May 25, 2022
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
Re: APS 2022 RES Implementation Plan, Docket No. E-01345A-21-0240 and Generic Community Solar Docket, E-00000A-22-0103
Madam Chair and Commissioners,
Vote Solar, Solar United Neighbors (SUN), the Arizona Solar Energy Industries Association (AriSEIA), and the Institute for Local Self-Reliance (ILSR) appreciate the opportunity to respond to the discussion preceding the passage of Commissioner Tovar’s 3rd Revised Amendment #1 during the May 18, 2022 Open Meeting. Our organizations thank the Commissioners for their support of this amendment and we look forward to participating in the community solar working group.
We seek to offer clarification regarding the work of our organizations and intent of the national petition mentioned during the Open Meeting. We believe that the decision to remove our organizations from the amendment is based on a misunderstanding of our support for a petition to the Federal Trade Commission (FTC). We joined the petition because it seeks to protect consumers from financial scandals and antitrust violations by utilities. The petition does not question or limit the Commission’s authority to regulate utilities in the state, nor does our support for it implicate the good faith efforts our groups have undertaken to build consensus among the solar industry, the utility, and advocates regarding a community solar program in Arizona. We would be happy to meet with any Commissioners interested in the petition to explain its substance and intent in greater detail.
AriSEIA, SUN and Vote Solar all have an established record of engagement at the Commission, where we are committed to working in good faith to support a transition to clean energy in Arizona. Similarly, ILSR maintains a positive record of engagement on regulatory issues around the country. We hope that this letter serves to clarify our commitment to advancing community solar in Arizona through the collaborative process approved by the Commission. We look forward to working with all stakeholders involved in the working group and to the Commission’s consideration of the recommendations that result from the working group in November.
Autumn T. Johnson
Arizona Solar Energy Industries Association (AriSEIA)
Arizona Program Director & West Region Director
Solar United Neighbors (SUN)
Interior West Regulatory Director
Co-Director of ILSR & Director, Energy Democracy Initiative
Institute for Local Self-Reliance (ILSR)
 FTC Legal Petition and Press Release, available here https://biologicaldiversity.org/w/news/press-releases/egal-petition-seeks-federal-trade-commission-investigation-of-energy-utility-abuses-2022-05-18/.