Federal & Other (Pending)

Download our briefs covering policies that are being considered by Federal entities that may affect Arizona or are being considered by other state and localities outside of Arizona that may be of interest to our state.

Crowdfunding and Renewable Energy: Could it Revolutionize Large-Scale Renewable Project Financing?

Published March 2014
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The essentials

  • Crowdfunding presents a new model for public investment in large-scale renewable projects.
  • Crowdfunding would allow businesses access to an estimated $2 trillion in capital from the general public. It has been successfully applied to financing utility- and commercial-scale solar projects by Mosaic, a California-based start-up company.
  • Rewards-based crowdfunding (as opposed to “donation-based” crowdfunding) is the funding of a company or project by selling small amounts of equity to many investors with an expectation of return on investment.
  • At this time, only residents of New York and California can participate in crowdfunding investments.  However, the 2012 JOBS Act obligates the SEC to issue regulations allowing start-up companies to raise up to $1 million in capital via crowdfunding from the general public across the country.
  • The new crowdfunding regulations will likely be issued in the third quarter of 2014.
  • When crowdfunding regulations are issued, it will allow the general public to invest small amounts in renewable energy with a reasonable expectation of return on investment.

NGS Part III: EPA's Proposed Regulations for the Navajo Generating Station update

Published September 2013
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The essentials

  • A comparison of the EPA’s Best Available Retrofit Technology rule requiring SCR against the Technical Work Group ‘s (TWG) two proposals.

Master Limited Partnerships

Published August 2013
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The essentials

  • A Master Limited Partnership (MLP) is a business structure that is taxed as a partnership but has the ability to issue stock ownership interests much like a corporation.
  • Federal legislation has boosted market capitalization investments in MLPs from $2 billion in 1994 to ~$480 billion in 2013.
  • The MLP Parity Act (introduced to the House and Senate on April 24, 2013) proposes to expand MLP eligibility to the renewable energy.

Energy Imbalance Markets Part II: A review of the EIM Proposal for the Western Interconnection and potential impacts

Published July 2013
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The essentials

  • The Public Utility Commission Energy Imbalance Market has proposed an EIM for the Western Interconnection 1.
  • The National Renewable Energy Laboratory Draft Report on EIM Analysis shows an annual societal operating benefit of between $146 million and $300 million for the Western Interconnection EIM with full participation.
  • Critics of the plan cite concerns of cost-shifting, jurisdictional issues for local governments to enforce penalties, and questions of reliability.

The SunZia Project and Rapid Response Team for Transmission brief

Published June 2013
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The essentials

  • The SunZia high-voltage transmission line project will span 500 miles over a portion of public land managed by the Bureau of Land Management (BLM), originating in NM and terminating in AZ.
  • It is proposed by the SunZia Transmission LLC that the 500 kV line will provide increased transmission capacity for renewable energy projects.
  • The Bureau of Land Management (BLM) identified a preferred route for the SunZia line that partly passes close to the U.S. military’s White Sands Missile Range (WSMR).
  • U.S. military officials oppose this preferred route and consider it a threat to national security.
  • In October 2011, the Obama Administration designated the SunZia Project for accelerated permitting and construction through the Rapid Response Team for Transmission (RRTT) to encourage greater coordination between federal agencies.

Introduction to Energy Imbalance Markets: Part I

Published May 2013
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The essentials 

  • An Energy Imbalance Market (EIM) would pool in electricity generation within a region and dispatch resources.
  • This could moderate the variability of renewable generation resources and electricity demand on a least-cost basis. Participation is voluntary.
  • The Public Utility Commission Energy Imbalance Markethas proposed an EIM for the Western Interconnection.
  • The EIM would lead to lower reserve requirements and increases reliability especially during unexpected generation outages and high peak demand.
  • The EIM brings with it concerns about new reliability problems and costs that could outweigh the estimated benefits.

NGS Part II: Proposed NOx Emissions Guidelines for the Navajo Generating Station

Published April 2013
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The essentials

  • The Environmental Protection Agency’s (EPA) Regional Haze Rule, authorized under the Clean Air Act, requires a state or federal agency to draft plans to reduce haze and increase visibility in the nation’s National Parks.
  • On January 18, 2013, the EPA issued its air pollution limits proposal for the Navajo Generating Station (NGS) due to its proximity to the Grand Canyon National Park and ten other Class I Federal protected areas, including seven other National Parks and Wilderness Areas. The NGS is one of the largest sources of nitrogen dioxide (NOx) emissions in the United States.
  • Under these rules, NGS’s owners will be required to install Selective Catalytic Reduction (SCR) technology by 2018. Due to the NGS’s economic importance to several Native American tribes, the EPA is considering allowing a five-year extension for the installation.
  • UPDATE: The EPA is accepting public comments through August 5, 2013.

Navajo Generating Station Background Sheet: pre-EPA NOx and SO2 rulemaking

Published June 2012
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The essentials

  • The Navajo Generating Station (NGS) is a 2,250 megawatt coal-fired power plant located a few miles from the beginning of the Grand Canyon, within the Navajo Nation, near Page, Arizona
  • About 25% of the electricity generated at NGS is dedicated to pumping Central Arizona Project (CAP) water from the Colorado River from behind Parker Dam over 300 miles to metropolitan Phoenix and Tucson.
  • The NGS draws its cooling water from nearby Lake Powell.
  • The Environmental Protection Agency is in the process of issuing new guidelines restricting air pollutants from industrial facilities that restrict visibility, including fine particulate matter (PM2.5), nitrogen oxide (NOX) and sulfur dioxide (SO2).
  • The regional haze reduction guidelines will impact NGS operations, which in turn could impact community health and water quality locally, as well as water quality, water availability, and water rates in those areas served by the CAP.
  • It is feasible that these new guidelines may influence a decision to close NGS.

FERC Order 1000

Published April 2012
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The essentials

  • The Federal Energy Regulatory Commission (FERC) regulates interstate electricity commerce over long-distance transmission lines.
  • FERC recently issued Order No. 1000, with an initial compliance deadline of October 11, 2012.
  • The purpose of FERC Order No. 1000 is to create more competitive wholesale electricity markets by removing barriers to building new interstate transmission lines.
  • The new ruling is partly aimed at enabling regions to make transmission investments necessary to meet state renewable energy policies.

BLM RDEP draft EIS

Published March 2012
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The essentials

  • The BLM proposes to support renewable energy development while also protecting and restoring landscapes in Arizona through its Restoration Design Energy Project (RDEP).
  • The RDEP will streamline part of the initial process for renewable energy development on public lands by vetting the areas before renewable energy developers submit proposals.
  • In the BLM’s draft environmental impact statement (DEIS), the BLM identified and analyzed six Alternatives plus the required No Action Alternative.
  • The BLM’s preferred alternative is Alternative 6 Collaborative-based Renewable Energy Development Areas (REDA) and the Agua Caliente Solar Energy Zone (SEZ). Alt. 6 allows for 237,100 acres for REDAs and 6,770 acres for SEZ.
  • The public comment period on the DEIS ended May 17, 2012.