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Georgia
Solar Energy Association
Supporting Renewable
Energy in Georgia
http://www.gasolar.org/
May 10, 2007
The Honorable
Bobby Baker
Chairman, Georgia
Public Service Commission
244 Washington Street,
SW
Atlanta GA, 30334
Regards: Docket 24505-U, Comments on Georgia Power’s
Integrated Resource Plan by members of
Georgia’s Renewable
Energy Industry
Dear Chairman Baker,
We, the undersigned,
present this letter in response to Georgia Power’s
Integrated Resource Plan and the
need for increased
priority to be placed on renewable energy production in
Georgia. Business owners,
industry
professionals, and advocates for a viable and thriving
renewable energy industry in Georgia
would like to see the
Public Service Commission support policies and provide
directions to Georgia
Power that will
accelerate renewable energy production and serve the
general public interest in solar,
wind and biomass
development. Participants in the renewable energy
industry in Georgia have serious
concerns related to
Georgia Power’s Integrated Resource Plan (IRP).
We appreciate the public service and responsibility of
each member of the PSC.
Georgia’s future depends on a wise mediation between the
public interest, including the quality and
preservation of our
natural and common resources, and Georgia Power’s
findings as presented in this
proposed IRP.
Fortunately, we now have another public resource for the
PSC to reference during its
evaluation of the IRP.
Georgia’s PSC should make every effort to scrutinize
this IRP according to the
priorities and policy
recommendations set forth in the Georgia State Energy
Strategy. The Georgia
Environmental
Facilities Authority (GEFA) under the direction of the
Governor’s appointed Energy
Policy Council,
developed and administered the comprehensive,
professional, science based, and public
spirited energy plan
process that produced the very credible State Energy
Strategy. The influence of
utility companies in
the final recommended state energy strategy was
considerable. But, in the
stakeholder and public
input framework of the planning process, that influence
was not overwhelming.
Many of the energy
strategy’s identified priorities deserve support and the
PSC has a vital role in
validating and
implementing those priorities.
I. GENERAL CONCERNS
Generally, we are concerned about the narrow and self
interested framework of Georgia Power’s IRP.
This concern is not
expressed as a condemnation. It is, rather, an
acknowledgment. Peter Barnes, in his
2006 book - Capitalism
3.0 A Guide to Reclaiming the Commons - characterized
the workings of our
economy as follows:
“Our current operating system is dominated by 3
algorithms . . . (1) maximize return to capital, (2)
distribute property
income on a per-share basis, and (3) the price of nature
equals zero . . . The first
algorithm is what
drives corporations. It tells them to sell as much as
they can, pay as little as possible
for labor, resources,
and waste disposal, and make shareholders happy every
quarter . . . This doesn’t
mean people inside
corporations don’t think about protecting nature,
raising their workers’ pay, or
giving something back
to society. Often, they do. It does mean their room for
actually doing such
things is too narrow
to make a difference . . . For all practical purposes,
the publicly traded
Chairman Baker, May
10, 2007, Page 2 of 8
corporation is a slave
to its algorithm... Corporate communications departments
would try to maximize
the appearance of
social responsibility for the lowest actual cost. We’d
see beautiful ads and reports
but little change in
core behavior.”
Unfortunately, in this crucial era of climate change,
environmental degradation, and perilous
dependence on fossil
fuel and foreign fuel imports, the framework of Georgia
Power’s IRP is
predominately business
as usual. In the IRP main document, there is no serious
disclosure of Georgia
Power’s generating
operations’ impact on Georgia’s environment nor is there
any serious reevaluation
of the consequences of
the utility’s past decisions and investments to provide
most of its electric power
output from burning
coal.
II. ENVIRONMENTAL IMPACT CONSIDERATIONS
When citizens pay attention to regulatory details, we
understandably expect that when regulatory bodies
require a utility
company to consider environmental impacts in its IRP,
there will be open and
understandable public
information about the environmental impact of the
company’s operations on the
environment of its
service territories. Instead, the environmental impact
considerations in Georgia
Power’s IRP appear to
be limited to the impact of environmental regulations
and protections on the
operations of The
Southern Company.
Externalized Costs of
Energy Production:
In the first draft of the State Energy Strategy, there
was idea 2.5(r), “evaluate the current processes that
the governing bodies
charged with establishing utility rates use in
establishing those rates. The study
could also consider
improvement to ensure that all costs, including external
environmental and public
health costs, are
considered in the economic analysis of supply
resources.”
