All right everybody it is just after one so we're going to go ahead and get started. Let's go on the record. Good afternoon. This is the second and final oral proceeding in the matter of the proposed modifications to the electric energy efficiency standards rules, docket number RE00000A twenty four zero zero twenty five. I'm administrative law judge Chris Nichols, and I have been assigned to preside over this matter. Chris Nichols. We have a Spanish language interpreter with us today who will be translating my introductory
and closing remarks as well as the comments of any Spanish speaking members of the public. The notice of rulemaking docket opening and notice of proposed rulemaking for this matter were published in the Arizona Administrative Register on 10/24/2025. This oral proceeding is being held pursuant to Arizona revised statutes section forty one ten twenty three to allow adequate discussion of the substance and form of the rule proposal and to allow persons to ask questions and present oral argument, data, and views on the proposal.
In a moment, I will ask staff whether they would like to present any additional information regarding the rulemaking proposal, and I may ask questions of staff to clarify the record. I will then take public comment. If you are physically present and desire to speak, please complete a speaker slip and bring it to me. If you are on the phone, please tell the person who answers both your name and that you desire to speak. Staff, may I please have your appearance for the record? Good afternoon, your honor. Nicole Leighton from the office of general counsel on behalf of staff. And with us today from staff is,
again, Barbara Keane and Renell Paladino. Staff would like to, for the benefit of those present today that may not have been on Tuesday, largely restate the presentation they gave on Tuesday as well as provide a bit of a clarification on one point. Thank you, miss Layton. Good afternoon, all. Staff, you may proceed. Good afternoon. I am Barbara Keane of commission staff. With this rulemaking, staff is recommending repeal of article 24 of title 14 chapter two of the Arizona Administrative Code as directed by the commission.
Article 24 is the Electric Energy Efficiency Standards rules, which I will refer to as the Electric EE rules. The commission adopted the Electric EE rules in decision number 71,819 in August 2010. The electric EE rules apply to class a public service corporations that provide electric service to retail customers in, excuse me, in Arizona unless the utility is an electric distribution cooperative that has fewer than 25%
of its customers in Arizona, the rules designate these utilities as affected utilities. The rules were designed to cause utilities to achieve energy savings through cost effective energy efficiency programs in order to ensure reliable electric service at reasonable rates and costs. Energy efficiency means the production or delivery of an equivalent level and quality of end use service using less energy or the conservation of energy by end use customers.
Energy efficiency is a type of demand side management, DSM. The rules also identify as DSM any measure designed to result in reduced peak demand or shifting of electricity consumption to off peak periods. The commission adopted the electric EE rules in an effort to ensure reliable electric service at reasonable rates and costs and to minimize the overall adverse environmental impacts resulting from electric utility service to the extent feasible. Among other things, the electric EE rules require affected utilities to,
by 2020, achieve cumulative annual energy savings equivalent to at least 22% of the affected utilities prior year retail energy sales through cost effective programs. The goal for electric distribution cooperatives is 75% of the goal for investor owned utilities. They have to file an implementation plan for commission approval on June 1 of each odd year or annually at the election of the utility, including a description of each DSM program to be implemented or continued and estimates of
the annual KWH and KW savings projected to be obtained through each DSM program. File an annual progress report by March 1 of each year providing information on each affected utilities commission approved DSM programs and measures and file a mid year status report by September 1 of each year including a tabular summary showing semi annual expenditures compared to annual budget and participation rates. The electric utility subject to the electric EE rule
excuse me. The electric utility subject to the electric EE rules who have met or exceeded the standard of 22% in 2020 are Arizona Public Service Company, Trico Electric Cooperative, Tucson Electric Mohave Electric Cooperative, Morenci Water and Electric Company, Nav Apache Electric Cooperative, and Sulphur Springs Valley Electric Cooperative. The electric EE rules went into effect in 2010, but many of the utilities had EE programs in place before that date. For example,
APS has provided information in its annual progress report on program to date DSM societal benefits from January 2005 through December 2024. Utility program costs over those years totaled $941,563,758 But the amount of net benefits of those DSM programs as resource options,
including incremental measure costs, utility costs, and carrying costs as a component of avoided capacity costs, totaled more than $1,432,000,000 Repeal of the rules would reduce a commission staff to review those documents. Staff believes that the repeal of the rules will not eliminate energy efficiency programs. Utilities will continue to have the ability to file for approval of modifications to existing programs or new programs. Repeal of the rules would not eliminate any commission approved surcharges unless the superseding commission
decision in either rate case proceeding or separate EE filing is issued. Finally, staff does not plan to provide oral responses to comments received at today's proceeding. As required by decision number 81496, staff intends the written and oral comments received concerning this rulemaking in its memo to be filed in the docket on January 5. Thank you, Ms. Keane. Alright. Let's, go ahead and move on to public comment portion of this proceeding. I will now begin to take public comment. I may ask questions to clarify a speaker's position for the record.
