Georgia Power’s 2022 Integrated Resource Plan in the Home Stretch: Yet Key Issues Remain 

A number of issues that we (Southern Alliance for Clean Energy & Southface), and other parties, are concerned about, were either omitted from the Stipulation or otherwise insufficiently addressed.

Guest Blog, Bryan Jacob, and Forest Bradley-Wright | June 17, 2022 | Coal, Energy Efficiency, Fossil Gas, Georgia, Solar, Utilities

This blog post was jointly prepared with contributions from Southface (Will Collier and Katie Southworth) and the Southern Alliance for Clean Energy (Bryan Jacob and Forest Bradley-Wright).

“In everything we do, our goal is to provide people with ways to better meet their economic challenges, build better communities, and seek a better future for their children.” – Tom Fanning, Chairman & CEO of Southern Company (Georgia Power is a subsidiary of Southern Company)

Georgia Power and the Public Interest Advocacy Staff of the Georgia Public Service Commission (PSC) have reached a preliminary agreement on many issues within Georgia Power’s triennial Integrated Resource Plan (IRP). On Tuesday, they jointly filed a Stipulation resolving 67 discrete points. The agreement now goes to the Commission for a vote. 

Earlier this year, SACE and Southface jointly intervened in the IRP proceeding, as did more than a dozen other organizations, associations, and municipalities from across Georgia. Only a select few of these organizations, however, were privy to the private negotiations that led to the stipulated agreement. As a result, a number of issues that we, and other parties, are concerned about, were either omitted from the Stipulation or otherwise insufficiently addressed. 

SACE and Southface’s recommendations focus on incorporating more competition and competitive market principles into the IRP and DSM (Demand Side Management) programs, lowering costs to consumers, providing a better and more efficient electrical system for all Georgia Power customers, and meeting the stated goals of Southern Company’s leadership.

Recommendations for Amendments to the Stipulation in Georgia Power’s 2022 IRP

1. Increase Georgia Power’s proposed DSM annual efficiency targets proportionately to save customers at least half a billion dollars of PACT (Program Administrator Cost Test) net benefits over three years.

Energy efficiency costs 2x to 3x less than avoided cost (i.e. the cost required to generate the same amount of energy saved through energy efficiency). The math is simple: The more investment in energy efficiency, the lower the total cost to customers. The less investment in energy efficiency, the higher the costs for all customers. Our proposed amendment is a clear, low-cost opportunity “to provide people with ways to better meet their economic challenges,” just what Mr. Fanning says Georgia Power should be doing.

Estimates of 3-year Customer Savings at Levels Above Georgia Power’s Proposal

In our expert witness testimony, SACE and Southface supported higher efficiency savings levels in the Advocates Case, which would save customers $1 billion more over 12 years than what the company proposed. It’s unfortunate that Georgia Power wants to invest less in energy efficiency, but it’s not surprising, since energy waste is quite profitable.

2. The Renewable Non-Renewable (“RNR”) monthly netting program should be reinstated with no participation cap. 

The “monthly netting” program gives solar customers full credit for the energy their systems contribute back to the grid and was adopted as a limited pilot in 2019 but was capped at 5,000 customers. Our recommendation is consistent with the testimony of Dr. Marilyn A. Brown, from Georgia Tech, who refuted Georgia Power’s primary objection. This type of distributed solar presently has a penetration of approximately 0.3% in Georgia – far below the level that could potentially result in discernible influence on nonparticipant rates. In Mr. Fanning’s words, this amendment would “provide people with ways to… build better communities…” 

Distributed Rooftop Solar as a Percent of Total Solar in Georgia, 2019 (1)

Georgia Power is committed, however, to pretending that a theoretical cost-shift is a ‘boogeyman’ for solar development in Georgia, despite the fact that current studies from major energy labs show that no predictable cost-shift occurs until 10% solar penetration (2). Scare tactics about theoretical cost-shifts in solar development look slightly silly as well while Georgia Power simultaneously doubles down on fossil gas production, which has seen prices vary by more than 100 times the normal price, in some states, over the last two years (3). Again, we ask: What’s more profitable for Georgia Power? Allowing private citizens to install their own solar systems, or continuing to centrally control energy generation through high-volatility fossil fuels?

3. A decision on the Purchased Power Agreement (PPA) for Plant Dahlberg Units 1, 3, and 5 should be deferred until the 2025 IRP.

Those are fossil gas combustion turbines with a combined summer capacity of 228 MW.  That PPA doesn’t start until 2028, so the decision doesn’t have to be made now. In addition, the Commission is also expected to make a policy decision on whether to keep two coal units at Plant Bowen (another 1,400 MW) beyond when Georgia Power has proposed to retire them. If the Commission orders Georgia Power to maintain Plant Bowen Units 1 & 2 beyond 2027, additional PPAs should be rejected as well, because that incremental capacity will not be necessary.

For fossil fuel production, the Stipulation would allow Georgia Power to have its cake and eat it too. By deferring a decision on the retirement of Plant Bowen Units 1 & 2 to the Commission, but limiting the timing of that retirement until after 2027, and up to 2035, Georgia Power would keep excess (i.e. unnecessary) fossil fuel production online while placing any future blame for that decision at the feet of the Commission. How does extending coal generation in Georgia, while adding more fossil gas generation, in Mr. Fanning’s words, “provide people with ways to… seek a better future for their children?”

4. Establish a Transmission Planning Collaborative that includes opportunities for meaningful engagement by interested stakeholders. 

Georgia Power’s rebuttal testimony refers to Southeast Regional Transmission Planning (SERTP). However, the SERTP planning process is wholly insufficient to meet urgent infrastructure needs in Georgia. It restricts public access to essential planning information that is often open to the public in other planning regions. Holistic and transparent transmission planning is critical to Georgia’s energy future, especially in the context of the ongoing energy transition exemplified by the key issues we highlight above as well as through the words of Southern Company’s leadership.

If Mr. Fanning’s, and Southern Company’s, goals are to be taken as anything more than deflections and diversions from profit-seeking at all costs, then the four low-cost opportunities above should be welcomed by Georgia Power as simple ways to fulfill the promises of their Chairman and CEO.

More Information and Next Steps

Witnesses for SACE and Southface presented various other recommendations and proposals in their testimony, but the items listed above are the most crucial for inclusion in the Commission’s Final Order.  The final hearing in this matter will be next week (Tuesday, June 21). 

Please contact Bryan Jacob ([email protected]) or Will Collier ([email protected]) for more information, and if you’d like to learn more about Georgia Power’s 2022 IRP, read our other blog posts:

To provide public comments on Georgia Power’s 2022 IRP, go to the Georgia Public Service Commission’s Public Comments Page and reference Dockets 44160 (IRP) and 44161 (DSM). Comments submitted at least 24 hours prior to the final decision on July 21, 2022, will be included in the public record, but the Commission is likely to finalize the details of any amendments to the Stipulation over the next several weeks.


  1. Brown, M.A., R. Tudawe, and H. Steimer, 2022, Carbon Drawdown Potential of Utility-Scale Solar in the United States: Evidence from a Case Study of Georgia, Renewable and Sustainable Energy Reviews (61): 112318.
  2. Barbose, G, 2017, Putting the Potential Rate Impacts of Distributed Solar into Context. Berkeley, CA: Lawrence Berkeley National Laboratory. Available at:
  3. See, for example,
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