Speak out @ EPA Public Hearing - Greenhouse Gas Standards and Guidelines for Fossil Fuel-Fired Power Plants

This week, the Sierra Club shared two very important calls to actions requesting public comments on: the APS rate case at the ACC that I posted yesterday and the EPA Public Hearing - Greenhouse Gas (GHG) Standards and Guidelines for Fossil Fuel-Fired Power Plants (see below.)
We understand that these calls to action require more time and thought than a simple petition or survey. So the Sierra Club included everything you need in an action kit for the APS Rate Case.

And at 5:30 p.m. tonight (May 31st) there is an online information session on What the EPA’s Cut Climate Pollution Plan Means for AZ & How to Testify. <use this to register.

The U.S. Environmental Protection Agency (EPA) is holding a virtual public hearing on June 13, 14 and 15, 2023, to provide the public the opportunity to present comments and information regarding the Agency’s proposed Greenhouse Gas (GHG) Standards and Guidelines for Fossil Fuel-Fired Power Plants. Note: the first two days have filled up so they will continue the public hearing on June 15, 2023. EPA will announce further details and updates at: https://www.epa.gov/stationary-sources-air-pollution/greenhouse-gas-standards-and-guidelines-fossil-fuel-fired-power

In this action, EPA is proposing Clean Air Act emission limits and guidelines for carbon dioxide from fossil fuel-fired power plants based on cost-effective and available control technologies. The proposals would set limits for new gas-fired combustion turbines, existing coal, oil and gas-fired steam generating units, and certain existing gas-fired combustion turbines.

Remaining Date and Time

Thursday, June 15, 8 AM - 1 PM Arizona time

Location

Online Virtual Platform

If you have any questions about the hearing or need help registering, please email: EGU-GHG-Public-Hearing@rti.org 

Registration

The last day to pre-register is June 6, 2023. Please submit a separate registration form for each person attending or speaking. You will receive an email from EGU-GHG-Public-Hearing@rti.org with your unique connection information. 

Note: EPA will use your registration information solely for this event. If you register to speak, we will post your name and affiliation as part of the hearing agenda. No other information you provide, such as contact or personal information, will be included on the hearing agenda or shared with any third party.

EPA will take written comments on the proposal until July 24, 2023.

EPA considers all comments equally, whether submitted in writing to the docket or given orally at a public hearing. Each speaker will have 4 minutes to speak. If time allows, the EPA will provide an opportunity for public hearing attendees, who did not preregister, to provide oral testimony.

EPA will announce further details and updates at: https://www.epa.gov/stationary-sources-air-pollution/greenhouse-gas-standards-and-guidelines-fossil-fuel-fired-power

This meeting will be held through a virtual platform. A link to the meeting and any additional instructions will be sent to your email address after registration closes. There is also an option to call into the meeting; that information will be provided after registration closes.

Additional Information/Questions

To read the proposal and fact sheets, please visit https://www.epa.gov/stationary-sources-air-pollution/greenhouse-gas-standards-and-guidelines-fossil-fuel-fired-power

If you have any questions about the hearing or need help registering, please email our hearing coordinators at: EGU-GHG-Public-Hearing@rti.org, or contact the SPPD Public Hearing Team by email: SPPDpublichearing@epa.gov; or by telephone: 888-372-8699.

Ask ACC for more clean energy and support for a just and equitable transition in APS rate case

Four Corners Generating Station

The Sierra Club has put together an action kit (below) with several actions (along with talking points) you can take on this important issue. If you don't feel comfortable talking, you can share the action with others. 

ACTIONS YOU CAN TAKE: 

1. Speak at one of the public comment sessions either telephonically or in person or both.
2. Submit written comments to the docket.
3. Share on social media and/or share the information with a friend.
4. Write a letter to the editor pointing out the concerns with this rate case.

Arizona Public Service (APS) filed for a rate increase with the Arizona Corporation Commission (ACC) that would result in an annual net rate increase of $460 million, which would result in a net 13.6% bill increase for ratepayers.

