High-level overview of the RFP includes:

• Project proposals are to be submitted in October, and selections announced in the spring of 2023.
• The RFP requests projects be online between 2023 and 2029.
• “Carbon-free” is defined as including the following sources: “solar, wind (offshore or land based), hydro, geothermal, biomass, nuclear, green gas, battery energy storage systems (BESS) paired with above resources, standalone BESS, and hybrid combinations of the aforementioned resources.”

Green energy, but for who?

While TVA does not explicitly say what it is seeking to do with this solicitation, in the past TVA has used these kinds of RFPs to put together a book of projects that its large customers can look through if they are interested in entering into a Green Invest contract to fulfill clean energy requirements. TVA’s Green Invest program is modeled after contracts to provide solar to Google and Facebook, and since the program was initiated it has also included Vanderbilt University in Nashville and the Knoxville Utilities Board, one of TVA’s largest utility customers. Through this program, it is clear that TVA is being responsive to some of its largest single customers, but potentially at the expense of the rest of TVA’s customer base that does not receive the environmental or economic benefits associated with the projects that are reserved for particular customers.

Select headlines announcing Green Invest deals made by TVA customers

TVA states in its latest quarterly filing with the Securities Exchange Commission (SEC) that “In recent years, TVA has issued request for proposals (“RFP”) in order to meet customer preferences and requirements for cleaner energy. TVA will procure the renewable energy and sell the resulting RECs to specific customers, allowing TVA to increase its renewable energy portfolio without additional costs to other TVA customers.” Since renewable energy costs continue to be both lower and less volatile than the cost of existing fossil fuel resources, TVA is adding additional costs to non-Green Invest customers by not contracting for these renewable projects directly and offsetting some of its expensive fossil fuel generation.

Good to do now, would have been better a year ago

Issuing an RFP to be able to identify the most cost-effective clean energy resources is an important step in decarbonizing the power sector, but with TVA having recently completed analysis that led it to conclude that new gas is a less expensive replacement for a retiring coal plant than a clean energy option, it seems this particular RFP would have been a lot more useful a year ago so that it could have informed TVA’s coal replacement analysis.

As SACE learned from requests to TVA through the Freedom of Information Act (FOIA), TVA’s coal replacement analysis primarily relied on cost assumptions from its 2019 integrated resource plan (IRP). Considering how much solar and storage costs have declined since 2018-2019, and how volatile gas price forecasts are today, a rerun of the coal replacement analysis would have a very different result. In fact, analysis shows significant savings from a clean energy option.

As the cost of solar has declined the installed capacity has increased. (Chart shows blended average solar price and total installed capacity for the United States from 2010 through 2021. Source: SEIA/Wood Mackenzie Power & Renewables U.S. Solar Market Insight Q2 2022.)

Since TVA has not made a final decision in how it will replace either the Cumberland or the Kingston coal plants, it should hold off on making these decisions until it is able to update its analysis with the results of this RFP and the latest fuel costs.

Results in time to inform the next IRP

On the other hand, by issuing this RFP now TVA will have fairly recent pricing information for clean energy technologies that it can use in its next IRP, which is expected to start toward the end of 2022 or in 2023. An IRP typically uses generic forecasts for the cost of technologies like solar and battery storage, both technologies that have seen costs drop much faster than any forecast was able to predict. This is one reason SACE has been advocating for the practice of All Source Procurement (ASP), which in a way combines an RFP process with the IRP process. By using real-world price proposals and projects to develop portfolios through the least-cost planning process already employed by IRPs across the region, utilities can reduce risks associated with relying on bad forecasts and save customers money. When TVA states in this RFP that it “will use least-cost planning in all evaluations,” that sounds a lot like an ASP-style process.

Once leading, now lagging

The bottom line is that TVA needs much more aggressive, concrete goals that will help it reach net-zero emissions by 2050, which is what science has determined is needed to mitigate the worst effects of the climate crisis. Despite having achieved a higher emission reduction today, compared to 2005 levels, than many utilities, TVA is now lagging behind comparable utilities in commitments to take the next critical steps to decarbonize. For example, Florida Power and Light recently committed to 90 GW of solar and 50 GW of energy storage to achieve zero carbon emissions by 2045.

TVA has taken important steps in the past to reduce carbon emissions from its power generation. This RFP is an important step in continuing decarbonization, but it comes at a time that TVA is adding a significant amount of long-term fossil fuel power plants across its territory that can limit TVA’s ability to achieve zero carbon.

