Georgia

2022 Integrated Resource Plan

NEE Expert Witness Testimony on behalf of Southern Alliance for Clean Energy and Southface Institute by Board Member, Ron Binz

Georgia Filing #189984

Georgia Filing #190155

Conclusions and Recommendations

∙ Some of the new gas will not be needed in a “least cost” scenario.

∙ Georgia Power needs to recharacterize solar plus storage in the planning process.

∙ Most importantly, move to All Source Solicitation for new generation capacity and reliability.

∙ The Georgia Public Service Commission needs to encourage or require Georgia Power to move into more regional cooperation and use of connected assets and reserve capacity in the region.

Video of Testimony

2022 Rate Case

NEE Expert Witness testimony on behalf of Southern Alliance for Clean Energy and Southface Institute by Board Chair, Ron Lehr

Georgia Filing #191855 

Conclusions and Recommendations

∙ Reject the proposed levelized rate increase and adopt an annual step increase.

∙ Require the company to identify available funding through IRA, IIJA, and present 28 findings to the Commission.

∙ Encourage the company to apply for, receive approvals, and use available funding to best provide timely consumer and community benefits.

∙ Encourage Commission staff and company to develop agreed upon federal funding tracking processes, including actual and anticipated funding, and actual and estimated costs and benefits to customers and communities.

∙ Order annual reports detailing results and define true ups resulting in updated revenue requests for 2024 and 2025 within the 3-year ARP.

∙ Provide for tax and other savings to benefit customers, including to offset rate increases during 2022-2025.

2023 Fuel Cost Recovery

NEE Expert Witness testimony on behalf of Sierra Club and Southern Alliance for Clean Energy by NEE board member, Brent Alderfer

 Georgia Filing #194057

Conclusions and Recommendations

∙ Planning assumptions going forward need to assume, prepare for and reduce exposure to higher and more volatile natural gas prices;

∙ High concentrations of natural gas generation in the portfolio multiply the rate shock from increases and swings in fuel prices;

∙ Renewable generation as a fuel-free resource lowers electricity costs and provides an effective long-term hedge against high and volatile fuel prices;

∙ Economics of utility-scale solar allow fuel savings to utility customers on the order of the fuel cost shocks at issue in this case, while at the same time offering investment earning potential for the utility;

∙ Rapid and irreversible structural changes in and exposure to global markets require an update of low fuel-price assumptions and resulting resource decisions as a fundamental underlying element of just and reasonable allocation of fuel costs.

Outcomne

∙ A Georgia fuel cost coalition formed and meet regularly, clarifying fuel cost recovery law and its limits, developing alternative methods and related policies to address moral hazard of 100% fuel cost passthrough, and conduct educational engagement on the problem and potential solutions.

2024 Integrated Resource Plan Update

NEE Expert Witness Testimony on behalf of Clean Energy Buyers Association by NEE Board member, Ron Lehr

Georgia Filing #217554

Conclusions and Recommendations

High-level outcomes supported by CEBA and NEE in this docket?

∙ Georgia Power’s forecasted future load should be met with least-cost, competitive clean energy resources.

∙ All new capacity additions should be as clean and cost-effective as possible, without preference given to utility-owned gas generation resources or affiliate transactions.

∙ Customers interested in voluntary clean energy purchases should be empowered to contribute to Georgia Power serving its forecasted load.

∙ Georgia Power should make progress on transmission expansion plans and increasing the availability of market mechanisms to improve reliability and meet forecasted load growth.

Specific recommendations to the Commission.

∙ Reject Georgia Power’s requests for CPCNs for PPAs with Mississippi Power and Santa Rosa Energy Center LLC.

∙ Reject Georgia Power’s request to develop up to 1,400 MW of simple cycle combustion turbine (CT) resources at Plant Yates.

∙ In the alternative, allow Georgia Power to develop only one simple cycle CT at Plant Yates to account for the limited transmission capacity at that location.

Outcome

∙ In settlement, Georgia Power gave written agreement to develop a new customer program in the 2025 IRP that will allow large load customers to develop and cover all construction and transmission integration costs for Clean Firm to address current and future demand. The program will help address and reduce the need for gas plants and reserve margin to address increasing demand from tech and industrial growth.  

Georgia Power Updated IRP Media

New Energy Economics Media Statement

“Renewable power has the potential to liberate our economy from volatile fossil fuel prices and dependence on foreign imports, while improving state business investment and increasing job opportunities here at home.”

“Right now, more than 70% of Georgia Power’s energy generation comes from burning gas and coal. But clean energy is fundamentally cheaper than its nonrenewable counterpart — in fact, 2021’s investments in renewable energy saved $55 billion in global energy costs in 2022.”

Hearing Starts Today on Georgia Power’s Plan to Burn More Fossil Fuels

2025 Integrated Resource Plan

NEE Expert Witness Testimony on behalf of the Clean Energy Buyers Association by NEE Board member Brent Alderfer, and Priya Barua, Clean Energy Buyers Association, Senior Director, Market and Policy Innovation.

“The purpose of our Direct Testimony is to provide analysis and recommend improvements to Georgia Power’s proposed Customer Identified Resource option, which Georgia Power proposed as part of the Clean and Renewable Energy Subscription (CARES) Program. The Customer Identified Resource proposal, if modified by our recommendations, has the potential to provide a revenue-neutral solution to help meet Georgia Power’s urgent capacity needs while also meeting the clean energy needs of large customers that are looking to expand business operations in Georgia.”

 Georgia Filing #222494

Conclusions and Recommendations

∙ Direct Georgia Power to allow large customers to bring forward Customer Identified Resources on a rolling basis after the conclusion of this IRP, or, in the alternative, direct Georgia Power to initiate its proposed Phase II process to procure Customer Identified Resources as part of the ongoing 2023 CARES request for proposals (RFP) or the upcoming 2025 CARES RFP.

∙ Direct Georgia Power to credit customers that subscribe to clean firm Customer Identified Resources for the avoided marginal capacity value of those resources.

∙ Direct Georgia Power to allow multiple customers to coordinate to bring forward and subscribe to a single Customer Identified Resource.

∙ Approve Georgia Power’s proposal to allow customers to negotiate directly with developers or to sign subscription agreements with higher prices to offset higher PPA costs for Customer Identified Resources.

∙ Direct Georgia Power to allow customers to subscribe to any type of carbon free energy generation technology through the Customer Identified Resource option.

∙ Direct Georgia Power to allow existing customers to subscribe to up to 5,000 MW of Customer Identified Resources to support their existing loads and not to impose any cap on the amount of clean firm Customer Identified Resources procured to support new and incremental loads.

∙ Affirm that the current Commission-approved CARES bill credit structure protects non-participating customers and so it is not necessary to establish “reimbursement thresholds” or otherwise cap bill credits for the CARES program and the Customer Identified Resource option.

Video of Testimony