In this rate case, APS asks ratepayers to pay for the continued operation of its polluting, outdated coal-fired power plants, even though those plants are no longer economical to operate and are more costly than clean energy alternatives. Since the last rate case, APS has spent hundreds of millions of dollars in capital expenses and operations and maintenance costs at its fossil-fueled power plants, including the coal-fired Four Corners Generating Station, where APS has just announced it will postpone a switch to reduced seasonal operations, and the coal-fired Cholla Power Plant. APS proposes to spend hundreds of millions more to keep Four Corners operating until 2031. APS can save ratepayers money and reduce pollution by retiring the Four Corners Power Plant prior to 2031 and replacing it with lower-cost renewable energy. Ratepayers should not have to pay for APS’s irresponsible spending to keep Four Corners running until 2031.

APS has also doubled down on fossil gas, spending over $100 million on its Sundance and Redhawk gas plants. On top of its existing coal and gas, APS is also proposing to add even more new gas through an upcoming “Request for Proposals,” even though renewables and storage are cheaper and more reliable.

Unlike Tucson Electric Power, APS is requesting approval of coal community transition (CCT) funding for communities impacted by coal-fired power plant closures. APS proposes $106.5 million in funding over nine years to support coal community transition, including for the Navajo Nation, Hopi Tribe, and the areas around Joseph City where the Cholla Power Plant is located. This funding is urgently needed to help these communities transition from coal to clean energy, although it is not enough to meet the need.

ACTION KIT:

Our key asks of APS and the ACC are:

• APS should retire the Four Corners Power Plant prior to 2031 and replace it with lower-cost renewable energy, which would save ratepayers money and reduce pollution.

• Ratepayers should not have to pay for APS’s irresponsible, unjustified spending to keep the costly, dirty Four Corners Power Plant running until 2031.

• APS should switch Four Corners to seasonal operations in 2023 as originally planned.

• APS should close Cholla Power Plant by no later than 2025 as scheduled.

• The ACC should approve funding for Coal Community Transition for communities impacted by coal plant retirements. APS’s proposed funding of $106.5 million CCT funding proposal is an important first step and should be approved by the Commission.

• APS should increase investments in energy efficiency and demand-side management (DSM) programs that save ratepayers money.

1. SPEAK AT ONE OF THE PUBLIC COMMENT SESSIONS

Date	Time
June 1, 2023	1:00 p.m. to 4:00 p.m., or until the last caller is finished speaking, whichever comes first
June 7, 2023	6:00 p.m. to 8:30 p.m., or until the last caller is finished speaking, whichever comes first
June 20, 2023	10:00 a.m. to 1:00 p.m., or until the last caller is finished speaking, whichever comes first
June 20, 2023	6:00 p.m. to 8:30 p.m., or until the last caller is finished speaking, whichever comes first
July 31, 2023	10:00 a.m. to 1:00 p.m., or until the last caller is finished speaking, whichever comes first

We would especially like to have a strong turnout for the June 7th meeting.

To attend in person, go to 1200 West Washington Street, Phoenix, Arizona 85007 and enter from the back or north side of the building. You will need to go through security to enter.

To speak in person, either complete a "Request to Speak" form on one of the kiosks in the lobby at the ACC or fill out a paper slip or use your computer or mobile device ahead of time and request to speak via the ACC Portal here: https://efiling.azcc.gov/cases 

To provide telephonic comments, phone 1-877-309-3457, then enter the passcode 801972877#.

The comments are usually limited to three minutes in length.

2.  SUBMIT WRITTEN COMMENTS TO THE DOCKET
   
   

1. Be sure to include the docket number at the top of your comments – Docket Number E-01345A-22-0144

2. Use the talking points listed below for your comments, plus include any specific reasons you are concerned about this rate case. Tell your story!