Hopefully the first of many

Based on previous analysis, we estimate that TVA would need to add at least 40-50 GW of clean energy resources like solar, wind, and storage in order to get to zero carbon emissions across its system. This is in addition to deploying robust and equitable energy efficiency, rate design, demand flexibility, and distributed generation programs. So this RFP for 5 GW of carbon-free resources is a welcome step, and will hopefully be the first of many similar RFPs that will ultimately result in a carbon-free TVA grid on a timeline in line with limiting the worst impacts of the climate crisis.

The post TVA issues request for carbon-free energy proposals appeared first on SACE | Southern Alliance for Clean Energy.

As part of the DEIS, TVA identified three possible methods for replacing the coal power with:

• Alternative A: A large (1,450 megawatt) gas combined cycle (CC) power plant that would require the construction of a new 32-mile-long gas pipeline to the Cumberland site,
• Alternative B: Two gas combustion turbine (CT) plants (1,530 megawatts) at different locations, and
• Alternative C: 3,000 megawatts of solar and 1,700 megawatts of storage.

In the DEIS, TVA announced that its intention is to pursue Alternative A and replace the coal plant with yet another fossil fuel, in this case, a fossil gas plant and a 32-mile pipeline to transport gas to the plant. 

As required by federal law, TVA held a public comment period to solicit public feedback on the DEIS that closed June 13th. During the comment period,  concerned individuals, organizations, cities, and a local power company in the Tennessee Valley indicated a strong preference for reaping the financial, economic development, and environmental benefits that would result from TVA pursuing clean energy replacement options for Cumberland, specifically demand-side management and energy efficiency, renewable energy, and storage. Additionally, numerous groups pointed out that TVA failed its obligations to provide the public with the information necessary for adequately informed decision-making.

One of TVA’s largest customers urges TVA to prioritize clean energy to help the community meet goals, and be economically competitive

Nashville Electric Service, the Metropolitan Government of Nashville and Davidson County, and Mayor John Cooper  all submitted separate comments and resolutions to TVA, calling on them to pursue less polluting energy options such as solar, while also highlighting the goal the city has put forth to reduce greenhouse gas emissions 80% by 2050. The comments also highlight how TVA’s investment in unnecessary fossil fuel infrastructure would saddle Nashville with the pollution resulting from a large gas plant at Cumberland for decades and undermine the city’s economic competitiveness in attracting businesses to locate locally.

Cumberland Fossil Plant. Source: Tennessee Valley Authority on Flickr.

EPA weighs in with concerns about TVA’s thoroughness, transparency, environmental impacts, and costs to customers

In a rare move, U.S. Environmental Protection Agency (EPA) officials found TVA’s plans for a new, multi-billion-dollar gas plant so flawed, its is encouraging the utility to change its plans or to choose another alternative entirely. This suggests EPA has substantial concerns and language this strongly-worded and lengthy from EPA is quite rare. The proposed plant’s climate impact would be so significant, that EPA goes as far as to say the agency “strongly recommends the proposed action be modified or a different preferred alternative be selected in the Final EIS.” TVA’s proposed gas plant would emit dangerous greenhouse gasses for decades to come, but EPA officials write that TVA’s draft EIS doesn’t adequately quantify or disclose the greenhouse gas emissions associated with its proposed plant. EPA officials wrote that TVA’s plan fails to analyze alternatives that include available and affordable renewable energy and energy efficiency options.

In the letter, EPA officials rightly point out that the proposed gas buildout would lock TVA’s roughly 10 million customers into paying for gas for decades, even as the costs of renewable energy options continue to fall. The financial risk associated with this lock-in is currently being demonstrated by volatile fossil gas prices increasing monthly power bills across the Tennessee Valley due to TVA’s fuel cost adjustment charges. 

Advocacy groups speak out

We at the Southern Alliance for Clean Energy submitted comments calling on TVA to more thoroughly evaluate all replacement options instead of skewing its analysis toward its desired choice of fossil gas. SACE also highlighted the fact that if TVA does indeed elect to move forward with new fossil gas plants and pipelines, then TVA ratepayers will be stuck footing the bill to pay for volatile gas market prices and stranded asset costs down the road. Furthermore, we point out that TVA does not need additional gas to integrate renewables, as they often claim. 

Additionally, Tennessee Interfaith Power and Light (TIPL), Appalachian Voices, Sierra Club, The Southern Environmental Law Center (SELC), the Center for Biological Diversity, and the Clean Up TVA coalition submitted comments on the DEIS. Given TIPLs faith-based approach, their comments focused on the need to protect our planet and future generations from climate change and pollution. Appalachian Voices’ organizational comments paid particular attention to the job impact of possible clean energy portfolios as compared to TVA’s preferred gas plant and pipeline. The chart from the comment letter below demonstrates various illustrative clean energy portfolios from SACE, Sierra Club, and RMI that would result in far more jobs than the fossil gas option. 

