Comments to the Arizona Corporation Commission (ACC) on Possible Modifications to Energy Rules

Comments on elements of Staff’s February 18, 2020 Third Revised Proposed Draft Rules (“Staff’s Draft Rules”), the Joint Stakeholder Proposal for New Energy Rules (“the Joint Stakeholder Proposal”), and Stakeholder Meetings and Workshops held March 10-11, 2020 (“the Workshops”). Comments are focused on requirements for demonstrating compliance with the Renewable Energy Standard and Tariff (REST) in Staff’s Draft Rules, the Clean Energy Standard (CES) and Distributed Renewable Energy Requirement (DRER) in the Joint Stakeholder Proposal, and Clean Peak Standards (CPS).