3. You can mail your comments to:  Arizona Corporation Commission, Consumer Services Section, 1200 West Washington, Phoenix, AZ 85007

4. You can submit your comments electronically or ask us to drop them off for you.

To submit a public comment, go to https://efiling.azcc.gov/cases, Click on “Make A Public Comment in a Docket.” Complete your information and click “Submit.”

Talking Points

Personal Financial Burden

1. The proposed 13.6% rate increase is too much following a time in which we have lost income as Arizona  residents survived the hardship of decreased wages and lost jobs during a global pandemic.

2. Bill increases have come too often –  this is the second proposed rate increase in just three years..

Continued Spending on Dirty, Expensive Coal Plants

3. APS cannot keep charging ratepayers for its dirty, expensive coal. APS is continuing to spend money on the dirty, expensive, and outdated coal-fired Four Corners and Cholla power plants, and is seeking to recover those expenses from ratepayers. The costs to keep operating APS’s coal plants exceeds the costs of alternatives like renewable energy. APS fails to justify those high costs, and relies on flawed and outdated analysis. Ratepayers should not have to pay for APS’s imprudent spending on fossil fuels.

4. APS can save ratepayers money by speeding up the retirement of Four Corners Power Plant and switching to cleaner and cheaper renewable power sources. Four Corners Power Plant is slated to retire in 2031, but an earlier retirement date can save ratepayers tens of millions and perhaps hundreds of millions of dollars, while keeping that additional carbon and other air pollutants out of the air. 

5. Renewables are cheaper and cleaner than coal. Clean energy resources like solar, wind, and battery storage are cheaper, cleaner, and more reliable than APS’s aging coal plants.

6. Across the nation, coal use is swiftly declining. By propping up polluting, toxic coal-fired power plants, APS isn’t preparing for a future that prioritizes a transition to clean energy – holding Arizona back. 

Environmental Justice and Coal Community Transition

7. APS is asking ratepayers to pay for dirty, expensive fossil fuel infrastructure that pollutes communities and harms public health. 

1. APS should not be burning coal or gas, or proposing new gas plants when we have a climate crisis.

2. APS is proposing to provide $106.5 million in funding for coal community transition, which is an important first step, but not enough to meet the needs of impacted communities. The ACC should support APS’s proposed funding and the requests of the Hopi Tribe and Navajo Nation, as well as the grassroots Indigenous groups who have requested a just and equitable transition for these coal-impacted communities.

3. The burning of fossil fuels continues to occur at the cost of the environment and health of communities of color. Coal plants emit thousands of tons of harmful pollutants that pose serious public health concerns, like increased asthma attacks, bronchitis, and heart attacks. Black, Indigenous, and people of color communities bear a disproportionate air pollution burden, and cleaner alternatives must be prioritized.2

Energy Efficiency

8. APS should be increasing investments in energy efficiency, which can reduce customer bills.

1. APS has not invested enough in cost-effective programs to increase energy efficiency and reduce peak energy demand.

2. Lack of energy efficiency in homes forces higher energy costs, disproportionately affecting Black, Indigenous and People of Color (BIPOC) and those of low and fixed incomes. These higher costs can lead to households going without needed electricity, which is uncomfortable and unsafe. 

3. Investing in energy efficiency helps keep electric bills lower and as noted above can lower energy burden on those with low incomes.

4. Energy efficiency programs are the lowest-cost energy option available.

5. We need to invest in what works. When we invest in efficiency, all electricity customers pay less than it would cost to generate that same power from more expensive alternatives.

6. By eliminating energy waste, we reduce the need for APS to generate power from more expensive alternatives. 

7. Energy Efficiency is also one of the few ways customers can reduce the cost of their utility bills. 

3) Share information on Social Media and with a friend.

