The Sierra Club and the Coosa River Basin Initiative asked the Georgia Public Service Commission on July 26 for clarification on a new, 525-MW solar program that the commission mandated in a July 17 order approving Georgia Power’s integrated resource plan (IRP).
The commission had approved by a vote of 3-2 a motion proposed by Commissioner Lauren “Bubba” McDonald, Jr., that Georgia Power include in this IRP an additional 525 MW of new solar generation. The amended motion requires that 260 MW be brought online by 2015 and 265 MW by 2016. The new solar will consist of 100 MW of distributed generation and 425 MW of utility scale solar and will require competitive bidding.
While the final order should memorialize the commission’s vote, and the commission’s intent underlying that vote, the environmental groups said in their July 26 petition they are concerned that the written version of the order does not represent the plan as voted by the commission. Specifically, with respect to the 525 MW of solar energy to be added to Georgia Power’s portfolio, the groups are concerned that the text of the final order does not accurately represent what it believes was the PSC’s understanding that the additional 525 MW of solar should generally follow the guidelines of the existing Advanced Solar Initiative (ASI) program.
They seek clarification on the following points:
- First, does the commission’s order require that the 100 MW of distributed generation solar resources have to undergo request for proposal and competitive bid processes, or will distributed generation continue under the same procedure as the existing advanced solar application and lottery system?
- Second, does the term “Georgia Power’s projected levelized avoided cost” refer to the levelized avoided cost as was recently used in the ASI (i.e. .12 or .13 cents)?
- Third, does the phrase “[n]o bid shall be accepted which exceeds Georgia Power’s projected levelized avoided cost for the term of the purchase power agreement” govern both the distributed generation and the utility scale solar to be added to the portfolio or just the utility scale solar?
The environmental groups said their understanding is that the commission intended the 525 MW of additional solar to generally follow the ASI provisions. Therefore, they asked that commission enter an order requiring the following:
- the 100 MW of distributed generation will be added through an application and lottery system based on a price set in the same manner as the ASI price;
- the term “Georgia Power’s projected levelized avoided costs” means the projected levelized avoided costs as determined by Georgia Power in the ASI proceeding, which the company testified does not put any upward pressure on rates;
- the phrase “[n]o bid shall be accepted which exceeds Georgia Power’s projected levelized avoided cost for the term of the purchase power agreement” applies only to the utility scale request for proposal process, and that distributed generation will be accepted into the portfolio following the ASI procedures.
The Georgia Solar Energy Industries Assn. filed its own July 26 motion for clarification of the IRP order. The association is seeking more precise details regarding:
- whether the 100 MW of Distributed Generation (DG) included in the IRP order is subject to a competitive bid RFP process;
- which “avoided cost” calculation the commission intended to establish as a cap on solar payments from the company; and
- whether the “avoided cost” cap will apply only to the “utility scale” projects.
“It is far better for the Commission to clarify its intent supporting its IRP Order now, rather than in 2015 when the RFP process commences,” the association said. “Clarification now will provide the parties with regulatory certainty and guidance while the issues are still fresh.”
The solar group added: “GSEIA appreciates the Commission’s leadership to advance the procurement of solar energy in Georgia, as evidenced in the IRP Order. The IRP Order is extensive, covering many issues. Left as a policy decision for the Commission to decide, solar energy was the subject of several motions presented by four Commissioners. The existence of some ambiguities resulting from that process should not be surprising. By this Motion, GSEIA only seeks to resolve any ambiguities that may remain so that all parties can move forward with regulatory certainty.”