May 13, 2022
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
RE: Community Solar Support in Docket No. E-01345A-21-0240
Madam Chair and Commissioners,
The Arizona Solar Energy Industries Association (AriSEIA) very much supports the Commission in an effort to move forward with community solar. Community solar provides a unique opportunity for residential and small business customers to participate in the clean energy transition when they otherwise would not be able to. Community solar is a useful opportunity for those that cannot utilize rooftop solar for practical or financial reasons to be able to join together in projects that are at strategically valuable locations, still close to distribution opportunities. It also provides a way to utilize otherwise underutilized brownfield and agricultural sites.
AriSEIA has many member companies that are very interested in investing in Arizona. Community solar provides another avenue for the solar industry to encourage job creation and economic growth in our state. As noted by the Coalition for Community Solar Access (CCSA), several university studies have been conducted that reflect the job and revenue opportunities for states that adopt community solar policies. Failure to act allows other states, including some of our neighbors, to seize those opportunities from us, including New Mexico, Colorado, and California. Arizona should be a leader in solar in the nation. We encourage the Commission to signal to the industry that Arizona very much wants those jobs and investment dollars.
We are eager to participate in the working group and feel confident that collaboration with other organizations, consumer advocates, Staff, and the utility will contribute to a better outcome. While there may not be consensus today on what the outcome of the group should be, Commissioner Kennedy’s Proposed Amendment No. 1 is an especially important step towards creating a thoughtful and workable program. AriSEIA encourages the Commission to utilize the working group to explore all of these numerous benefits, as well as utilize the lessons learned from other states that have already adopted community solar policies. All of the details need not be fleshed out today, as that is the very purpose of the working group.
AriSEIA is aware that there are presently two different avenues put forward as to how to commence with community solar in Arizona. We do not feel these opportunities are incompatible with each other. We fully support moving forward with a working group in the Arizona Public Service (APS) Renewable Energy Standard and Tariff (REST) docket, as well as utilizing the new docket for fact finding and programs in other service territories if a REST docket is unavailable.
We urge the Commission to move forward with a working group in this docket at the May Open Meeting and recommend that a final vote on the outcome of the working group be scheduled for the October Open Meeting.
/s/ Autumn T. Johnson
 Coalition for Community Solar Access, May 13, 2022 Letter, available here https://docket.images.azcc.gov/E000019242.pdf.
 Commissioner Kennedy Proposed Amendment No. 1, available here https://docket.images.azcc.gov/E000018712.pdf?i=1652155834150.