Georgia Power Company already uses the poorly outdated Aurora model for its IRP, then adds its own disinformation to arrive at a pre-determined outcome. A list of GPC IRP flaws includes, but is not limited to:

(1) the long-term capacity expansion plan modeled in Aurora was constrained to only allow for generic capacity expansion beginning in the year of capacity need, which in the 2022 IRP was 2029. Yet in 2024, GPC announces the year of capacity need is 2025, but that is not reflected in the published Avoided Cost.

(2) The Company failed to address the issue of uneconomic dispatch commitment examined by Synapse in their November 2021 report “Georgia Power’s Uneconomic Coal Practices Cost Customers Millions.” Synapse determined that the Company’s uneconomic unit commitment practices resulted in $232 million in excess costs for Customers from 2017 to 2020. As in past IRPs, this coal and gas-heavy proposed portfolio fails to adequately demonstrate the economic benefits to Georgia and to Customers as required by O.C.G.A. § 46-3A-2.

(3) Continued over-reliance on a non-diverse, gas-heavy portfolio. The Company’s own scenario modeling shows that there is significant upside risk that Total System Costs could be much higher than the Base Case. This creates upward rate pressure risk from any level of carbon pricing and from high gas prices. The Base Case is six (6) times riskier than a low gas future if each scenario is equally likely as the Company claims. This is not an acceptable risk when existing, commercial technologies like solar+storage can provide all the energy, capacity, and ancillary services that gas fired units can provide, except at lower cost and lower risk than gas.

(4) Georgia Power Company assigns a 0% capacity accreditation to solar in the winter, which is incorrect. It also assigns a 100% capacity accreditation to gas and coal thermal plants, which is also very incorrect. This biases the model toward fossil thermal generation.

(5) The System reserve margin is too high because the generation capacity of Georgia Power Company and Affiliates is overbuilt, beyond what is recommended in the company’s economic Target Reserve Margin. Furthermore, there are significant historical energy exports to neighboring Balancing Authorities, which is a strong signal of excess capacity, uneconomic unit commitment, or both. Overbuilt capacity is a significant cost that is not in the interests of Georgia and Customers of the Company.

(6) Transmission planning is conducted independently of the generation planning and is only planned out 10 years, half the time horizon as generation planning. Generation and transmission planning analysis can be performed together, which provides internal consistency to the modeling and increased confidence in results, after which more detailed transmission analysis (voltage, frequency, thermal violations, etc.) can be conducted.

This IRP assumes carbon capture and sequestration (CCS) will not only be commercially viable but up to 8,000 MWs could be installed and operating on Georgia Power Company’s system by 2034, just 10 years from now. This assumption is not grounded in reality but rather in disinformation from an affiliate of Georgia Power Company, the National Carbon Capture Center, meant to make it seem like carbon capture is a viable technology. But from the Company’s own testimony, “Although these technologies are not demonstrated nor technically feasible for implementation on simple cycle combustion turbines, the Company nonetheless included an assessment of possible costs.” The Company then says that, “carbon capture costs are unreasonable for Plant Yates Units 8-10,” leaving this power plant exposed to emissions compliance costs and at high risk of becoming stranded assets, which Georgia Power Company will ask to be put into the rate base as a regulatory asset, yet another hidden cost of gas.

This IRP fails to account for the cost today to use fossil gas as a fuel, by assuming $0 for CO2-equivalent emissions in the MG0 case (used as the base case). The reality is there is a methane emissions charge in place in 2024 that adds $900 per ton of methane, growing to $1,500 per ton by 2026. Georgia Power Company’s plan to meet load growth is based on a world in which greenhouse gas emissions cost $0, which does not reflect the reality today. The result is a flawed and rushed 2023 IRP Update.

Georgia Power Company is inflating the size of the load growth by assuming a statistically improbable level of load growth, at the 95th percentile instead of the 50th percentile. This inflates the magnitude of the capacity need and makes it appear as if the need is much larger than it is likely to be. Many of these prospective customers and their load growth are not even located in Georgia Power Company’s service territory or they are controversial cryptocurrency mining operations. The Company was unable to forecast 2 years into the future, from its 2022 IRP to this one, with a load forecast that was off by 1650%, so how can we trust their plan to take us 20 years into the future?

