While Arizona's patchwork of jurisdictions creates complexity, early engagement with regulators and careful project design can enable project proponents to navigate these challenges successfully, particularly given the state's historically pro-development stance.
Five key takeaways from this 2025 Arizona energy siting guide include:
1. New Rules Clarify CEC Triggers -
. A 2023 statutory amendment clarified that only transmission lines with 5+ structures spanning more than one mile at 115kV+ require a Certificate of Environmental Compatibility (CEC).
2. Renewable Mandates Under Attack Despite Market Momentum -
. Commission voted to repeal $3 billion renewable energy standards...
. Major utilities (APS, TEP, SRP) continue pursuing renewable goals independently...
. Market forces may continue driving renewable development, but REST rules may not...
3. Federal Land Complicates Project Development -
. Less than 20% of Arizona is privately held—this increases the probability of NEPA triggers...
. Developers spend considerable time and money avoiding or addressing NEPA issues...
. Many project proponents prioritize private lands or State Trust lands to avoid federal triggers where possible...
4. Tribal Sovereignty Creates Legal Complexity -
. Excellent resources but complex sovereign immunity and federal trust land issues...
5. Navigating Arizona Water Law and Rights Is Tricky -
. Complex groundwater/surface water distinctions vary by geographic location...
. Colorado River shortages are impacting water needs for a range of projects
. Municipal effluent, a “third category of water,” can be an option
Please see full publication below for more information.
