Comments on Modifications to the Arizona Corporation Commission’s (ACC’s) Energy Rules and Notice of Proposed Rulemaking (Docket No. RU-00000A-18-0284)

Comments on proposed modifications to the Arizona Corporation Commission’s (ACC’s) Energy Rules (“Proposed Rules”) and the December 1, 2020 Notice of Proposed Rulemaking. Our primary comments focus on required documentation for an electric utility to “demonstrate its ability to deliver energy from Clean Energy Resources and Renewable Energy Resource to its Customers” in Sec. R14-2-2704(D).