Table of the number of jobs created by possible replacement options (for illustrative purposes) for the Cumberland coal plant. Source: Appalachian Voices comments to TVA, June 13, 2022.

The Southern Environmental Law Center’s comments – filed jointly with Appalachian Mountain Advocates, Sierra Club, Center for Biological Diversity, Appalachian Voices, Energy Alabama, and SACE – are wide-ranging technical comments focused on:

• TVA’s shortcomings in fulfilling obligations required by their DEIS filing,
• Lack of transparency with the public,
• Flaws in TVA’s analysis that bias the selection of the preferred replacement power resource, and
• Various environmental and socioeconomic impacts to Middle Tennessee.

The groups submitted a technical study by Synapse Energy Economics that Sierra Club commissioned, which showed that customers would save about $9 billion in the next two decades if TVA replaced its coal plants (including Cumberland and others) with a low-cost, highly-reliable clean energy portfolio instead of a business-as-usual portfolio of prolonged reliance on coal and expansion of fossil gas power. 

The Center for Biological Diversity focused comments on the urgent crisis of climate change and how TVA’s decisions will impact Valley residents in an ever-warmer climate. Finally, the Clean Up TVA coalition, of which many of the aforementioned groups are a part including SACE, submitted its own comments combining many of the issues raised in the other group’s comments.

Individuals from around the Valley speak out

Hundreds of individual citizens added their voices urging TVA to replace the Cumberland plant with clean energy alternatives. Appalachian Voices members submitted more than 150 individual comments to TVA. Sierra Club members submitted more than 650 individual digital comments, including more than 300 personal messages, mostly focused on the affordability, reliability, and availability of renewable energy. Through the Clean Up TVA coalition, more than 350 people signed onto comments to TVA. Read some of the messages from TVA area residents delivered by the Clean Up TVA Coalition below. You can view the full petition and all individual comments here.

“Stop using carbon emitting fuels. Lead us to a clean renewable energy future. The technology is here already.” – Chet H., Knoxville, TN 

“I am a scientist and a consumer of TVA power in Tennessee. I have reviewed TVA’s current plan for expanding power production capacity. I applaud TVA for the upcoming planned retirement of coal- fired plants: Cumberland Fossil and Bull Run. I am writing to support replacement of part of the retired fossil generation with clean energy producing solar, wind and battery storage options. In order to achieve the net-zero carbon objective and prevent irreversible climate damage from fossil combustion, TVA must step up to building clean energy infrastructure. It must start now.” – Debra D., Spring Hill, TN

“Please be a leader for renewable energy, to make up for all the greenhouse gas emissions that Tennessee has put in the atmosphere for decades. The next generation is depending on organizations like TVA to make a difference to help mitigate climate change and reduce the risk to humans around the world.” – Deb O., Knoxville, TN 

“Solar + Wind + Battery storage are more cost effective than fossil fuels (leaking gas wells and fracking) because of three items:

1. solar + wind are free and have no input (fuel) costs and no fuel/well leaks of CH4 or CO2!
2. solar and wind have no output liability like above fuel leaks  eg. 2500 sq mile methane cloud over NM ) and fuel burning emissions
3. Battery storage gets cheaper as it scales”
– Frank Warmath, Humboldt, TN

“In making its preliminary decision to build a large gas plant and pipeline, TVA has submitted an entirely inadequate full cost and environmental analysis, which is required by law under NEPA. TVA has already dumped 150 million tons of coal ash onto the land and into the rivers around the Kingston Coal Plant, resulting in extensive environmental damage. We can’t afford more risky and expensive fossil fuel investments or more environmental or human harm. The country is moving rapidly to renewable energy to confront the climate crisis, and TVA should be a leader in a just transition to clean energy instead of a disgrace to its own history.” – Helen D., Knoxville, TN 

“Clean energy = healthy future, more jobs, and economic security.” – Isabelle M., Nashville, TN

“Please stop turning a blind eye to progress. TN needs to be the first in something rather than the follower. Stop spending money on old-date technology. Even your children want to progress in technology.” – John Nolen, Lenoir City, TN

“You are in a position to make a big difference to climate change. Be a hero!” – Karen S., Memphis, TN

“The people are at their financial limit, history will show the disregard for sane energy policies for profit. In the long run energy in a civilized nation should be safety first always.”– Nathan L., Memphis, TN 

“The TVA ratepayers are going to be strapped with bearing the rising cost of natural gas as the unwise investment in gasification requires astronomical investment. The detrimental costs to public health, negative effects contributing to climate shift, especially from methane, along with other environmental concerns such as those caused by fracking, make gasification of retired coal plants completely unacceptable—but more precisely, unnecessary. The technology is here NOW to make use of all sources of renewables including WIND which must be added back in the mix!  Instead of taking us forward, the CURRENT TVA BOARD is taking us backwards, pandering to BIG FOSSIL. We need the transition to a renewable energy economy NOW—the time is HERE. No “transition fuels”—renewables and storage NOW.” – Nancy Muse, Florence, AL 