Renewable energy and conservation are economically
competitive with conventional energy production
and consumption when
public health and environmental health costs are
considered. The public health
costs and the
environmental costs that are pushed off on the public
sector, private citizens, and
unrepresented future
generations of inhabitants ought to go into the rates
we're paying for today’s dirty
energy. Unfortunately,
this proposed idea was not included in the final version
of the Strategy.
Apparently there is much reluctance between political
office holders and conventional energy producers
to increase utility
rates to account for some of the externalized
environmental and health costs of energy
production practices.
In the absence of will from our leadership, citizens
ought to at least have official
access, through the
IRP process, to accurate information about utility
company impact on the
environment in which
we live. The true price of nature does not equal zero,
except perhaps, in the case
of fuel prices for
solar and wind energy production.
Georgia’s Water Supply:
From Georgia State
Energy Strategy Chapter 6 - Energy and The Environment
Section 2 - Water Quality and Water Supply:
“Steam generation and
cooling processes in power plants take billions of
gallons of water each year
from Georgia’s surface
waters and groundwater. While most of this water is
returned, a significant
portion is lost to
evaporation . . . The pressures of a growing population
and industries will tighten
water supplies in more
regions of Georgia, making even less water available for
energy production . . .
According to Sandia
National Laboratory, coal generation requires 25 gallons
of water for each
kilowatt-hour of
generation (Sandia National Laboratories, 2005) . . .
Sandia’s examination of this issue
concludes that
consumers may indirectly consume as much water turning
on the lights and running
appliances as they
directly use taking showers and watering lawns. (Sandia
National Laboratories, 2005)
. . .
Chairman Baker, May
10, 2007, Page 3 of 8
The State’s energy and
water planners should pay close attention to the results
of these studies and the
development of
additional data and tools, and should incorporate them
into future planning efforts.”
The water supply issue
is not seriously addressed in the IRP plans for new coal
and nuclear plant
construction in
Georgia. The PSC should require Georgia Power’s IRP to
address the State Energy
Strategy’s policy
objective to “Minimize Water Supply and Water Quality
Impacts of Energy
Production in the
State Implementation Strategies.”
III. NET-METERING AND INTERCONNECTION AGREEMENTS
The emerging renewable
energy industry relies heavily upon the insurance that
the Public Service
Commission will
continue to provide for premium buy back rates and long
term interconnection
agreements to
customers who are eligible for net-metering.
Net-metering provides an incentive for many
individuals in the
state who would like to invest in renewable energy
systems on their private property.
Participants in the
renewable energy industry would like to see Georgia
Power provide longer term
contracts in their
interconnection agreements with little to no monthly
metering service charges.
Regarding IRP section
14.2 -
“Net Metering Standard – Section 1251of EPAct 2005
states: (11) NET METERING – Each electric
utility shall make
available upon request net metering service to any
electric consumer that the electric
utility serves.”
Georgia Power then states that, “ Georgia Power is
exempt from the net metering requirement due to the
comparable standard
passed by the Georgia State Legislature (Georgia’s
Cogeneration and Distributed
Generation Act of
2001) so the state and Georgia Power are already in
compliance and therefore the
EPAct requirement is
not applicable.”
However, as described, Georgia's 2001 bi-directional
legislation provided that “Utilities will purchase
energy until
renewable-energy capacity reaches 0.2% of the utility's
system peak. Eligible technologies
include photovoltaics
(PV), fuel cells and wind systems up to 10 kilowatts
(kW) for residential
applications and up to
100 kW for commercial applications.”
The program ending limitation of 0.2% of the utility’s
system peak is in direct conflict with the EPAct
provision that
net-metering be “available upon request . . . to ANY
electric consumer that the electric
utility serves.” This
conflict indicates that Georgia’s legislation is NOT
comparable to the EPAct and
the PSC should act to
carry out the more expansive net-metering requirements
in EPAct. Improvements
of this nature would
encourage increased renewable energy investment by
Georgia Power residential
and commercial
customers.
In practical terms, consider that the IRP includes this
information:
“ 1.12 THE DEMAND AND ENERGY FORECASTS A territorial
peak demand of 17,160 MWs was
set on August 4, 2006
for the Georgia Power service territory. " and also from
the IRP economics
section: “It is
estimated that 105,000 new homes were built in Georgia
in 2005. "
Accordingly,
calculations show the 0.2 percent of peak demand net
metering cap amounts to 34
megawatts, an amount
equal to the output of 9714 residential 3.5 kw PV
systems. Therefore, under
present net-metering
constraints, net-metering could be denied after less
than one in ten new homes in a
single year were
equipped with solar PV systems. This constraint is a
real barrier to the growth of
renewable energy
production in Georgia.