Link to graphic 

Bit.ly Link to Add Up

Twitter

@APSFYI customers may see an increased utility bill in their future as it proposes a 13.6% rate increase that comes on the heels of hardship for communities contending with raising costs. Take action so APS doesn’t keep customers on the hook for its fossil fuels: https://bit.ly/RateCaseAPS

Facebook

ACTION ALERT: During a time where our communities are contending with raising prices and lost income after the pandemic, Arizona Public Service (APS) is proposing a rate increase that would spike customer bills by 13.6% to prolong expensive and outdated power plants that dirty our air and damage our lungs instead of increasing investments in #EnergyEfficiency.  APS can’t keep customers on the hook for its fossil fuel! Tell APS how this rate increase would impact you and your community by submitting a public comment or speaking at a public comment hearing. Click the link to learn more: https://bit.ly/RateCaseAPS

Instagram

Are you an Arizona Public Service (APS) customer? If so, did you know that APS is proposing a rate increase that would spike your bill by 13.6%? Tell APS that it can’t keep customers on the hook to prolong expensive and outdated power plants that dirty our air and damage our lungs by submitting a public comment, or joining the public comment hearing. Link in bio to learn more!

4) Write and submit a letter to the editor. See information below and use talking points above.

General LTE Guidance:

Keep it brief	Focus your letter on one point and don’t bring up other issues in your writing. Stick to your point. Do not repeat your opponent’s arguments or take the myth/fact approach. Restating a contrary position only serves to put it in print once again.
Make it local and original	Newspapers care about what affects the people who subscribe to their newspapers, and they know a form letter when they see one. Speak from the heart about why you care about this issue.  Do not copy talking points or materials verbatim. Use your own voice and story. Show how your issue will have a local impact, or how it will affect you or your family.
Make it timely	Relate your letter to an article or issue that has been printed recently or a current event. If no other article on the issue is available, begin your LTE with why you are writing about this now.
Include your contact information	Full name, address, phone number, email in the body of an email  or form but not in the LTE itself.

Where to publish your LTE:

Name	Type	Word Limit	Submission	Notes
Arizona Republic	State	200	Submit Letter Here
Arizona Daily Sun	N AZ	250	Submit Letter Here
Arizona Capitol Times	State	200	Submit Letter Here
Arizona Mirror	State	200	Email
The Daily Courier	Prescott	275	Submit Letter Here
Yuma Daily Sun	Yuma	350	Submit Letter Here

Jana Segal-Stormont
Environmental Advocacy and Water Committee Lead
Jana@SustainableTucson.org

Ask Gov. Katie Hobbs to Veto HB 2444 that could fund predatory groundwater pumping

Water for Arizona Coalition (WAC) asks @GovernorHobbs to veto HB 2444 —it doesn't ensure taxpayer funds are protected & could leave the public to subsidize predatory & unsustainable groundwater pumping. Until rural AZ has the ability to protect their GW bills like HB2444 are not enough https://bit.ly/3BqTdr6

RE: HB 2444

On behalf of the Water for Arizona Coalition (WAC), a collective of five conservation organizations with more than 60,000 members in Arizona, we respectfully request your veto of House Bill 2444, which proposes to create a Natural Resource Conservation District (NRCD) Commission and NRCD Fund. HB 2444 fails a fundamental test of good financial stewardship because it does not ensure that taxpayer funds are protected. This means that the public could end up subsidizing predatory and unsustainable groundwater pumping throughout the state. Until rural Arizonans have the ability to protect their groundwater, bills like HB2444 cannot be–will not be–enough.

On its face, HB2444 represents a noble goal. Rural Arizona is facing a natural resource crisis: something must be done. Across 80% of Arizona, groundwater pumping is completely unregulated, meaning anyone can sink a new well and pump as much groundwater as they want regardless if that pumping dries up a neighbor’s well, depletes nearby community water supplies, or dewaters connected rivers and streams. This groundwater free-for-all is a fundamental threat to our economy, family farms, and rural communities. Ignoring this threat guarantees increasingly negative impacts to the state as more groundwater basins are depleted and Arizona’s foundation for rural economic development is undermined.