“TVA led the way in bringing electrification to the South. It should be leading the way making strides and investment in clean energy in the South. The sources for methane are dirty supply lines and have negative impacts across the board.We must care for our land so that it will continue caring for us.” –Jeremy W., Goodlettesville, TN

Next Steps

These comments will hopefully guide TVA to reconsider its preferred fossil gas replacement alternative for the Cumberland plant. We expect a final decision on the Cumberland plant by the end of 2022.

The post Hundreds of individuals and groups, including Nashville and the EPA, submit comments on TVA’s proposed gas power plant and pipeline appeared first on SACE | Southern Alliance for Clean Energy.

The event featured several local dignitaries including Knox County Mayor Glenn Jacobs, and Knoxville City Council members Seema Singh and Tommy Smith, all of whom supported the project. 

Knoxville dignitaries including Knox County Mayor Glenn Jacobs (suit), Knoxville City Councilwoman Seema Singh (grey dress), and SEEED Executive Director Stan Johnson (green shirt) cut the ribbon outside the solar home.

Building Generational Wealth Through Homeownership

SEEED seeks to address the highest Black poverty rate in the Southeast, with 42% of Black Knoxvillians living in poverty. As one way to address this high poverty rate, SEEED is selling the solar home to a low-income family as a way to build generational wealth and create a pathway out of poverty.  The low energy bills that will result from all the power generated by the solar panels and stored on the batteries, coupled with the ultra energy efficient design that includes insulation in the attic and walls, plus a high efficiency heat pump to heat and cool the home, is a practical solution to poverty and high energy burdens that will benefit the new homeowners and their family for years to come.

For most of the year, the homeowners should pay almost nothing on their electricity bill, because almost all of their power needs will be met by solar power + storage. Additionally, the future homeowner’s need for power will be reduced because of the weatherization measures taken. 

Solar panels on the roof of the SEEED solar home.

The project has been ongoing for nearly a year, with early financial support from us at the Southern Alliance for Clean Energy (SACE). SEEED plans to build several more homes in the coming years that benefit the environment and community at large. In fact, SEEED recently broke ground on its second ultra-energy efficient solar home that will be sold to another low-income family to help them build generational wealth and promote clean and affordable energy.

These homes and financing that will allow the home to be sold below-market rates, and will have give the family equity of approximately $70,000 as soon as they move in, serve as models for other sustainable and affordable housing options for many families in Knoxville and surrounding areas in the years to come. 

Building Pathways Out of Poverty with Workforce Training

Part of SEEED’s mission is to train young people in Knoxville on workforce development skills, including weatherization, to build pathways out of poverty. Many of those youth workers assisted in the construction of the home and will continue to hone their skills as more solar homes are built in the Knoxville area.

A recent Department of Energy jobs report found that in Tennessee, 4,870 workers were employed in the solar electric generation sector – the second-highest sector in the energy generation category behind hydroelectric generation. Additionally, the report found that 885 workers were employed in the energy storage sector. And the energy efficiency sector employed nearly 50,000 workers in Tennessee. The electric power generation and energy efficiency sectors are projected to grow more than 1% in the next 12 months, according to the report. SEEED is helping employ workers in all these fields.

JD Jackson, Chief Operating Officer at SEEED, stands in front of the solar home.

We look forward to more clean energy homes in Knoxville and beyond and will continue to advocate for policies to ensure equitable and affordable access to energy in a state that is growing increasingly hostile to clean energy. We are proud to be in the Knoxville Water and Energy coalition with SEEED. Learn more about our work in Tennessee and SEEED’s work.

The post Local Knoxville Nonprofit Hosts Open House for Low-income Solar Home  appeared first on SACE | Southern Alliance for Clean Energy.

Energy Efficiency Measures that would Lower Customer Bills Ignored, Despite Company “Commitment” to Customers

In pre-filed testimony, CEO Chris Womack states, “At Georgia Power, our customers are, and will always be, at the center of all we do.” This echoes similar statements made by Southern Company CEO, Tom Fanning, in a 2021 report that outlines the company’s views on energy justice: “We believe the communities we serve should be better off because we are there – a goal that’s bigger than the bottom line.”

All evidence to the contrary. If customers were at the center, and if there were anything bigger than the bottom line, Georgia Power would be embracing more energy efficiency programs. In the latest IRP, Georgia Power proposed to freeze energy efficiency savings levels at the same levels ordered by the Commission in 2019. And the rate case looks to be no different: Mr. Womack’s testimony doesn’t mention energy efficiency, at all.

