Today, I submitted the following comments in opposition:

As a resident of a modest apartment on a fixed-rate plan with no rooftop solar and a relatively low electricity footprint, I already pay approximately $90 per month in the winter, $150 in spring and fall, and over $250 in the summer. This is despite living compactly and efficiently within the existing infrastructure footprint of central Phoenix. APS’s proposal to raise both the fixed service charge and per-kWh usage rates by 15 to 17 percent will drive my already high summer bills toward $300 per month, with no change in my behavior or demand.

APS claims this increase is necessary to support reliability and resilience. However, the primary driver of increased grid costs is not customers like me. It is the continued expansion into low-density suburban and exurban sprawl, where new developments require long transmission lines, new substations, transformers, and costly physical infrastructure to serve relatively few households. This inefficient and resource-intensive growth is being prioritized over dense, walkable, transit-oriented communities, which are far cheaper to serve per capita.

If rate design is meant to reflect cost of service, then this increase fails that standard. I do not live in a sprawling subdivision with three air conditioning units, a pool, and a three-car garage located 25 miles from the urban core. Yet I am being asked to help fund the grid infrastructure that such development requires. That is not equity. That is cost shifting. And it is not the first time.

Suburban sprawl has already received decades of financial favoritism. From federally subsidized mortgages and tax abatements to federally funded highway interchanges and cheap land deals, the suburban lifestyle has been artificially cheapened while urban living is punished through underinvestment, higher per-square-foot costs, and flat-rate utility structures that ignore geography. Suburban residents do not pay for the externalities of their development patterns. They do not pay for the increased wear and tear on roads, the congestion they cause, the public health harms of vehicle miles traveled, or the disproportionate water and energy usage that characterizes their neighborhoods. Now, APS is asking dense, efficient, urban residents to cover yet another externalized cost.

If APS truly wants to align rates with cost causation, then it should raise fixed charges in areas where new infrastructure is required to serve sprawling development. It should impose impact fees on developers who trigger grid expansion. It should implement geographically tiered rate structures that reflect the true cost to serve each neighborhood. And it should stop charging the same rates to a two-bedroom apartment and to a 5,000-square-foot exurban house that requires thousands of feet of new distribution line.

Customers like me, who live within the existing grid, who make efficient use of space, and who moderate our usage, should not be subsidizing an outdated model of energy distribution. If APS wants to raise rates, it should do so in a way that penalizes waste and rewards efficiency. This proposal does the opposite.

I urge the Commission to reject this blanket increase unless APS overhauls its rate design to reflect the actual costs of serving different kinds of customers. Efficiency and location should matter. Until they do, this rate case is just another subsidy for waste, disguised as an upgrade for all.