Chairman Baker, May
10, 2007, Page 4 of 8
The 100 kw limit on commercial systems could also
discourage consequential kw capacity investments
in Georgia that will
be welcomed in other states. Certainly, the 100 kw limit
ought to be waived for
projects in the
Northeast Georgia area where demand growth is
challenging the present grid capacity.
The executive summary
of the State Energy Strategy includes the need to
“implement a suite of policies
to encourage highly
efficient distributed generation, including the
development of statewide
interconnection
standards (Strategy 1.9) and the development of a
Georgia combined heat and power
roadmap (Strategy
1.10).” Renewable and native resource-based generation
are promising and practical
elements for wide
scale distributed generation capacity development in
Georgia. Implementing the
net-metering and
interconnection policies of EPAct 2005 is a necessary
action in promoting the growth
of distributed
generation from renewable and native alternative fuels.
IV. GREEN ENERGY PROGRAM
Participants in the renewable energy industry are
depending on the long-term success of Georgia
Power’s green power
program to ensure that the Public Service Commission
will continue to provide
premium buy back rates
to owners of renewable energy systems. We are concerned
that the current
program falls short in
promoting immediate growth of renewable energy
production.
It is not surprising
that the public at large, including well-informed
advocates for clean energy
production, has been
reluctant to voluntarily contribute funds to Georgia
Power under the present terms
of its green power
program. First, almost none of the participants in the
program will directly
consume the clean
energy which they purchase, we are asked to send the
extra money without materially
receiving anything in
return. Second, there is the issue of trust in
voluntarily contributing to a utility
company with a
reputation of being generally non supportive of
renewable energy production.
Georgia Power’s
presentation of the green energy program in this IRP
does little to address the trust
issue and does not
indicate any near term prospects for significant growth
in renewable energy
purchases:
From IRP Main Document Section “ 10.1 GREEN ENERGY
PROGRAM - . . . Georgia Power Company has
secured resources to
meet the projected customer demand. Since the use of
“green” power will be a
voluntary purchase by
the customer, the growth of this program will be
dependent on customers’
response. Also, since
the program is voluntary, it will not have an adverse
impact on non-participants.
Contracts for the
renewable resources will likely be negotiated as
customers’ interest in the “Green”
tariff produces
additional need. The types of renewable resources will
be determined at the time of need
based on availability,
cost, mix of existing generation in the program and the
resources available in the
market.”
Why must the entire program depend on voluntary
purchases, more accurately, contributions from
extra-responsible
consumers? The IRP description also insists on the
complete discretion of Georgia
Power to determine the
source of the renewable energy purchased by its
well-meaning customers.
In order to promote a
more successful and consequential green energy program,
we ask the PSC and
Georgia Power to
consider and enact the following improvements:
A. The PSC should require the program to become Green-e
certified then provide extensive marketing
to ensure the success
of the program:
Chairman Baker, May
10, 2007, Page 5 of 8
1. Green-e accreditation provides a reputable third
party verification process to utilities who wish
to offer a green
pricing program where customers opt to pay a premium
price for a green energy
product.
2. Accreditation builds support for green power in the
community by working with a broad group
of stakeholder
interests including renewable energy suppliers.
3. Green-e ensures that renewables are sourced from the
customer's region - or if not, that the
customer is notified
of the geographic location at which the renewable energy
was generated.
4. The U.S. Green Building Council’s L.E.E.D.
Certification allows Green-e certified renewable
energy purchases to
earn points toward LEED Green Building Certification.
By requesting third party certification of the green
power program, purchasers can be confident that the
premium product meets
environmental and consumer hurdles acceptable to the
majority of
environmentally
concerned citizens. Extensive marketing for the program
will ensure that all Georgia
Power customers are
aware of the option to purchase green power as well as
the benefits of the program.
B. Customers purchasing green energy should be given the
option of choosing the source of their green
power and directing
the purchase from the choice of providers that Georgia
Power has identified. For
example, there could
be a check off for solar, wind, methane, or best
available resource.
C. Resources for the program should be doubled by a
green tariff matching fund. This fund would
match the total amount
raised from $ 4.50 per block voluntary purchases with a
few pennies from each
other rate payer.