In addition, I will allow staff the opportunity to respond to statements and to ask questions to clarify a speaker's position for the record. I will also have staff respond to any substantive questions posed by speakers regarding the proposal. I may ask excuse me I may have staff respond to any substantive questions posed by speakers regarding the proposal. For each of you who has provided your name to speak, I will call on you by name and will spell out your last name. When I call on you, if you're here in person, please step forward to the podium.
If you're on the phone, please unmute yourself by pressing star six, then please confirm or correct the spelling of your name and provide the city or town where you live. If you're speaking on behalf of an organization, please identify the organization and your position with it. Please remember that each speaker is requested to limit their comments to three minutes. If you are reading from prepared remarks, please pay extra attention to speaking slowly and pause occasionally. We also would ask you to file your prepared comments with the commission. If you're using the services of our translator today,
please pause frequently so that the translation can be made. Alright. And I will begin with our in person speakers beginning with Marissa Ruiz, r u I z. Please come forward. And if you could just make sure that the, green light on the microphone there is on. Tis. Good. Go ahead. Hello. My name is Rish Ruiz, and I'm here first and foremost to say that I oppose the repeal of energy efficiency standards. I am a climate activist. I have a master's in this subject, and I'm a native Arizonan, so this is near and dear to my heart.
I'm gonna switch it up real quick. A man walks into a bar. Right? And I don't know what this guy did, but when he gets there there's a very long line of people and they all take turns punching him. First of all, that's the punchline. Second of all, thank you. As as this happens, another man walks into the bar and he sees this guy getting punched and he decides, I don't wanna get punched. I'm scared of that, and it hurts, so he goes home. That is an emotionally driven decision. I have heard a lot of people say that EE standards are emotionally driven and that climate activists are fear mongering, creating a emotionally driven and that climate activists are fear mongering, creating a sense of doom and gloom.
Where does that come from? Commissioner Thompson himself. But the thing is we're human, and emotions are an inevitable part of consciousness, unfortunately. Fear tells us when something is wrong, and the facts are that people of when something is wrong and the facts are that people of Arizona are scared of climate change and we recognize that the Arizona Corporation Commission has a role in addressing it, a significant role. Federal energy efficiency standards, the the resources provided by the Department of Energy themselves, they acknowledge that one barrier to implementing EE standards would be the psychological impacts of
embracing uncertainty and investing in new technology. We can't ignore fear. The corporation commissioners cannot ignore that people are scared. Eco anxiety, eco grief, greenhouse gaslighting, I'm sure some of you out there listening have just rolled your eyes beyond hard at me, but these are words that young people are using because it's elected officials aren't listening to us. I don't know what to say beyond that. I know you know all the facts. I know you know the benefits of energy efficiency. It's an investment that we're willing to make. The point of all the monitoring and files that,
utilities and commissioners have invested in over the last few years or ten years. The point of that is to improve these programs, not to repeal them once we've met that landmark. So, yeah, thank you for listening. Thank you, miss Reeves. Before you go, could you just provide the, the city that you live in? I'm in Phoenix, Arizona, though I've been all over Arizona. It's preposterous. Thank you. Alright. Next, I have a slip for Richard Sigler, s I g l e r. Good afternoon. Hello. Yeah. The spelling is correct, and I live in Phoenix.
So I oppose a appeal of the energy efficiency rules because they are an effective way to save energy, which benefits all rate payers. As has been said many times, the cheapest energy is the energy we don't use. If we lower the demand through energy efficiency, then we reduce we've reduced the need for new infrastructure, which saves money for everyone. Utilities make their money through their capital investments, not through the amount of electricity they sell.
So why wouldn't they approve programs that will save electricity for the benefit of the consumer? Because they can make more money by increasing their capital investments, I e, by building more gas plants. In order to build more gas plants, there has to be a need for more gas plants. The more electricity that is needed, the greater the need for new gas plants. So if you're a utility, your motivation is to sell more electricity, not to conserve it. The argument argument that by repealing the EE rules will give you the utilities the
ability to choose on a case by case basis what the most cost effective efficient programs are that they can implement is a false argument. They will not do it. I am sorry, but I do not believe that they have the rate payer's best interest first. Their first priority is to make more money. This is where the commission comes in. You are here to make sure that they do that they do put the interest of the consumer first. It is for this reason that I'm asking you to not repeal the EE rules,
be a watchdog be a watchdog over the utilities, and require them to make the most energy efficient, cost effective choices. They will not do it on their own. Thank you. Thank you, mister Sigler. Alright. Next I have Bill Geniga. Coconut. Sorry. I tried my best. Alright. I live in Paradise Valley. And I wanna, first of all, thank the commission for their service to the constituents and the time they spend trying to make Phoenix a better place to live. Unfortunately, if we continue down the path we are going that goal will never be met.
