Update: Arizona Staff Raise Proposed Eligibility Threshold For Retail Electric Choice, Aggregations, In Revised Draft

July 3, 2019

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Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Staff of the Arizona Corporation Commission have filed revisions to a report regarding "possible" modifications to the ACC's retail electric competition rules, with such modifications raising the eligibility threshold for a customer to take retail electric choice

As exclusively first reported by EnergyChoiceMatters.com, Staff's draft filed on July 1 provided that customers eligible for retail electric choice would be defined only as all non-residential consumers who use more than 100 kW demand monthly. Under the initial draft, non-residential consumers who do not meet the monthly demand of 100 kW could, within the same service area, aggregate to combine and consolidate their loads, the aggregation of which must total at least 1 MW.

Both the individual and aggregation thresholds have been modified under Staff's revised draft

Specifically, the revised draft filed on July 2 provides that customers eligible for retail electric choice would be defined only as all non-residential consumers who use more than 400 kW demand monthly.

Furthermore, the revised draft modifies the aggregation threshold such that non-residential consumers who do not meet the monthly demand of 400 kW could, within the same service area, aggregate to combine and consolidate their loads to take retail choice only if the aggregation totals at least 5 MW. We'd note that the aggregation of customers as a means to meet this threshold is based on Staff's original description of the draft rules (updated with the new threshold), but that the actual language could use clarification, as it says that an electric service provider (ESP, or retail supplier), or CCA, may aggregate to meet this threshold, and that such ESP or CCA (with no language concerning the customers) would, "be eligible for competitive electric services." In other words, the rules say that the ESP or CCA would be eligible for competitive electric services via the aggregation, not the underlying customers (though, as summarized by Staff, the intent of the language is to allow smaller non-residential customers to aggregate to take competitive retail supply)

While not explicitly stated in the definition of aggregation, the draft rules at various points provide that aggregations, except municipal aggregations, are limited to non-residential customers

Municipal aggregations would be required to meet the 5 MW threshold as well, under the revised draft, but, as previously reported, municipal aggregations include "residents", per the definition of community choice aggregation

Docket E-00000A-18-0405

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