Diverse stakeholders recognize Arizona’s groundwater crisis and have worked together to craft non-partisan, common-sense bills to address this need. And yet, certain special interests have blocked these bills year after year, leaving rural Arizona high and dry. As long as groundwater pumping is unregulated across greater Arizona, proposals that can funnel taxpayer money to large pumpers and special water-related projects in unregulated basins like HB 2444 cannot solve our groundwater crisis. Basic water management is necessary to provide security and assurance that publicly funded investments will yield meaningful public benefits–a basic principle of fiscal responsibility.

HB 2444 also proposes to enable NRCDs to access public funds from the Water Infrastructure Finance Authority (WIFA). In light of the funding prioritization criteria defined in A.R.S.

49-1274(B)(3), which prioritizes projects, in part, on “[t]he reliability and long-term security of the water supply to be developed through the project,” it seems highly unlikely that NRCDs or other entities in unregulated groundwater basins could be competitive if they seek funds from WIFA’s Water Supply Development Revolving Fund. This would be due to, again, the lack of any groundwater management and protection in rural basins.

HB 2444 has been unanimously opposed by Democrats at every step of the way. In contrast, bills proposing groundwater management solutions with bipartisan support in the Legislature and across rural Arizona have been introduced year after year. Year after year, a small handful of special interests block these bills.

A veto of HB 2444 is an opportunity to send a powerful message to the Legislature that there will be no more taxpayer handouts to entities pumping large amounts of groundwater in unprotected basins. It is a reminder to rural Arizonans that the status quo is unacceptable and that they should not be forced to stand by as their groundwater is pumped out from under their feet. First things first, the Legislature must send a bill that allows rural communities to meaningfully manage and protect their groundwater, and only then will you consider sending any more state money to NRCDs.

WAC appreciates your leadership and commitment to water solutions for all Arizona communities. We look forward to working with you to accomplish this goal.

Thank you for your consideration and service to our state.

From the Sierra Club's Legislative Report: 

• HB2444 natural resource conservation districts; revisions (Griffin) establishes a Natural Resource Conservation District Commission and sets up a whole system for them to get more money. Most of these entities represent industrial agriculture. OPPOSE.

Read the bill: https://www.azleg.gov/legtext/54leg/1R/bills/HB2444P.pdf

Contact Governor Katie Hobbs:

The Honorable Governor Katie Hobbs,
Governor’s Office
Arizona State Capitol Complex
1700 W. Washington St.
Phoenix, AZ 85007

https://azgovernor.gov/office-arizona-governor/form/contact-governor-hobbs

Email. engage@az.gov

Phone. Phoenix: 602.542.4331. Tucson: 520.628.6580.

Tell your state Reps to vote "no" on bad bills that limit Tucson's ability to protect the environment and voting

A bill that prohibits cities from planning bike paths advances at the AZ legislature

Despite our best efforts with Request to Speak, some bills still advanced to the House for a vote. Please, sign the petitions the Sierra Club provided to reach out to your Representatives to ask them to oppose these bills. Adding a personal comment helps. For even more impact, you can email your reps directly - using some of the talking points included on the petition.

Keep up the pressure against bills that would impede efforts to reduce traffic and promote transit and biking. Use this link to take action to oppose SB1312, SB1313, SB1314, and SCR1018.

Don't forget to ask your representatives to oppose SB1278, a bill to limit cities' and towns' ability to protect their residents via local building code provisions related to affordability, energy, and public health. Use this link to take action on SB1278.

Ask your representatives in the Arizona House to oppose bills that prohibit consideration of environmental, social, and governance (ESG) factors when deciding on state investments. Use this link to ask them to vote NO on SB1139 and SB1500!

Most people in Arizona use early voting by mail as a safe and secure method of voting. Unfortunately, the Arizona Legislature is seeking to make that method of voting much more difficult and has introduced many bills to do so.

Ask your representatives to oppose SB1141 (early ballot drop off; identification).

It requires additional voter ID to drop off an early ballot. This is unnecessary as they already have the signature for verification. In the last election, people waited in lines for more than two hours to vote. This bill will make them longer. Use this link to reach out to your Representative on SB1141.