first solar filing to azcc

7/29/2019 First Solar Filing to AZCC

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BEFORE THE ARIZO r o N ~ O ~ ~ S S I O NBOB s r m ,

Chairman2013 SEQ I8 P r: 21

GARY PIERCE,BRENDA BURNS,CommissionerCommissionerROBERT L. BURNS,CommissionerSUSAN BITTER SMITH,Commissioner

IN TK E M A E R OFTHEAPPLICATIONOF ARIZONA PUBLIC SERVICE COMPANY) Docket No. E-0134SA-13-0248FOR APPROVAL OFNET METERING 1COST SHIFT SOLUTION 1

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Comments of First SolarFirst Solar, Inc. (First Solar) respectfUy submits these Comments to the ArizonaCorporation Commission (ACC) to provide its perspective on the Arizona PublicService Company (APS)et metering cost shift solution application.On November I , 2006, after a three-year review process, the ACC adopted a renewableenergy standard (RES]. The RES requires Arizonas regulated utilities to generate I5percent of their energy from renewable resources by 2025 in order to generate cleanenergy to power Arizonas future. Given Arizonas potential renewable genera~ionresources, it was clear that this RE S goal was likely to be met largely by solar electricitygeneration.Adopting the RES was a forward-Iooking step. In 2006, the solar industry was stillnascent. Therewas very little experience to guide predictions of solar cost retrajectories, so~arsgrowth path,applications that made the mostAt the time, only 140 MW of sotheU.S. as awhole, of which 5MW non-residential {including

dogies, or solarItaic CPV) i ~ ~ l a t j o n sad been installed in(MW) was considered residential and 90buildings, retail stores, utility installations,

Arizona Corporation Com missi on (ACC). Com missioners Approve Rules requiring 15 Percent of Energy fram Renewttblesby 2025. Press Refease. 1 No v 2006.

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and military installations)2. The largest PV systems in the U.S., all located in California,were no larger than 1 M W in size. Even Germany, which led the world in PV in 2006,had not yet reached 1,000MW of total installations. In Arizona, just over 2 MW of PVcapacity was installed in 2006, for a total of 19MW of PV installed in Arizona by theend of that year?The cost of PV in 2006 was on the order of $8-9.0O/ nstalled watt: and utility scalePV systems effectively did not exist.Given the relative inexperience with solar and its high cost both in general and in Arizonaspecifically, it made sense at the time to adopt policies and initiate a range of programsand generous subsidies to gain experience across a variety of solar options. Theseincluded a 30% distributed generation (DG) carve-out as part o f he RES, an upfrontsubsidy from A P S of $3 .OO/watt installed for rooftop systems, and net energy metering(NEW). Since 2006 the Commission has adopted new rate basing methods which havehelped facilitate new solar resources.The solar industry has matured significantly since 2006 and installations in Arizona. havegrown exponential1 : 1,097M W of sofar-generating facilities were installed in Arizonaby the end of 2012, making Arizona second in the nation only to California. Even moresignificantly, the price of PV has fallen precipitously. Recently released data by the SolarEnergy Industry Association and GTM Research show an average cosbinstalled watt forresidential rooftop PV of $4.81 and the average costlinstalled watt forutility scalesystems as $2,seven, years ago, First Solar has consistently said that as the cost of solar comes down,so must solar subsidies. For the solar industry to be sustainable and maintain its publicand political support, subsidies should be appropriate to the economic, environmental andsocietal value provided by solar energy. In locations when: it is not yet possible tocompete entirely without subsidies,we should aim to achieve solar POlowest overall cost with the intent of creating a level playing field with other energysources over time.

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No one could have predicted these cost reductions two, much less

In light of the experience gained over the past seven years and the significant costreductions during that time period, it is appropriate to review and revise the programs andU.S.Dcpartnlent of Energy. Energy Efficiency & Renewable Energy (EERE) Network News. Report: U.S. Solar Cell MarketIncreased 33 Percent in 2006 , 28 March 2007. Web. 19 September 2013. henvood, Larry. US Solar Market Trends 2007. Intefstatc Renewable Energy Council. August 2008: pp. 15& 9. In 2006, a