There is a recent article in the Capital Times titled How Many ratepayers does it take to replace an energy efficient light bulb. The article discusses the renewable energy standards and the taxes and the tariffs, and the ACC is considering a repeal of both of these mandates. I am strongly opposed to this. These mandates were implemented fifteen years ago to help promote use of renewable energy and we have met the original goal of 15%. That's great news. However, citing expensive clean energy rebates and rate increases due to renewable energy sources,
they would like to repeal the mandates going forward blaming the use of renewable energy for rate increases under the existing regulations. In my opinion, the ACC should be looking forward to implementing a more aggressive renewable energy usage. We know that utility companies are responsible for significant amount of greenhouse gases that drive the temperature skyward here. What we need is for ACC to continue to implement renewable sources of energy not limit them. Foresight to plan for the future. If this logic is not strong enough, I ask each commissioner that have children and grandchildren to ask themselves one day,
though, if they ask why did we care more about money than protecting them environment, you will say the right things. Abraham Lincoln, a Republican, by the way, stated that a house divided itself it cannot stand. He was referring to the debate over slavery issue and whether it was the right thing to do. We also have a choice. We can consider the value of financial gains versus the value of the environment. Let's make the right choice. Thank you. Thank you. Spell your name. Yeah. I I neglected to spell your name for our core report. A.
N I g a, Janiga. I'm sorry. Please, please repeat that. J a n I g a, pronounced Janiga. Thank you. Just a reminder for anyone who is joining us, who would like to speak, I believe there are speaker slips on the podium, so please take one, fill it out and bring it up to me if you'd like to speak today. Next we will move on to Will Green, g r e e n e. Thank you, judge. Will Green. I'm the Arizona representative for Southwest Energy Efficiency Project or SWEAP. I live in Phoenix. We support updating the electric energy efficiency rules,
and acknowledge they are outdated. However, they should be modernized and not discarded. In our comments filed in this docket in September, SWEAP expressed concern that in the absence of rules that require utilities to have a plan for energy efficiency, that they will gradually back away from initiatives that reduce their own sales as efficiency, of course, does I suspect that this is exactly what we saw yesterday in open meeting as APS publicly supported the chair's amendment that cut APS's energy efficiency budget in half the
chair said it himself yesterday nearly an open meeting nearly no one reached out to him in support of APS's energy efficiency plan and other commissioners and accurate statements made it clear APS did not lift a finger to explain the differences sorry, explain the effectiveness of their energy efficiency efforts to commissioners yesterday or in the prior weeks and months. APS above else all else would have been in in a position to best explain the intricacies of their DSM plan, the ways they know these efforts efforts help people in the grid,
and why should we expect a for profit utility to enthusiastically embrace reducing their own sales? That's a lot to ask and it's why Arizona's founders created this body to see the bigger picture for ratepayers in the grid. That bigger picture is energy efficiency is the lowest cost resource, and it's not even close. And, staff's numbers highlighted, that earlier. Sweep acknowledge in our letter, that the current standard is outdated. What we still fail to understand is why commissioners had no interest in at least maintaining sections of the rule that require the utilities,
report their results in a public docket so we can at least see what they're doing and that energy efficiency be cost effective among other consumer protections. We'd highlight again the amendment language that sweep filed on the docket on 09/12/2025 that would accomplish maintaining at least these bare minimum, provisions of the rule. Thank you. Thank you, mister Green. Alright. Next, we have Maureen Rojas, r o j a s. My name is correct and I live in Phoenix. I'm also a member of Dayspring United Methodist Church.
Arizona is growing and I know the commission is concerned with meeting the demand for energy. Taking away the current energy efficiency standards is counterproductive because those standards help us meet that goal. For consumers, the utility programs standards are repealed, there are no guarantees these utility programs will continue. You've reported a $1,000,000,000 cost to customers for these programs. But that cost is an investment in our future because for every dollar spent, Arizona saw nearly $4 in benefits. Your study found that eliminating EE standards may require new infrastructure or the use of
less efficient resources like methane gas to meet peak demand. When that happens, it's consumers who will pay the cost. Since the EE standards were created with bipartisan support they've saved families hundreds of millions, reduced stress on the grid and cut down on the need for gas power plants. As the leader of the green team at my church I talk with many people about Arizona's need for energy to deal with our growth and our extreme heat. They're concerned about the lack of focus on efficiency and clean energy.