A key pillar of load growth outlook was the $5 Billion Rivian electric vehicle manufacturing plant just east of Atlanta. Rivian announced in March 2024 that it would pause its plans to move forward with the factory.

Just a few IRP cycles ago in 2016, Georgia Power Company said, “Adding only natural gas-fired resources would result in an over-reliance on a fuel with a history of volatility and which is subject to potential future cost increases driven by regulation, changing market conditions and other factors.” Meanwhile they locked in nearly 2,400 MWs of gas-fired capacity in 2022 and now they want 2,300 more MWs of gas in this IRP. At the same time, Georgia Power Company has scaled back their fuel price hedging program in its Fuel Cost Recovery FCR-26 docket because Georgia Power Company passes 100% of the cost of fuel onto ratepayers. They can be cavalier about gas prices in their modeling because they bear no risk. In 2023, Georgia Power Company came before the Georgia Public Service Commission to recover an extra $2 billion in fuel costs for fossil gas on top of their normal annual gas bill of $2 billion. Meanwhile, solar and wind are continuing their record-long streak of $0 fuel costs. By contrast, with gas, there are hundreds of millions of dollars, likely billions of dollars in hidden costs to gas-fired power plants that Georgia Power Company cleverly manipulates to be excluded or minimized in its IRP analysis.

The IRA is heavily undervalued in this 2023 IRP Update. Georgia Power Company is undercounting the IRA benefits, using a small tax credit bonus for generic renewables or BESS additions when 40% or 50% is expected for utility scale solar and storage projects. It is possible for distribution level solar and storage projects to achieve even higher percentages of a project’s cost in Investment Tax Credit and other federal benefits provided by the IRA. Moreover, Georgia Power Company is suppressing the development of new solar and storage resources by not committing to a retirement date of 2028 for its coal units, which would unlock the 10% Energy Community tax credit and new economic development at critical sites like near Plant Bowen and near Plant Scherer. We are 1.5 years into the IRA with 8.5 years left, and Georgia Power Company is wasting this opportunity.

The Mississippi Power Company Power Purchase Agreement for 750 MW is a black box that when opened is full of dirty coal, gas, and likely the worst of their power plants, the bottom of the barrel. Georgia Power Company has not revealed what is in the PPA but we can expect it contains coal-fired and gas-fired capacity dating to 1965, meaning the oldest assets will be entering their 7th decade of service.

Georgia Power Company appears to have entered into this PPA and the Santa Rosa PPA outside of the law, specifically O.C.G.A § 46-3A-3 that lists “Actions prohibited without a certificate of public convenience and necessity” and this includes “enter[ing] into a long-term purchase of electric power” and would infer prohibition of the further step of re-marketing a contracted PPA for two (2) years prior to capacity need.

Georgia Power Company has already spent $250 million on the Yates CTs without any approval from the Commission. They already signed a precedent agreement for gas pipeline service possibly from its own pipeline affiliate and also contracted for engineering services with a major EPC contractor and also began procurement with a major turbine OEM, already signed and in effect as of last month, and also signed a Payment for Ecosystem Services agreement for the Yates CTs, and initiated LGIP applications for interconnection request for the Yates CTs and even held the interconnection request scoping meeting for Yates CTs back in August 2023. All these actions and costs were made imprudently before allowing the Commission to review and approve them. This is why there is breathless urgency from Georgia Power Company to make haste and approve this massive buildout of new gas-fired units…or at least get their imprudent costs covered as regulatory assets. This is a waste of $250 million in sunk costs for which Georgia Power Company is already asking pre-emptively to be given regulatory asset treatment.

Moreover, the Yates CTs will not be able to deliver full firm Network Resource Interconnection Service or NRIS transmission capacity to meet peak loads until 2028—many years after the current capacity shortage. The Company only requested Energy Resource Integration Service or ERIS in the interconnection queue for the Yates CTs, which means the CTs can be curtailed during peak demand and cannot provide full deliverability to the network during periods of stress (until 2028).