Tuesday, March 13, 2018

My letter to the Arizona Corporation Commission asking them to oppose TEP's application to install 10 gas-fired generators

proposed location for 10 RICE gas-fired generators

Here is my letter to the Arizona Corporation Commission asking them to oppose TEP's application to install 10 gas-fired generators.  (See yesterday's Call to Action.) Got it in just under the wire to be considered at their 10 a.m. hearing in Phoenix today! Hope you got yours in too!

AZCC Docket # L-00000C-17-0365-00177 

Dear Corporation Commissioners,

As a Tucson Electric Power customer, I urge you to delay your ruling on TEP’s application for a Certificate of Environmental Compatibility, and withhold authorization for the construction of the Reciprocating Internal Combustion Engine Generation Project and the Irvington 138kV Transmission Line Relocation Project, consisting of 10 modular RICE generators and 2.2 miles of transmission lines, located within TEP’s Irvington campus.

As a member of Sustainable Tucson, I am concerned about TEP’s unambitious goal of transitioning to 30% clean energy by 2030. Unfortunately, the negative impacts of climate change are progressing much faster than that. If TEP is truly dedicated to transitioning to clean energy, why would they be installing 10 new pollution spewing gas-fired generators?

In Commissioner Tobin’s “Arizona’s Energy Modernization Plan, the commissioner outlined steps for Affordability and Reliability.

Number one on the list:

1. Thoughtful planning so the transition to clean energy is gradual and considers the useful life of existing facilities while not locking into new non-clean energy investments that may be stranded in the near future.

Aren’t the RICE Generators locking us into non-clean energy investments that may be stranded in the future?

My engineer husband, Dan Stormont, and I have been actively following the rapid innovations happening in solar storage and believe that they will be an economically feasible option in the near future.

Battery storage has already resulted in the cancellation of proposed gas peaker plants in California. Regulators there are even requiring utilities to open competitive solicitations for solar + battery storage that are likely to supplant three existing gas peaker plants. Please, allow a similar condition to arise in our utility area. Regulate for the right choice to be made from the start.

TEP has failed to adequately demonstrate that there is no substantially more environmentally responsible and comparably cost and performance-competitive set of measures than the internal combustion generation they propose. I, along with the sustainability community, believe that currently available solar plus battery storage technology (possibly but not necessarily accompanied by time-of-use rates and other demand response measures) would result in improved service to all TEP customers with better environmental and financial outcomes for the utility and the customer base.

Two years ago, RICE may have made more sense than it does now. Even in the last few months, battery storage has come of age. Given the urgency of the need to decarbonize our energy production mix, we need to take advantage of the best solutions available now. This is a great opportunity for Tucson to promote climate justice and for TEP to model in-time climate and environmental decisions and action.

Thank you for your time and for considering my concerns.
Jana Segal
Sustainable Tucson


But our activism doesn't stop there! Tonight at Sustainable Tucson's meeting (after a screening of "Beyond the Mirage" and a discussion of important water issues) we will announce more activism opportunities to oppose the RICE generators. We will also work on personalizing letters to the editor (EdOps) that can be revised to send to our City Council Members and Board of Supervisors.  Join us for an interesting movie and organic popcorn! Stay for some activism! 

"Beyond the Mirage" screening and water discussion
Tuesday, March 13,  at 6 PM
Ward 6 Council Offices
3202 E 1st St, Tucson, Arizona 85716
(behind the Walgreens across from the Loft Cinema.) 


  1. Glad to see this published.

    The question of generators vs. battery storage needs to be illuminated and examined closer. Just a few months ago, our solar installer (one of Tucson's largest) explained to me that TEP's natural gas generators would be a positive for solar users (because they can come on line much faster than coal or diesel-fired plants, and therefore more quickly respond to cloudy conditions).

    Over the last year, large-scale battery storage solutions have come on line in California, Hawaii, Australia and Puerto Rico to name a few. When I was in the UAE on business just a few years ago, locals were feverishly working on solar solutions as they pumped oil from the ground to sell to the outside world.

    Besides the important long term impact gas-fired generators have on climate change, anyone willing to open their eyes can see that Tucson suffers from dirty, dingy air. Let's get the message out about battery storage so we can leave our children and grandchildren a world better and healthier than the one we inherited.

    1. Great points, Augsburg. Have you considered writing a letter to the editor to that effect?