As Christians, we're concerned about community members who are having a tough time getting by. We care about what happens to owners of small businesses and residents of rural areas. So I'm asking the ACC please do not make a decision that gives top priority to utility profits while at the same time increases cost for ratepayers, puts strain on the grid, and causes job loss in an industry that employs nearly 45,000 Arizonans. Thank you. Thank you, miss Ross. Alright. Next we have Cynthia Zwick,
z w I c k. Thank you, Judge. My name is Cynthia Zwick. As you said, I serve as Director of the Residential Utility Consumer Office. I live in Phoenix but we represent, residential customers in every corner of the state of Arizona. We appreciate the opportunity to the people who are here today and those who came down and talked about, their concerns yesterday. The Residential Utility Consumer Officer, RUCO, supports the ongoing electric energy efficiency standards. And we believe preserving the existing rule in this docket is in the best interest
of all residential customers. The rules are reasonable, prudent, foster economic investment in Arizona, and promote reliability while saving customers money. Energy efficiency programs are some of the easiest, most cost effective ways for customers to control their growing energy bills. Every approved energy efficiency program meets the cost effectiveness test, meaning the program saves more than it costs. It benefits all residential customers, not just those who participate in energy efficiency programs. And between 2010 and 2022, Tucson Electric Power estimated a cumulative annual energy savings of over 2,000,000
megawatt hours. In the 2024, Arizona Public Service Thermostat Program had nearly 90,000 thermostats installed in residential customer homes and eliminated approximately 140,000,000 megawatts, sorry, 140 megawatts of peak energy demand during one of the many summer thermostat events. Their 2024, report indicates spending of approximately $70,000,000 with a net benefit of over $106,000,000 Excuse me. The utilities may not get rid of their programs if these standards go away.
However, we do anticipate that they will continue to approved. Many of them are being eliminated completely or others are being unfunded or defunded or the funding is significantly reduced. As Ms. Kane pointed out yesterday, the overall benefit, the net benefit of these programs is astounding. And therefore, we support their continuation. I think it's clear that there is support for these programs statewide and across residential, large, and small business customers. And as a result, and in response to many of the comments that we've heard yesterday and today,
we continue to support the ongoing standards. Thank you. Ongoing standards. Thank you. Thank you, Ms. Zwick. And my last in person speaker slip is for Horst Schmidt, s c h m I d t. Afternoon. Good afternoon. And, the spelling is correct. I'm in support of keeping the energy efficiency, rules that we currently have, and there are a number of reasons. One is that, we're by repealing the energy efficiency standards, we're going to have higher costs, we're going to have less reliable power,
and jobs will be lost. It's also would help customers by keeping the energy standards by, by a matter of fact, that we have this record breaking heat each year, and we have this tremendous population growth. So we need as much help for for our our customers to or your their customers to make sure that we have adequate support for people who are moving into the air into the area and also the fact that there
are a lot of older housing that probably needs help in terms of getting its energy efficiency up in terms of insulation and and other other techniques. The other part of this is is the matter of consumer choice and energy independence and that means that the energy assistance programs, efficiency programs give families and businesses tools and control over their energy use and costs. In terms of jobs and economic growth, energy efficiency industry employs almost 45,000
people as mentioned earlier, but also most of those jobs are small businesses. So in effect, by doing repealing this, the commission becomes a job killer. Reliability and resilience, both APS and TEP in a report from ACC said that cost effective tool for load growth is part of what energy efficiency has done for them. It's also reduced their system costs and it enhances customer affordability.
Then finally, in terms of affordability and cost savings, repeal equals higher utility bills, keeping energy efficiency less new infrastructure and lower cost. Thank you. Thank you, Mr. Schmidt. All right. Is there anyone else in the hearing room today who would like like to provide comment? Alright. Miss Patel, p a t e l. Hi. My name is Sheila Patel, and I'm from Tucson, Arizona. I'm 20 years old, a student at ASU, and the communications director with the Arizona Youth Climate Coalition.
