August 13, 2025
Kevin Thompson, Chair
Nick Myers, Vice Chair
René Lopez
Lea Marquez Peterson
Rachel Walden
Arizona Corporation Commission
1300 W. Washington Street
Phoenix, AZ 85007
Re: Leave the Renewable Energy Standard and Tariff Rules
Docket RE-00000A-24-0026
Dear Commissioners,
The Arizona Public Health Association urges you to reject the proposal to repeal the Renewable Energy Standard and Tariff Rules (“REST Rules”). Repeal would raise power bills, weaken grid reliability, and threaten one of Arizona’s most vibrant job-creating industries.
Since 2006, the REST Rules have ensured that utilities steadily increase clean energy use 15% by 2025, with 30% from distributed sources like rooftop solar.
APS has already abandoned its voluntary goal of 45% renewable power by 2030. Without enforceable rules, Arizona risks losing investment and jobs to other states. More dependence on fossil fuels means more exposure to price spikes and supply disruptions.
The Commission’s duty is to ensure rates are just, reasonable, and supported by evidence. The evidence here is clear: the REST Rules protect ratepayers, support economic growth, and safeguard public health.
Repealing the REST Rules would raise power bills for Arizona families and businesses, undermine the reliability of our electric grid, and jeopardize a vibrant renewable energy industry that supports tens of thousands of jobs and generates tens of millions of dollars in tax revenue annually.
Adopted in 2006, the REST Rules were groundbreaking: they required Arizona utilities to get 15% of their electricity from renewable resources by 2025, with 30% from distributed energy sources like customer-owned rooftop solar. The Commission recognized that enforceable rules—not voluntary pledges—were necessary to drive investment, innovation, and cost reductions.
That vision has been realized. Since the REST Rules took effect, the cost of utility-scale solar has dropped 84% and wind costs have declined 55%. Both are now cheaper to build than new natural gas, coal, or nuclear plants.
Renewables protect ratepayers from volatile natural gas prices. Arizona’s abundant sunshine has made us the fifth-largest solar-producing state, and distributed solar reduces the need for costly peak-hour energy imports.
The economic benefits are equally compelling. Renewable energy now accounts for nearly half of Arizona’s power sector jobs. In 2023 alone, the solar industry generated over $155 million in state, county, and local tax revenues. Rural and urban communities benefit from renewable energy investments, which ripple through the state’s economy in construction, manufacturing, operations, and maintenance.
The rationale for repeal, reducing compliance and administrative costs, is dwarfed by the economic, environmental, and public health benefits of maintaining the REST Rules. Moreover, APS’ decision this week demonstrates that utilities won’t keep voluntary renewable commitments.
The Commission’s ratemaking authority carries the responsibility to ensure rates are just, reasonable, and supported by substantial evidence. Stripping away the REST Rules would expose ratepayers to unnecessary price volatility and undercut the long-term stability of our energy system.
We urge you to update, but not repeal, the REST Rules, ensuring they’ll continue to deliver affordable, dependable, clean energy for millions of Arizonans while sustaining a thriving industry that benefits our economy and public health.
Sincerely,
Will Humble, MPH
Executive Director
Arizona Public Health Association
