April 26, 2019

ESA Comments: Review, Modernization and Expansion of the Arizona Renewable Energy Standard and Tariff Rules and Associated Rules

Docket No. E-00000Q-160289

Comments of the Energy Storage Association

Pursuant the Arizona Corporate Commission’s (“Commission”) Notice of Inquiry filed in Docket Number E-00000Q-160289 on February 22, 2018, ESA respectfully submits these comments for the consideration of the Commission.

ESA applauds the Commission for its leadership in opening a proceeding to investigate new and innovative policy mechanism to drive the State of Arizona’s electric system towards a more efficient, flexible, sustainable and affordable future. The proposals presented in the Energy Modernization Plan carry the potential for doing just that, and merit further investigation and development. ESA appreciates the opportunity to provide information and input to the Commission in this docket. In these comments, ESA provides recommendations on the development of a storage deployment target, the necessary reforms to the integrated resource planning (“IRP”) process to level the playing field for energy storage technologies, and initial comments on the Clean Peak Standard proposal.

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