I'm speaking on behalf of over 80 young people who cannot attend today because they're in school, but who demand that the energy efficiency mandate be updated and not repealed. In the report that you all commissioned, we were all thoroughly warned that the repeal of energy efficiency standards would lead to long term utility bill increases. It was also included that with higher peak demand comes more need and benefits of energy efficiency. He was supporting he was supporting this repeal because he did not want the government
instituting rules or policies with expiration dates and letting them linger. All rules implemented by the government need to have some sort of expiration date so to repeal or change them if they're not working. However, this mandate was and is working. This mandate addressed accessibility, lowered rate payer bills, and held APS and TEP accountable for actions as private companies regarding energy efficiency. Your job as commissioners is to pass and implement said rules and regulations for utilities. Updating and extending this mandate is a very easy way to do your job.
Thank you. Thank you, Ms. Patel. Alright. I don't see, not sure I see anyone else. Was there anyone else who wanted to provide comment today? Alright. With that, we'll move on to our telephonic participants. So I will begin with, Troy Horton, h o r t o n. Hello. Can you hear me? I can. H o r t o n is correct. I'm with Scientist Rebellion, Sierra Club, and Third Act. I appreciate the opportunity to speak about the importance of not repealing the energy efficiency standard. There are seven reasons to keep the energy efficiency standard.
One, lower consumer cost. Energy efficiency programs when cooling costs spike. Two, grid reliability. Efficiency and demand side management programs reduce strain on the grid during peak hours. This helps prevent blackouts and reduces the need for costly emergency power. Three, avoiding new generation costs. Building new power plants is far more expensive than saving energy through efficiency. Standard delays or eliminates the need for new generation saving billions in infrastructure costs.
Proven success, Arizona's largest utilities, APS and TEP have exceeded the standard. This shows the programs are effective and scalable. Five, environmental benefits. Energy efficiency reduces emissions by lowering overall electricity consumption. This supports cleaner air and aligns with broader sustainability goals. Sixth, equity and fairness. Efficiency programs can be designed to help low income household reduce energy burdens, repealing the standard risk leaving vulnerable communities behind.
Seven, modernization opportunity. Instead of repeal, the commission could update the rules to reflect new technologies, smart thermostats, battery storage, EV integration, and others. This keeps Arizona competitive and clean energy innovation. Why the repeal is risky? Commissioners who support repeal argue that mandates cost rate payers over $1,000,000,000 in surcharges. However, these costs are investments that return long term savings and reliability.
Without a standard, utilities may underinvest in efficiency leading to higher bills and more expensive infrastructure later. Repeal also sends a signal that Arizona is stepping back from proven cost effective energy solutions. While utilities can still propose efficiency programs voluntarily without a binding standard, there's less accountability to ensure consistent savings across the state. In short, keeping and modernizing the energy efficiency standard protects consumers,
strengthens the grid, and ensures Arizona continues to benefit from proven cost effective energy savings. Thank you. Thank you, mister Horton. Alright. Next on the line, I have Kelly McGowan. Oh, excuse me. Mister Horton, if you're still on the line, if you didn't provide it, could you please provide, the city or town where you live? I'm sorry. Buckeye. Thank you so much, mister Horton. Alright. Moving on to Kelly McGowan, last name, m c g o w a n. Go ahead and proceed. Good afternoon. That is the correct spelling. My name is Kelly McGowan,
and I am the executive director of Wildfire. We are a statewide nonprofit based here in Phoenix. Wildfire is an organization that has represented the interests of low income rate payers at this commission for decades, and we operate several programs geared towards geared towards energy affordability, including efficiency for low income households. I'm here today to strongly oppose the repeal of Arizona's energy efficiency standards. For the households we serve, energy efficiency is a financial lifeline. Low income families spend a far greater share of their income on energy bills than
the average households. When a home is drafty, appliances are inefficient, or heating and cooling systems are outdated, families pay the price month after month. Energy efficiency measures, whether it's insulation, efficient lighting, or a modern HVAC unit, help reduce that burden and make energy bills more predictable and manageable. Repealing these standards would take away some of the simplest, lowest cost tools we have to help families stay in their home, avoid utility shutoffs, and maintain safe living conditions. These are not abstract benefits. They are the difference between whether a parent can afford food,
medication, or rent in any given month. Energy efficiency also benefits all rate payers, not just those receiving upgrades. When we reduce energy waste across the system, utilities face lower demand, which reduces strain on the grid, delays the need for expensive new infrastructure, and ultimately lowers cost for everyone. This is one of the rare policy areas where the cheapest energy is the energy we never have to produce, and those savings flow directly to ratepayers. Nonprofits like wildfire see firsthand how much these programs matter. They allow us to help families stabilize their budgets,
improve improve health and safety in their homes, and reduce long term energy costs for the entire community. Repealing energy efficiency measure measures would move us in the wrong direction towards higher bills, greater volatility, and deeper energy and security for those who can least afford it. For these reasons, wildfire is urging the rejection, or is rejecting the repeal and maintaining strong energy efficiency standards. They are good for low income households, good for rate payers, and good for the resilience of our energy system as a whole. Thank you for your time and consideration today,
judge Nicholl. Thank you, miss McGowan. Alright. The next speaker I see online is Sandy Bahr, b a h r. Can you hear me? I can. Thank you. Go ahead and see. Hear me okay? Yes. Okay. And the the spelling is correct. Thank you. Good afternoon. I'm the director for Sierra Club's Grand Canyon chapter, which is the Arizona chapter, And I'm speaking on behalf of Sierra Club and our nearly 30,000 members and supporters in Arizona. And I do live in Phoenix, by the way, and Arizona has been my home most of my life.