1 MW solar thermal electric plant was constructed in Arizona, This wasto 1991.from 1998 io 2012. Lawrence Ber hley National Laboratory.July 2013,

new U.S. sMW wereonstructed in 15 years. Nine solar thermal electric plants with a capacitBarbose, Dargouth, Weaver and Wiser. Tracking the Sun Id, An Histor id Summary of the InstaIled Pr iceofPhotovoltaicsSolar Energy Industries Associatio n (SEIA). U.S. Solar Industry Year in Review 2w9. I5 April 2010.SEINGTM Research.U.S. olar Market Insight@Report:2012 Year in Review: ExecutiveSummary. 013.SEINGTM Research.U.S. Solar Market Insight@ Report. Q2 2013 ive Summary. 2013: pp. 14-15. It should benoted that these figures represent national averages based on d&tacol SEIA and OTM Research, which likely doesnotinclude all price points in the market Further, as noted in the report, actual pricing will vary by geography and jurisdiction .

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subsidies put in place in 2006 in order to reflect current market realities and to provideboth value and continued solar growth for Arizona, and it is reasonable for the ACC toconduct such a review.For example, in 2006, when the ACC proposed a distributed generation carve-out,community solar programs that achieve most, if not all, of the DGpolicy goals were noteven an option for consideration, While there are several models of community solarprograms, in general they are smaller installations (


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bler. These grid benefits of larger scale solar were certainly not foreseen in2006. In addition, increasingly reliable forecasting also makes solar from utility-scalesystems a much inore predictable generator of electricity. Furthemiore, these larger scalesystems can provide all of these attributes, as well as the environmental benefitsassociated with all solar applications, at a significantly lower cost per kilowatt hour dueto the cost economies associated with large scale.The 2006 RES and the policies adopted to achicve the RES mandate have successfullyfacilitated thc growth and maturation of solar in Arizona. The past seven years have alsoprovided valuable experience to help guide todays decisions about the nextES-relatcd policies, The ACC can now use real experience and data to evaluate thevarious solar options available and their costs and benefits, something that was notpossible in 2006, and use that information to guide its decision about NEM.The objective of this next phase of solar policy should be to maximize the solar benefitper dollar spent; fairly compensate or solar generation without discrjmjnating amongvarious solar app~icat~ons;ncrease access to green electricity for all ratepayers; andreduce the cost of achicving Arizonas renewable energy goals. The current review andproposed revision of NEM have been criticized by some as anti-solar. We believe justthe reverse to be true. Unless the regulatory structure is ad-justed to incorporate currentmarket realities, the unforeseen economic impact obacklash against solar of all sizes and types. The issue is not whether Arizona shouldcontinue to develop large amounts of new solarshape and fine-tune its poIicies to achieve this objectiveACC needs to take the lead to develop a solar plansustainable solar industry by developing the appropriate solar regulatory structure for thefuture, not the past. This plan should consider all the salient operational, financial, marketand resource pl~nningactors in order to meet customers solar needs at the lowestaverage cost for ALL customers. W e believe that the AGC has the full range ofinformation needed to make a decision now. Tt is important that this review of policyproceed expeditiously and not be deferred.

M may result in an indiscri~inateeration but rather how Arizona shoulditably and at lowest cost. Thecreate a robust and

Sincerely,/

FIRST SOI,AR, lN(&

Suite 600Tern e. Arizona 85281(60284 14-9300

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ORIGINAL and thirtegn (1 3) copies of theforegoing filed this 18 day of September, 2013, with:Docket ControlArizona Corporation Commission1200 W, Washington StreetPhoenix, Arizona 85007G a P Y of the foregoing hand delivered this18' day of September, 2013, to:Rob Stump, ChairmanThe Arizona Corporation Commission1200 W. Washington StreetPhoenix, Arizona 85007Gary Pierce, CommissionerThe Arizona Corporation Commission1200W. Washington StreetPhoenix, Arizona 85007Brenda Burns, CommissionerThe Arizona Corporation Commission1200W. Washington StreetPhoenix, Arizona 85007Robert L, Burns, CommissionerThe Arizona Corporation Commission1200 W. Washington StreetPhoenix, Arizona 85007Susan Bitter Smith, CommissionerThe Arizona Corporation Commission1200 W. Washington StreetPhoenix, Arizona 85007SteveOlea, DirectorThe Arizona Corporation Commission1200 W. Washington StreetPhoenix, Arizona 85007

Utilities Division

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first solar filing to azcc

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