Georgia Power’s own analysis reveals that more energy efficiency would result in lower total cost for customers. The utility’s objection to expanding the energy efficiency (Demand Side Management, DSM) program targets is that the Company perceives it as a “cost shift” – some customers who choose not to take advantage of the programs would still have to pay for those that do. And if that’s truly a concern, the Company should actually increase its energy efficiency offerings. Many low-income customers have been paying into energy efficiency for years or even decades with every monthly bill, even before income-qualified energy efficiency programs were available to them.

Georgia Power’s energy savings fell considerably further in 2020 compared to both peer utilities and the national average. The Company’s dismissal of energy efficiency will reduce these savings even further in years to come. Source: SACE’s “Energy Efficiency in the Southeast” fourth annual report, February 2022, page 10

Further, it’s disingenuous for Georgia Power to oppose programs that would enable customers to reduce their consumption and bills because it would potentially increase ratepayer costs when they are proposing to increase the Return on Equity (ROE) from 10.5% to 11.0% which will cause a direct cost-shift of $80 million per year from Georgia Power ratepayers to Southern Company shareowners.

The True Bottom Line: Rates and Bills are Going Up

• For residential customers, Georgia Power’s proposal would increase a typical household annual bill by over $195 or $16.29 per month.
• The biggest jump is just around the corner in 2023, 11.4%, followed by smaller increases in 2024 and 2025. [$14.32 + $1.35 + $0.62 = $16.29 per month]
• Other customer segments will experience similar levels of increase as well. Small businesses, for example, will increase 12%.
• Large industrial businesses on the marginal price rate will only increase 6.3%.
• In total, over the three-year period, the proposed rates and fees will increase by more than $1 billion or 11.9%.

But Shareowners Will Still Be Compensated 

• Part of that increase is because Georgia Power has proposed to increase the Return on Equity (ROE) by an additional 0.5%. (ROE is the portion of the revenue requirement that a utility ultimately keeps as profit. See How do Electric Utilities Make Money? for more information.)
• If the Public Service Commission – Georgia’s elected energy regulators – approves that increase, Georgia Power will collect approximately $80 million additional each year for shareowners of Southern Company.
• The 11% ROE Georgia Power has requested is well above the U.S. average. For reference, “The combined median 9.50% ROE in 2021 was slightly higher than 9.45% in 2020, which dropped from 9.70% in 2019.“
• In addition, there’s an earnings band around that target ROE, from 9.5% to 12% — which Georgia Power has proposed to keep the same. In each of the last 10 years, Georgia Power has earned above their target and in four of the last ten, they’ve earned above the top end of the band.

Options to Take Advantage of Bill Lowering Renewable Energy Programs Will Be Limited

• Georgia Power continues to oppose monthly net metering that would properly credit solar customers for the energy they produce, despite the fact that a pilot test ordered in the 2019 Rate Case was very popular.
• The traditional Residential (“R”) tariff will be discontinued. After the end of this year, it will not be available for newly constructed residential premises. Since the 2019 Rate Case, the new Time-of-Use Residential Demand (TOU-RD) “Smart Usage” tariff has been the default for new construction, though customers continue to have the ability to opt for a different rate upon request. Apparently, the ordinary R tariff will only be available for existing premises, so new construction won’t be able to opt for that.
• Georgia Power is proposing to raise the fee for participating in the Community Solar program. At $24.99 per month for each subscription block, many felt the program was already overpriced. Now Georgia Power has proposed to increase that monthly fee to $27.99 per month. That seems likely to hinder, rather than help, enrollment.

Next Steps + Take Action

The rate case process is just getting started. We’re presently working with the first filing made on June 24. The first round of hearings will begin on September 19, followed by another on November 8. A decision is scheduled for December 20.

Additionally, we’re still a few weeks away from final PSC decisions on the Georgia Power IRP (Integrated Resource Plan).

We’re bringing Georgians together to be the generation that achieves clean, safe, and healthy communities because all of us deserve to benefit from an equitable clean energy transformation. Join us to learn how you can stay involved in the rate case and more to Renew Georgia.

Get Involved

The post What’s at the Center of the Georgia Power 2022 Rate Case? appeared first on SACE | Southern Alliance for Clean Energy.

Numerous studies conducted in recent years have demonstrated the potential for savings from Memphis switching energy supplies, but the studies needed to be ground-truthed with actual bids from electricity suppliers. That’s what MLGW did last year when it published a series of three requests for proposals (RFPs).

The June 9 meeting was the public’s first glimpse at the results of the bids and the results verify that there could be large benefits to Memphians from MLGW switching to new electricity supplies. 