Georgia Power’s green energy promotional flyer tells us
that “The money you spend
will support renewable
energy development that benefits every Georgian.”
Indeed, it does. Placing a
minuscule green energy
tariff matching fund amount on each customer’s electric
bill does not constitute
“an adverse impact on
non-participants.” It would more likely promote support
for clean energy
production from the
public at large. This small charge could pave the way
for public support of the
State Energy
Strategy’s proposed creation of “a Georgia Clean Energy
Fund for energy efficiency and
other clean energy
strategies (Strategy 5.3).”
V. DEMAND-SIDE PLAN
In presenting the new demand side plan, Georgia power’s
IRP introduces five new pilot demand side
management (DSM)
programs. “If approved, the new pilot programs will
result in 67 MWs of demand
reduction by the end
of the two year pilot.”
The demand side plan should add a solar thermal pilot
program. Other utilities have provided solar
water heaters to
customers along with utility grade btu meters to certify
system performance. Domestic
water heating is a
significant share of the overall energy demand. Solar
thermal technology provides a
means to heat most of
our domestic hot water load with systems that will
continue to produce over the
years of a typical
residential mortgage. We recognize that the initial cost
for such systems is
significantly higher
than a water heater jacket or a home supply of compact
florescent bulbs. Ideally, a
solar thermal DSM
program would be a collaborative initiative. Gas and
electric utilities should
materially participate
with developers, builders, contractors, lenders, and
planning and zoning boards to
promote this sensible,
effective, and environmentally responsible DSM option.
Electric utilities have a
huge stake in the
reliability and price of natural gas. Therefore, they
would materially benefit from solar
domestic water heating
offsets of conventional natural gas water heating as
well as offsets in electric
water heating.
We do not object to Georgia Power being compensated by
rate payers for its DSM initiatives.
Chairman Baker, May
10, 2007, Page 6 of 8
This concept is consistent with Georgia’s State Energy
Strategy “Strategy 3.15 – Consider Alternative
Utility Regulation
Strategies That Allow Utilities to Recover Investments
in Energy Efficiency.”
We hope that the PSC
will be able to arrive at an appropriate value for
compensation as it goes through
this IRP process
review.
There is a notable contrast in Georgia Power’s proposal
“that the collection of both program costs and
the Additional Sum
amount for certificated DSM programs be accomplished
through a DSM rider (or
riders) that would
apply to Residential and Commercial class customers” and
the previously cited green
energy program
directive that the program “will not have an adverse
impact on non-participants.”
We would also expect
to cite this contrast in response to any resistance from
Georgia Power
to all rate payers
participating in a prospective Georgia Clean Energy
Fund.
We call on the PSC to recognize that Georgia Power can
market and sell Renewable Energy
Certificates (RECs) or
Green Tags that it captures through renewable energy
programs out on the
growing market for
these instruments. Expanding renewable energy programs
introduces a utility
company revenue source
that will reduce demands on rate payers to compensate
the utility company for
its efforts.
VI. SMART-METERING AND TIME OF USE RATES
The Public Service Commission should consider requiring
Georgia Power to place smart meters or timeof-
use meters on homes
and businesses. There should also be serious
consideration of mandatory
variable rates based
on time of use.
IRP Main Document Section 14.5 - evaluating the Real
Time Pricing Day Ahead (RTP-DA) and Real
Time Pricing Hour
Ahead (RTP-HA) option states that “at current levels of
coal and gas prices, there is
less differential
between peak and off-peak prices which will provide less
opportunity for savings.”
There are costs other than fuel in meeting peak demand -
the facility capacity costs, the impact on air
and water quality, and
the impact on water supply.
Georgia Power should encourage their customers to
participate in demand management. The choice of
schedules in
previously offered time of use rates should be
continued. This would promote customer
awareness of the
amount of power they are using during certain periods of
the day and encourage them
to reduce their energy
consumption during peak use periods.
Higher rates for peak use hours will also support
premium buy back rates for production from customer
owned solar PV
systems. Georgia’s State Energy Strategy recognizes that
“solar systems also offer the
distinct advantage of
being able to displace peak demand because they produce
their highest electrical
output on the sunniest
days, which typically correspond with high demand on the
electrical system.”
We request that the
PSC and Georgia Power pursue a coordinated effort to
deploy solar PV as a
significant source of
peak demand power. Time of use rates and program
strategy to orient solar
collectors southwest
to capture more late afternoon solar energy would be
part the effort.
