Comments of the ESA re: Arizona Corporation Commission Docket No. L-00000D-14-0292-00169

Posted: October 21, 2014 - 17:00 / AZ / ESA Filings

Pursuant to the Comment Opportunity in the Arizona Corporation Commission
(“Commission”) open DOCKET L-00000D-14-0292-00169, the Energy Storage Association (“ESA”) appreciates the opportunity to submit the following comments and
information for the Commission’s consideration.

The ESA enthusiastically supports the request put forth by Arizona Public Service
(“APS”) and the Residential Utility Consumer Office (“RUCO”) to have the Arizona
Corporation Commission approve conditions for Certificate of Environmental
Compatibility number 169, laid out in Exhibit A to their request for review. The ESA
believes that the (1) issuance of an independently monitored RFP for resource
procurement that include alternatives to traditional generators, including demand side resources and storage; (2) 10% floor for simple-cycle gas procurement to include energy storage capacity before 2021; and (3) issuance of a competitive RFP for storage project(s) totaling 10 MwH by 2018 will enhance grid performance resiliency, increase system efficiency, and ultimately provide significant cost benefits to Arizona consumers.