Sierra Club strongly opposes the proposed repeal of Arizona's electric energy efficiency standards. These efficiency standards have been effective and successful. They save money for ratepayers by requiring utilities to offer cost effective programs that conserve energy, lower electric bills, and benefit Arizona's economy. They also indirectly conserve water and reduce air pollution. We were involved in the extensive stakeholder process that resulted in the standard,
and they're something that we as a state can be proud of. They've made a difference in people's lives. Energy efficiency has the lowest cost and the best return on investment of any energy resource available, costing three or four times less than other options. It is much less expensive to reduce energy consumption via efficiency programs than to build new generating resources to provide an equivalent amount of power. By reducing the need for spending on generation,
efficiency programs save millions for ratepayers every year and can help with saving off peaks. Deleting the standards would be a huge step backwards for Arizona ratepayers. The revised economic impact statement provided with the commission's September decision identifies many of the costs and harms of repealing the standard, including for ratepayers, small businesses, local governments, utilities, and Arizona's economy. Re repealing the standard would likely reduce rate payers' access to programs that help them upgrade appliance appliances and limit their their utility bills.
It would also create uncertainty for utilities and undermine businesses in the energy efficiency sector, which have created tens of thousands of jobs in Arizona. If the efficiency standards are eliminated and we rely on utilities to voluntarily implement efficiency measures, there's a risk utilities will not invest enough in efficiency and that ratepayers may see reduced access to efficiency programs and higher utility bills as a result. The commission's own economic impact statement makes these risks clear.
Elimination of the standard is especially concerning at a time when utilities are backsliding on their commitments to ratepayers. While the current rules only set efficiency targets through 2020, the solution is to adopt an updated standard that sets reasonable and achievable new efficiency targets going forward, and that keeps effective programs in place not to eliminate the rules. But even if the commission decided to eliminate the rules, it should keep the other provisions in the rules that require utilities to create implementation
plans and submit progress reports to the commission on their efficiency programs. We're also submitting written comments in the docket today that go into more detail on our concerns. Again, we strongly oppose repeal of these standards and encourage the commission to keep them. And thank you again for being there and the opportunity to speak today. Thank you so much. Alright. The next speaker I have is Amanda Ormond, o r m o n d. It looks like you're trying to unmute. Are you there? Yeah.
Your honor, could you hear me? I can. Thank you. Thank you, your honor. Amanda Ormond. Spelling is correct. I'm the director of the Western Grid Group. I'm also an APS customer, and I live in Flagstaff. I'm opposed to the elimination of the energy efficiency standard. I was active at the commission when the standard was passed in 2010, and I've watched every year as the programs have been scrutinized to ensure that they
provide benefits. As Ms. Keane explained, energy efficiency is doing the same amount of work with less energy. Eliminating this standard, if regulators do that, it's saying that we're allowing our utilities to be unnecessarily wasteful. On the benefits on the energy efficiency standard and programs are well documented, clear, and compelling. These facts are in the record, but they include more than $1,400,000,000 in benefits, water savings, reduced air emissions, and reduced overall need for new generation.
Monopoly utilities do what's in their best interest. Their interest is to make money for their shareholders. It is not reasonable to think that a for profit company is going to voluntarily continue programs that significantly cut cut into their process. Energy efficiency is not in the interest of the regulated utilities. The energy efficiency standard was created to and continues to be in the public's interest.
An energy efficiency standard is essential, a requirement is essential to ensure that utilities have to work to reduce energy use by individual customers, and, ultimately, that reduces the overall size of the electricity system. The requirement, even though it it went to 2020, it provides a floor, it provides a minimum. To illustrate the point about why it's so important to maintain a mandate of floor, we just have to look at the energy or the land side management vote yesterday.