The presentation to the Board and City Council was informative and it was clear that the evaluations have been thoughtful and diligent so far, yet it lacked critical information that the community needs in order to make an informed decision, particularly when the decision is as monumental as what faces them.

Memphis City Council, the MLGW Board, the media, and the public gather in Memphis to hear a joint presentation from GDS on the status of MLGW’s RFP looking at alternate energy supply options other than TVA.

Below are a few top takeaways from the presentation including benefits that were verified at the meeting and information gaps exist that need to be explored in the coming weeks before MLGW makes any decisions.

What the Presentation Verified Clearly

Big savings are available for Memphis and Shelby County

The initial RFP evaluation verified that Memphis could indeed save large amounts of money by switching electricity supplies, as numerous studies have shown. Initial analysis of the RFP bids discussed in the presentation showed that one of MLGW’s preferred portfolios of energy resources would yield about $55 million per year in savings compared to TVA’s lowest-cost offer. This level of savings is quite large and amounts to over a billion dollars over 20 years–a reality that shouldn’t be overshadowed by the fact that greater savings were predicted by previous studies. $55 million may actually be an underestimate due to cost-saving factors that were not incorporated into the tentative evaluation, however, as detailed below.

MLGW Alternative Power Portfolio Levelized Costs 2028-2047, Source: MLGW GDS presentation, June 2022, Slide 43

Companies are lined up to invest in Memphis and Shelby County

The presentation showed that there is strong industry interest in investing in Memphis and Shelby County. The RFP yielded more proposals from companies ready to build in Shelby County than would be able to be accommodated, meaning MLGW gets to selectively pick and choose only the best proposals. For example, while MLGW was seeking up to 1,000 megawatts (MW) of local solar in Shelby County and over 2,000 MW of solar from Arkansas and Mississippi, they received bids on 2,150 MW of local solar and 4,900 MW of out-of-state solar–twice as much as MLGW was seeking. 

What the Presentation Verified, with Some Reading Between the Lines

MLGW’s integrated resource plan study (IRP) in 2020 clearly identified major economic development and environmental benefits as potential upsides of switching electricity suppliers. The presentation indeed verified these very important benefits, yet did not include these benefits as direct points in the presentation. Rather, the presentation left us needing to read between the lines to draw out these conclusions. As MLGW and their contractor GDS Associates finalize offers from bids and update their evaluation before making a recommendation to the MLGW Board, it is essential that they place the following big benefits back in the forefront of evaluations as they were in the 2020 IRP discussions.

Billions of dollars of investment are ready to flow into Memphis and Shelby County, creating local jobs, and generating local government revenue

MLGW’s integrated resource plan study (IRP) in 2020 indicated that leaving TVA would prompt nearly $3 billion of capital investment into the Memphis area through building power generation and transmission infrastructure. The RFP bore that out and identified specific companies that are ready and willing to do billions of dollars worth of projects in Shelby County. This investment would mean jobs for Memphians and tax revenue for the City and County to fund critical services for residents.

For example, solar farms can generate thousands of dollars per megawatt in property tax for local governments. If MLGW contracted for 1,000 megawatts of solar to be built in Shelby County, that would mean millions of dollars every year in property tax revenue to Shelby County and Memphis. These potential projects were not accounted for in the presentation.

Memphis would become a clean energy leader and slash climate pollution while saving money with an alternative energy supply

MLGW’s energy supply would be about 75% renewable under the lowest-cost alternative energy portfolio considered in the RFP. Much of that would be local solar energy produced by solar farms in Shelby County while the rest would be solar energy brought in from Arkansas and Mississippi. In fact, a large part of the reason why the lowest-cost option of MLGW’s preferred energy portfolios is less expensive than TVA power is precisely because of taking advantage of low cost of solar, which TVA is failing to fully take advantage of. All this renewable energy would result in slashing the climate-warming pollution from Memphis’ electrical supply, to the tune of nearly 40% lower carbon emissions compared to what TVA is offering.

MLGW Alternative Power Portfolio Mean 20-Year Carbon Emissions, Source: MLGW Board-Presentation, August 2020, Page 20.

The carbon reduction offered by the alternative energy portfolio could be key to meeting the Memphis Area Climate Action Plan goals, championed by Mayor Strickland and Mayor Harris, which seeks to achieve 80% carbon-free electricity, particularly solar and wind, by 2035 and 100% by 2050. Meanwhile, TVA has expressed such targets as goals and aspirations but is failing to put actions behind its words and is on track to take until 2088 to get to net-zero.

While TVA has historically reduced emissions at a rapid pace, their forward-looking plans do not get them to net-zero carbon emissions until 2088. Source: Source: SACE’s fourth annual “Tracking Decarbonization in the Southeast” report; June 2022, page 19.

