that will generate real-world data about the value provided by participating aggregators. This data is valuable because it will provide detailed insight into the specific value of participating resources and can be used to refine future iterations of the Tariff to improve its cost-effectiveness. The LBNL Report and Amendment 1 rightfully question why APS chose to consider only five (5) years of benefits when the measures employed will bring ten (10) years benefit to the grid, commensurate with the typical lifetime of battery storage. We agree with Amendment 1 and echo its conclusion that this DDSR Aggregation Tariff will provide ninety-five percent (95%) more grid benefits than are presently quantified by APS, including the benefits associated with daily shifting, avoided outages and associated costs, added grid resilience, and avoided carbon emissions. Current benefits under the LBNL Report include: Significant Peak Load Reduction for APS Customers - The LBNL Report found that participants in the program will reduce peak period loads substantially during weekdays by installing battery storage to existing rooftop solar. This reduces costs for all utility customers Increased Reliability and Resilience for Participants - The LBNL Report found that participants who add battery storage to existing rooftop solar will benefit from an annual cost savings of $14/yr. for Flagstaff, $25/yr. for Phoenix, and $29/yr. for Yuma. The LBNL Report also found participants will experience significant resilience benefits, valued at between $2,000 and $6,000 per customer.[5] This is a step towards additional energy efficiency in Arizona. Overall Cost Reduction for Ratepayers - The LBNL Report found that, from a ratepayer perspective, battery storage is cost neutral and does not result in cost shifting (the study did not consider cost for reconfiguration of an existing rooftop array to incorporate a battery). Further, LBNL found that if evaluated over 10 years, as they recommend, the benefits of the resources chosen through the DDSR Aggregation Tariff equal or exceed its costs.[6] This means that both participants and non-participants will benefit from ratepayers with battery storage. We support Sunrun’s proposed changes to the Tariff. These changes include requiring APS to periodically issue a minimum number of requests for proposals to drive competition, lowering bidder fees to encourage aggregator participation, accepting bids from aggregators that partially provide the services sought, and creating an open Tariff that all qualified aggregators may leverage, informed by cost data generated through the periodic RFPs. These changes improve the Tariff by allowing the program to develop to its full potential. Making the Tariff available to all aggregators will help reach the realized goal of bringing the Tariff to ratepayers. While the initial cost savings may seem minor (and also considering the overall benefits are undercounted by 95% in the study), the benefits provided by this DDSR Aggregation Tariff are very significant. Overall, LBNL's expert analysis leads to the conclusion that this innovative Tariff is cost-effective. We strongly urge the Commission to move forward with approving this Tariff in this docket at the November Open Meeting. Failure to approve the DDSR Aggregation Tariff will put Arizona behind the curve of this fast-changing technology and forgo an opportunity to support a program that strives for a positive community outcome and can deliver significant cost and grid resilience benefits. We are eager to participate in the ongoing efforts of the DDSR Aggregation Tariff, which will provide benefits to all ratepayers for many years to come, and feel confident that collaboration with other organizations, consumer advocates, Staff, and the utility will contribute to a bright future for residential solar in Arizona. Thank you for your consideration of this important matter. Respectfully, Autumn T. Johnson Executive Director Arizona Solar Energy Industries Association (AriSEIA) autumn@ariSEIA.org 520-240-4757 Bret Fanshaw Western Region Director Solar United Neighbors (SUN) bfanshaw@solarunitedneighbors.org 602-962-0240 Kate Bowman Interior West Regulatory Director Vote Solar kbowman@votesolar.org 703-674-8637 [1] Arizona Corporation Commission’s Decision No. 78165 (E-10345A-19-148), Filed July 28, 2021, available here https://docket.images.azcc.gov/0000204280.pdf?i=1667008921051 [2] Sunrun’s Exceptions to Staff’s Memorandum and Proposed Order, Filed October 26, 2022, available here https://docket.images.azcc.gov/E000021983.pdf. [3] Arizona Corporation Commission’s Memorandum Re: Lawrence Berkeley Laboratory Reports, Filed September 30, 2021, available here https://docket.images.azcc.gov/E000021442.pdf?i=1667005959409 [4] Arizona Corporation Commission’s Memorandum Re: Revised Lawrence Berkeley Laboratory Report, Filed October 21, 2022, available here https://docket.images.azcc.gov/E000021864.pdf?i=1667005959409 [5] See LBNL Report at page 12. [6] See LBNL Report at page 15. |
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