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Sierra Club July 26 2013 Ga Power Request.Pdf

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Sierra Club July 26 2013 Ga Power Request.Pdf BEFORE THE GEORGIA PUBLIC SERVICE COMMISSION IN RE: ) GEORGIA POWER COMPANY’S 2013 ) INTEGRATED RESOURCE PLAN AND ) APPLICATION FOR DECERTIFICATION OF ) PLANT BRANCH UNITS 3 AND 4, PLANT ) DOCKET NUMBER 36498 MCMANUS UNITS 1 AND 2, PLANT KRAFT ) UNITS 1-4, PLANT YATES UNITS 1-5, PLANT ) BOULEVARD UNITS 2 & 3, AND PLANT ) BOWEN UNIT 6 ) MOTION OF THE SIERRA CLUB AND THE COOSA RIVER BASIN INITIATIVE FOR RECONSIDERATION OR CLARIFICATION ON THE COMMISSION’S FINAL ORDER On July 17, 2013, Chairman Chuck Eaton and Executive Secretary Reece McAllister signed a Final Order in the Georgia Power 2013 IRP proceeding (“Final Order”). While this Final Order should memorialize the Commission’s vote, and the Commission’s intent underlying that vote, Sierra Club and the Coosa River Basin Initiative (hereafter collectively “Sierra Club”) are concerned that the written version of the order does not represent the plan as voted by the Commission. Specifically, with respect to Commissioner McDonald’s motion for an additional 525 megawatts of solar energy to be added to Georgia Power’s portfolio, Sierra Club is concerned that the text of the Final Order on page 17 does not accurately represent what it believes was the Commission’s understanding that the additional 525 megawatts of solar should generally follow the guidelines of the existing Advanced Solar Initiative (“ASI”) program.1 Thus, Sierra Club submits this motion for 1 Although this motion only addresses issues related to the additional 525 MW of solar, the Commission should not consider this a waiver of Sierra Club’s rights to pursue other arguments, nor approval of other aspects of the Final Order. reconsideration or clarification within 10 days of the effective date of the Final Order under Commission Utility Rule 515-2-1-.08. Sierra Club seeks clarification on the following points. First, does the Commission’s order require that the 100 megawatts 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 ASI (i.e. an 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? Sierra Club’s understanding is that the Commission intended the 525 megawatts of additional solar to generally follow the ASI provisions. Therefore, Sierra Club respectfully requests that the Commission enter an order requiring the following2: 1. the 100 megawatts 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; 2. 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; 2 Sierra Club notes that even the ASI price was too low as it did not consider the full value of solar. For example, distributed generation has significant benefits in addition to energy generation: decreased land use; reduced cooling demand on buildings; and location of generating units as close to load demand as possible, which in turn reduces transmission and distribution needs as well as line loss. Other utilities specifically pay distributed generation solar for this last benefit. However, in this motion, Sierra Club is only requesting that the Commission clarify the Order to ensure that it is consistent with ASI as it is Sierra Club’s understanding that that was the Commission’s intent. 3. 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. These changes will ensure consistency with the ASI and ensure that the State of Georgia receives benefits of an increased 525 megawatts of solar generation. Respectfully submitted this July 26, 2013, /s Robert Ukeiley Robert Ukeiley, Ga. Bar No. 721597 GreenLaw 507 Center Street Berea, KY 40403 Tel: 859-986-5402 Ashten Bailey, Ga. Bar No. 803367 GreenLaw 104 Marietta St., Suite 430 Atlanta, GA 30303 Tel: 404-659-3122 IN RE: ) GEORGIA POWER COMPANY’S 2013 ) INTEGRATED RESOURCE PLAN AND ) APPLICATION FOR DECERTIFICATION OF ) PLANT BRANCH UNITS 3 AND 4, PLANT ) DOCKET NUMBER 36498 MCMANUS UNITS 1 AND 2, PLANT KRAFT ) UNITS 1-4, PLANT YATES UNITS 1-5, PLANT ) BOULEVARD UNITS 2 & 3, AND PLANT ) BOWEN UNIT 6 ) CERTIFICATE OF SERVICE I certify that I have this day had served a copy of the foregoing MOTION OF THE SIERRA CLUB AND THE COOSA RIVER BASIN INITIATIVE FOR RECONSIDERATION OR CLARIFICATION ON THE COMMISSION’S FINAL ORDER upon the following persons by electronic copy: Kevin Queen Jeffrey Stair Reece McAlister Manager, Regulatory Affairs Attorney Executive Secretary Georgia Power Company Georgia Public Service Commission Georgia Public Service Comm. Bin 10230 244 Washington Street, S.W. 244 Washington Street, SW 241 Ralph McGill Boulevard, NE Atlanta, GA 30334 Atlanta, GA 30334 Atlanta, GA 30308-3374 [email protected] [email protected] Kevin Greene, Esq. G. L. Bowen, III Randall D. Quintrell, Esq. Troutman Sanders Charles B. Jones, III Randall D. Quintrell, P.C. NationsBank Plaza GA Traditional Manufacturers 999 Peachtree Street, NE, 27th 600 Peachtree Street, NE Association Floor Suite 5200 The Hurt Building Atlanta, GA 30309 Atlanta, GA 30308 50 Hurt Plaza, Suite 985 [email protected] kevin.greene@troutmansanders Atlanta, Georgia 30303 m .com [email protected] Newton M. Galloway Jeffry C. Pollock Jim Clarkson Terri M. Lyndall J. Pollock, Inc. Resource Supply Management The Lewis Mills House 12655 Olive Blvd, Suite 335 1370 Walcora Drive 406 North Hill Street St. Louis, Missouri 63141 Sumter, SC 29150 Griffin, GA 30223 [email protected] [email protected] [email protected] [email protected] Kurt Ebersbach Jill Tauber Kristofor Anderson Southern Environmental Law Southern Environmental Law Center Georgia Environmental Finance Center 122 C Street NW, Suite 390 Authority 127 Peachtree SI. Suite 605 Washington, DC 20001 233 Peachtree Street, NE Atlanta, GA 30303-1840 P: (202) 828-8382 Suite 900 P: (404) 521-9900 F: (202) 499-2078 Atlanta, GA 30303 F: (404) 521 -9909 [email protected] [email protected] [email protected] Robert B. Baker, Jr. Robert E. Green Liz Coyle Freeman Mathis & Gary, LLP Georgia Solar Utilities, Inc. Georgia Watch 100 Galleria Parkway, Suite 3330 Cumberland Blvd., Suite 55 Marietta Street, Suite 903 1600 500 Atlanta, GA 30303 Atlanta, GA 30339 Atlanta, GA 30339-5997 [email protected] [email protected] [email protected] Dan Moore Alan R. Jenkins Energy Services Group, LLC Jenkins at Law, LLC 1875 Old Alabama Road, Suite 2265 Roswell Road, Suite 100 1320 Marietta, GA 30062 Roswell, GA 30076 [email protected] [email protected] July 26, 2013 /s Ashten Bailey Ashten Bailey Counsel for the Sierra Club and Coosa River Basin Initiative .
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