Information Gaps Left Out of the Presentation

There were some other topics that were completely left out of the presentation, which left significant information gaps for Memphians and decision-makers.

Household-level savings and benefits from switching supplies were not discussed

It’s one thing to talk about how $55 million in projected annual savings from switching to an alternative power supply did not meet people’s expectations after numerous reports showed the potential for $100 million+. But what was not discussed at the June 9 meeting is how far tens of millions of dollars in savings could go for actual families in Memphis. For example, if MLGW dedicated just 10% of the savings to bill-lowering weatherization/energy efficiency and demand-side management programs, that would be a $5 million+ annual budget. Such a budget could annually fund over 700 average-sized home weatherization retrofit projects per year, or about 14,000 homes over 20 years. These numbers would only scale up if a higher percentage of savings were allocated to such programs. For context, because of TVA’s lack of investment in weatherization programs, MLGW had to work for eight years–from 2013 to 2021–to complete 500 weatherization projects through the ‘Share the Pennies’ program. Despite MLGW’s work to keep energy rates low, Memphis area residents still suffer some of the most unaffordable energy bills of major cities across the country. Being able to help make energy bills affordable for thousands of Memphis households would be an immense public service that could be facilitated by an alternative power supply.

Important factors that could increase the relative savings of switching supplies compared to staying with TVA were not discussed

While GDS’ initial analysis of the portfolios already showed large savings from Memphis switching to new electricity suppliers, it appears that numerous factors in the presentation may have been left out of consideration that could substantially increase annual savings from $55 million to a higher figure. Below are a few key areas of information that GDS and MLGW must clarify and include in further analysis in order to have a thorough understanding of the possible costs and benefits of leaving TVA.

Comparing the savings of portfolios to MLGW’s current five-year TVA contract rather than the long-term contract.
MLGW is currently in a five-year rolling contract with TVA, meaning that MLGW would have to give five years’ notice to TVA before switching suppliers. MLGW can continue with this contract indefinitely rather than switching to TVA’s practically neverending 20-year contract. It appears that the long-term contract is a nonstarter with at least some leaders in Memphis. For example, at the presentation, Memphis City Councilman Martavius Jones said, “I am not in favor of the 20-year contract,” and asked if the analysis had been done to compare the potential savings of leaving TVA with the costs of staying under MLGW’s current five-year TVA contract. The answer was “no,” even though this type of comparison is precisely what MLGW’s IRP did in 2020. In the IRP, such a comparison of potential savings of leaving TVA with both the current MLGW-TVA five-year contract and the long-term contract showed that MLGW’s preferred alternative supply portfolios yielded 25-31% more annual levelized savings in comparison to the five-year contract than the long term contract:

• Portfolio 9 estimated annual savings: $153M against the five-year contract vs. $122M against the long-term contract
• Portfolio 6 estimated annual savings: $130M against the five-year contract vs. $99M against the long-term contract

Pending tax policy that could dramatically lower costs of solar, transmission, and battery storage, even for tax-exempt entities.
The U.S. House of Representatives passed legislation last November that would provide a 30% tax credit for the costs of solar energy installations, battery storage, and certain transmission infrastructure. Notably, the policy also made tax-exempt entities like Memphis eligible for the tax credit, when historically only private entities with enough tax liability could fully monetize the credits. This legislation has not yet passed the U.S. Senate, but news reports indicate that there is a significant likelihood that these policies may become law this summer or fall–perhaps before the MLGW Board would vote on whether or not to switch to alternative power suppliers. While some of the solar projects that bid into the RFP probably included some amount of existing tax credits to lower the delivered cost of energy to MLGW, they likely did not include the full 30% value that could be soon available, and the transmission projects in the RFP almost certainly did not include tax credits since that would be a brand new, previously unavailable credit. Overall, pending legislation on clean energy policy could lower the cost of an alternative power supply portfolio by hundreds of millions of dollars.

Energy efficiency and demand-side management could begin lowering Memphians’ costs immediately.
While MLGW will need to give TVA at least five years’ notice before taking power from other providers, Memphians could start to benefit immediately from investments in energy efficiency. Energy efficiency can pay for itself by lowering the amount MLGW has to pay TVA in the interim and reducing the need for purchasing power should MLGW leave TVA.

The effect of a partial resolution of the U.S. Department of Commerce solar investigation on the cost of solar.
It was mentioned in the presentation that one factor driving up the price of solar compared to when the IRP was undertaken in 2020 was the U.S. Department of Commerce’s investigation into solar tariff compliance. The investigation created a huge amount of uncertainty in the solar market over the past few months and temporarily drove up the cost of solar. President Biden partially resolved the issue at hand in early June 2022, enabling better market certainty for solar development. It is unclear if either the Commerce investigation or President Biden’s resolving action affected the RFP solar bids, but it will be important for MLGW to true up any costs in the final bids compared to cost assumptions during the initial evaluation.

