Thoughts on Making Comments to the ACC



Speak from the heart, and feel free to say what you are thinking. SunZia’s attorney will of course try to keep the focus only on SunZia’s narrow amendment requests, but in public comments you are free to say whatever you want.

That said, here are some suggestions:

--Remind the commissioners that it’s always been a bad route, and the changes over the years have only made it worse and worse for Arizona’s interests (See below for a more points about that)

--Tell them about the special place that the San Pedro is, and what conserving the local ecosystem means to you

--Inform them of the many mitigation properties that are located in the San Pedro Valley to compensate for growth elsewhere in Arizona, and point out that SunZia now wants to put a mega transmission corridor through this narrow watershed, inviting co-location from other transmission lines in the future

--Point out that in Southline’s scoping comments for the Federal process, they made many suggestions about how to upgrade current infrastructure and use existing corridors that would not open a new transmission corridor through the San Pedro. There ARE better options.

--If you attended the Line Siting Committee hearings, feel free to comment on how unprepared the Chair and other committee members were, how little substantive information they demanded of SunZia regarding its effect in Arizona, and how the hearings were tilted to favor the applicant.

Following are some more detailed ideas about the current Arizona process that have been discussed among active CWG participants. (Thanks to David Robinson of Tucson Audubon for these.)
  • The Corporation Commission is responsible for ensuring, to the best of their ability, that every energy project they approve will provide adequate, economical, reliable energy for Arizona.

  • SunZia, Pattern Energy, and Southwestern Power Group haven't provided any proof that the energy to be transmitted through their lines will be used in Arizona. 

  • Given that California's utility rates are roughly twice as high as Arizona's, and given that Pattern Energy and Southwestern Power Group are private companies, it stands to reason they will sell their product at the highest price the market will bear -- in other words, to California, not Arizona.

  • When asked about this at the Line Siting Committee hearing, the applicants refused to answer, insisting that the rates they plan to charge are “proprietary information.” The most they would say is that their energy will be "a good value proposition" for Arizonans. In other words, "just trust us."

  • By not pressing the applicants on this issue, the Committee Chair -- and, indeed, the entire Line Siting Committee -- demonstrated clear bias toward the applicants, as well as disregard for Arizonans' need for adequate, economical, reliable energy.

  • If the Commission approves the Line Siting Committee's ruling, they will be forcing Arizona to make a huge sacrifice -- allowing considerable damage to an enormous stretch of precious, largely unfragmented, enormously biodiverse ecosystems along the San Pedro River -- while giving all the renewable-energy benefits to California.

  • Even worse, our public servants at both the state and national level continue to move the SunZia approval process forward without considering other options for upgrading existing infrastructure and using existing corridors (see Southline Transmission Project scoping comments)

  • Implore the Commission to carry out the responsibility they were elected to perform: ensure that the projects they approve will provide adequate, economical, reliable energy for Arizona. On those grounds alone, they must not allow the SunZia project to go forward.