The chairman of the corporation commission puts forward a successful amendment programs. By my count, 14 programs were either completely eliminated or significantly changed with no rationale or without knowing the effect that that would have on customer or on customer call. The facts are clear that the energy efficiency standard has produced significant benefits. The utilities will not continue significant energy efficiency programs as they are not in the
company's interest. The rule needs to be maintained as it is in the public interest. And Judge Nichols, I have one question. Miss Layton, would staff like to respond? Miss Layton, would staff like to respond? I your honor, I can respond briefly to that. The there's a clarification or more of an addition included in staff's presentation today as compared to Tuesday. On Tuesday, staff did not make note of the benefits that it sees from the actual repeal
of the rules. Miss Keaton's statement today did include, the statement that repeal of the rules I'm reading the wrong spot. Repeal of the rules would reduce some cost for utilities, associated with the requirements for filing plans as well as, cost to staff resources for reviewing those plans. That was something that just was not, stated on Tuesday. Thank you, miss Layton. Thank you, your honor. Thank you, miss Orban. Alright. Our next, caller is Tatiana Johnson, j o h n s o n.
Hi. Can you hear me? I can. Thank you. You can go ahead and proceed. Perfect. Thank you. That spelling is correct. Thank you, your honor. And good afternoon. My name is Tatiana Johnson, and I'm an organizer with Nissan Media in Action. We're based in Phoenix, but I have lived in Arizona my whole life. I am speaking today on behalf of Arizonans and the Latino community who already bear the economic burden of high energy costs. I'm here to urge the ACC to stand with our communities and reject the repeal of the energy efficiency standards.
Since 2010, these standards have saved Latino families millions of dollars and provided safe and reliable solutions to Arizona's homes during record breaking heat. Supporting energy efficiency is supporting our communities with access to projects like window shading, attic insulation, and low income weatherization. Revealing these standards is a mistake. It won't be utilities that pay the increased cost. It will be Arizonans, specifically, Latinos who are already struggling to keep up with rising bills. It's clear that energy efficiency is cost effective with a return of nearly $4 in
benefits for every $1 invested. Additionally, APS has saved 1,740 megawatts in peak demand since 2005, and TEP has saved more than 600 megawatts since 2015, demonstrating that energy efficiency is not only cost effective but also essential for stable grid reliability. I urge commissioners to reject this repeal and instead commit to standards that lower bills for our communities. Arizonans are already struggling to make ends meet. We deserve fair access to affordable reliable energy,
not higher utility bills. Thank you again for the opportunity to speak today. Thank you, miss Johnson. And before you go, could I just ask you to repeat the organization that you're affiliated with for the benefit of our court reporter? Yes. It's me, Familia, in Accion. It's in Spanish, so I can spell it. It's m I space f a m I l I a space e n space a c c I o n. Thank you so much. Thank you. Alright. Our next caller is mister Jose Gonzales, g o n z a l e z.
I live in Tucson. Hi. Thank you for taking my call. I live in, Nissan, and I'm calling, more to comment that just as president Trump has a brilliant plan to replace Obamacare, I'm sure the Arizona Corporation Commission has a brilliant plan to replace the energy efficiency mandates. But I'd like to see what those plans are before they destroy a significant segment of the economy as well as contribute to worsening climate change. That's my only comment.
Thank you, mister Gonzales. You're welcome. Have a good day. Alright. Our next caller is Vania Guevara, g u e v a r a. Yes. Thank you, your honor. Can you hear me? I can. Thank you, your honor. Can you hear me? Yes. Okay. Perfect. My name is Nadia Guevara. Correct spelling. I live in Phoenix, Arizona. I'm calling on behalf of Chispa, spelled C As In Charlie, H I S, P As In Paul, A, Arizona. We're a program of the League of Conservation Voters. We represent approximately 300 members and just wanna echo everyone else's powerful,
statements, opposing, in opposition of the repeal of the energy efficiency rule. This is something that is extremely important to our members. As yesterday, we were at the corporation commission where one of our members, gave a very emotional statement about, the fact that she's retired and constantly has to choose between having to pay for her medicine and her utility cost in addition to the cost of living. And so there have been studies by the ACC that clearly state, you know, that this, will cost consumers significantly more. I believe on a memorandum that was issued on September 3.
So just to please, echo again everyone else's sentiment in that we actually need this. We constantly see, unfortunately, commissioners, vote against and and, consumer voters and constantly represent and tend to support the interests of corporation commissions. And I wanna also note that people are becoming more and more aware of the economic and political system that we live in where these private interests are constantly prioritized over basic human needs.