Chairman Baker, May
10, 2007, Page 7 of 8
VII. ECONOMIC DEVELOPMENT
The renewable energy industry has the potential to
provide significant economic development to
Georgia. According to
the Apollo Alliance, if Georgia were to fully invest in
clean energy development,
we could potentially
gain an additional $6.5 billion of economic activity in
the state and create 101,585
new jobs, which would
result in $4.1 billion of increased income in Georgia.
The Commission should
take into account the
economic development impacts of Georgia Power investing
in renewable energy in
their long range plan.
According to the Georgia State Energy Strategy Final
Draft, “ In 2001, the most recent year for which
data are available,
Georgia residents and businesses spent over $19 billion
on primary energy fuels,
nearly all of which
left the state (EIA, Table S1b, 2005) . . . Encourage
Development of Emerging
Clean Energy
Industries: The development of renewable energy
resources is a local endeavor, and
money spent for fuel
and job opportunities created by energy producers
remains within the state.
Given the prospects
for the clean energy industry in the United States,
promoting Georgia as a leader in
this field could
provide substantial benefit for the state. According to
research conducted by Clean Edge
. . . clean energy
technologies . . . will grow four-fold within the coming
decade.
Specifically, Clean Edge forecasts the following trends
(Makower, Pernick, & Wilder, 2006):
1. Biofuels (global manufacturing and wholesale pricing
of ethanol and biodiesel) will grow from
$15.7 billion in 2005
to $52.5 billion by 2015.
2. Solar PV (including modules, system components and
installation) will grow from an $11.2
billion industry in
2005 to $51.1 billion by 2015.
3. Wind power (new installation capital costs) will
expand from $11.8 billion in 2005 to $48.5
billion in 2015.”
Other nations and states are already out in front of
Georgia in capturing the economic rewards of
renewable energy
production. Germany, whose solar exposure is comparable
to Alaska’s, is realizing
significant electrical
production from grid connected solar PV panels because
programs are in place to
pay a premium price
for the power generated and metered from the PV
installations. Several states have
wisely enacted
renewable fuel portfolio mandates that require utilities
to fuel a significant share of their
production with
renewable resources. Unfortunately, no state in the
Southern Company’s territory has
done so.
The PSC should consider that there are real economic
risks, beyond our current losses, in endorsing an
IRP that extends the
state’s reliance on coal as a primary source of electric
power generation and fails to
promote an ambitious
renewable energy program. As other governments and
multinational corporations
unify to reduce
greenhouse gas (GHG) emissions, Georgia will stand out
as a disproportionate GHG
emitter. Outside
investment will be drawn elsewhere to more attractive
and environmentally
responsible areas.
In closing, we hope that the Commission will support and
endorse renewable energy policy as it comes
forward in our state
legislature and other regulatory arenas. Broader
policies covered by state and
federal regulatory
bodies such as Renewable Portfolio Standards, Public
Benefit Funds, and Renewable
Energy Production Tax
Credits provide many benefits to the renewable energy
industry.
Chairman Baker, May
10, 2007, Page 8 of 8
Thank you for the opportunity to comment and we look to
the Commission as a partner in promoting
the development of a
green energy market for Georgia.
Sincerely,
Ronald Cloud Vikram
Sami
rcloud@maconautomation.com
Chair,
Georgia Solar Energy Association
Macon Automation
Company vsami@lasarchitect.com
Macon, Georgia
Atlanta, GA
Darrin Primm Andrew
Cohen George T. Andrews
darrin@powerupco.com
acohen@ehso.emory.edu brightenergyga@yahoo.com
Power Up Solar / Power
Up, Inc. Emory University SOLAR SOURCE of Georgia
330 Austin Way Box 362
Auburn, GA 30011
Barnesville, GA 30204
Kelly Provence Keith
Freeman
koprovence@solairgen.com
willkfree@comcast.net
Solairgen, Inc.
OneWorld Sustainable, Inc.
Dahlonega, Georgia 215
Lyman Hall Rd. / Savannah, Ga, 31410
William (Bill) Hosken
Fred Fox
whosken@solarenergymarketing.com
ConsiderSolar@aol.com
Solar Energy Marketing
Inc. Fox Independent Energy Company
120 Churchill Drive
Sugar Hill, Georgia
Atlanta, Georgia,
30350
cc. The Honorable Chuck Eaton, Commissioner from
District 3
The Honorable Doug
Everett, Commissioner from District 1
The Honorable Angela
Speir, Commissioner from District 4
The Honorable Stan
Wise, Commissioner from District 5
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