And so, just to please, your honor, staff, anyone who's listening, listening, continue to do your best to demonstrate to the commission why we need these energy efficiency standards in place or modernize and for them to not be repealed. And that's it. Thank you so much for your time, Honor. I'd like to thank everyone else for your powerful statement. Thank you. Thank you, miss Guevara. It looks like in Phoenix. I don't know if I said that. Sorry. Thank you. I'm sorry. What? I meant to say that I live in Phoenix. I'm not sure if I said that. Thank you, miss Guevara. Okay. It looks like there might be one additional person on the line who might be,
interested in providing comments. So I'll, I'll give you an opportunity to unmute yourself with star six and, chime in if you'd like to provide a comment today. Hi there. Would you like to provide a comment today? Alright. Hearing none, we'll move on and I will, I may circle back in just a moment here. We have an additional person who is here in the hearing room today who I think would like to provide, public comment. So go ahead and proceed. Thank you, judge. For the record, my name is Diane Brown. I'm the executive director of the Arizona PIRG, p I r g, Education However, I appreciated Ms.
Orman asking for the clarification on the update or correction from staff. I did have have one additional one that I'm hoping can get clarified and on the record. In my comments the other day, I mentioned that staff is erroneous, that the energy efficiency resource standard has not expired. It's the energy savings that that don't continue to increase. I'm hoping that staff will agree to that today on the record and correct what they stated. This has been told to me as mentioned the other day a few times by
staff now and it also is part of the record in the repeal of the standard. Miss Layton, I know that staff has indicated it plans to, respond in writing, to the the comments and and questions today from our participants but, I would like to give you an opportunity to respond if staff would like to today. We would like to respond to that point in writing, so that we can prepare as thorough of a response as it deserves having that dispute. Thank you, judge. Judge. And I would just say this to me is one of the most easy questions
that I probably have ever asked to staff. It's just verifying something that they said that was said incorrectly. It is staff's prerogative, obviously, to put that in writing, but for folks hearing and folks not wanting to have to wait another month to get that answer, I would respectfully ask them to reconsider providing that very basic answer today. I I think staff has made itself clear. Thank you. Alright. It looks like, we have a Michael Dario, d a r r I o, who has joined us via telephone. Mister Dario, would you like to provide a comment today?
And, mister Dario, you can unmute yourself. Looks like you have. Go ahead and proceed. Hi. Yes. Michael Burrow with Advanced Energy United. We're a national business association, representing companies that develop and deploy advanced energy tech here in Arizona and across the country. And, just from a a business and industry perspective, regulatory certainty and consistency are critical. You know, the state's existing efficiency and renewable energy framework. I'm sorry, sir. You have to slow down. Sorry, sir. You have to slow down. You have to slow down. Okay. For years, this framework has given companies a clear sense of how the state plans,
to manage gross, diversify resources, and control cost. And it's working. It supported cost effective energy savings and, orderly additions of clean resources, and it's helped utilities plan ahead. So repealing these rules now when the state's load growth is outpacing existing grid capacity really sends the opposite signal, tells investors and utilities that the rules of the game can change abruptly just as state faces record demand. And efficiency, in particular, is one of the lowest cost tools available to reduce strain on the system and limit long term cost to customers.
So, you know, growth is an option for Arizona. It's already here, and we want the growth. And I think the question is whether or not the commission maintains a stable framework that helps manage that growth or steps away from it at the moment. It's most needed. So we respectfully urge the commission to not repeal. Thank you. Thank you, mister Dario. And, before you go, I'd just like to confirm that I've got your last name correct. Is it d as in David, a r r r I o? B as in boy. B as in boy. Thank you so much for the clarification. Alright. It looks like we have reached the end of our,
telephonic participants, and I don't see any new faces in the hearing room today. So, Ms. Lane, would staff like to, make a closing statement or add anything to the record today? No, your honor. Staff is satisfied with the presentation it's made. Thank you. Alright. So the next step in the rulemaking process will be for staff to file by 01/05/2026, a summary of all written and oral comments concerning the notice of proposed rulemaking received between 09/26/2025 and 12/04/2025,
along with staff's responses to those comments, as well as a final economic small business and consumer impact statement or a memo explaining why no revision to the economic impact statement dated 08/27/2025 is needed. The hearing division will then review the record and issue a recommended opinion in order for the commission's consideration at an open meeting. The commission will determine whether and in what manner the rule making should go forward. Are there any additional comments or other issues that need to be addressed during this, oral proceeding,
staff? No, your honor. Thank you. We will now adjourn. Thank you everyone for your participation today. This oral proceeding is adjourned. We can go off the record. Thank you all. Okay. And, judge, I need the, spelling of the interpreter's name, please. First name spelled Keith, k e I t t h, pronounced Kate, middle name Elizabeth, last name Franco, f r a n c.