Risk factors of staying with TVA

The presentation did a decent job of communicating that there are variables that could affect the overall price tag of MLGW choosing one path forward or another. This was covered in the presentation’s “Sensitivity Analysis” section. But shockingly, the sensitivity analysis did not discuss any factors that would increase MLGW’s risk by staying with TVA. Rather, it presented a one-sided picture that ignores important considerations by exclusively outlining scenarios in which alternative power supply portfolios would lose value for Memphis while failing to consider scenarios in which staying with TVA would lose value for Memphis. Below are a few of those considerations that must also be included in the risk analysis in order to portray a more complete view. 

Effect of fossil gas price on TVA.
The sensitivity analysis appeared to indicate that MLGW would be insulated from future higher-than-forecast gas prices were it to stay with TVA, but this would be inaccurate since the risk applies to TVA also. The vast majority of TVA’s gas procurement is non-hedged, meaning it is subject to the volatility of the fossil gas market. The risk of gas price on TVA is particularly pronounced since TVA is proposing to build a new large combined cycle gas plant at the Cumberland power plant which would increase TVA’s reliance on fossil gas from 29% of total annual energy (using 2020 annual load as an example) to 34% in 2026, which would actually be more reliance on gas than one of MLGW’s preferred alternative energy supply portfolios. TVA is also proposing to replace the Kingston coal plant with even another large combined cycle gas plant, which would further increase TVA’s reliance on fossil gas and expose MLGW’s customers to market volatility. 

Future TVA rate hikes.
MLGW’s integrated resource plan (IRP) estimated the costs of staying with TVA based on TVA’s 2019 IRP. Yet future cost drivers for TVA not accounted for in their IRP that is now apparent could include ratepayer obligations to pay for stranded assets, environmental compliance, and speculative nuclear construction, detailed below.  

TVA ratepayer obligations to pay for stranded assets.
One large potential driver of future TVA rate hikes is the risk of stranded assets that TVA is exposing ratepayers to in its large buildout of fossil gas generation facilities. TVA is currently proposing to invest billions of dollars to build 2,900 megawatts of fossil gas combined-cycle generation at the Cumberland and Kingston power plants, accompanied by 157 miles of new gas pipelines. However economic and regulatory trends may render much of this investment bad, well before the anticipated end of the projects’ lifespans. Higher-than-expected long-term gas prices, cost reductions in clean energy alternatives, and environmental policy may turn the gas plants into costly burdens. For example, a large and growing body of experts recommend that the United States reach a zero-carbon electricity system by 2035, a target that has been formally adopted by the Biden Administration. In such a scenario, the gas plants would run for less than ten years before needing to be retired, leaving TVA ratepayers to pay billions for unused, obsolete power infrastructure.

TVA ratepayer obligations to pay for environmental compliance and obligation costs.
The Memphis community is well aware that TVA has a major coal ash problem. As historically one of the largest coal plant operators in the country, TVA has tremendous amounts of toxic coal ash to clean up and safely dispose of. TVA CEO Jeff Lyash has characterized this task as, “dealing with 100 years of the deferred costs,” and it is expected to cost billions of dollars. 

Nuclear cost risks.
As last week’s presentation accurately stated, many power supply risks cannot be quantified. One of those concerning risks for MLGW should it stay a TVA customer is TVA’s dedication to pursuing speculative new nuclear power technology while ignoring cost-effective clean energy resources. TVA is investing in unproven small modular reactor technology as part of its stated long-term aspirations to reach net-zero carbon emissions, even while it gives short shrift to the lowest-cost clean energy technologies of energy efficiency, solar, and wind. The track record of nuclear construction in the twenty-first century shows that it has been spectacularly expensive and slow going: the price tag of the two nuclear power units under construction in Georgia has ballooned to $30 billion, which is $16 billion over budget and is six years behind schedule. In South Carolina, construction on two nuclear units was canceled after $9 billion was invested–without the benefit of receiving a single kilowatt-hour–a move to cut losses and avoid paying the rest of the estimated $25 billion total it would have taken to complete construction. The other nuclear construction in recent history is TVA’s completion of Watts Bar Unit 2, which was completed 37 years late and billions of dollars over budget. The new generation of nuclear reactors that TVA is interested in are smaller and less expensive, so the financial risks may not quite reach the same levels as past projects, but it is worth MLGW bearing in mind the industry’s current track record and whether or not it wants to hitch Memphians’ wallets to TVA’s nuclear aspirations for decades to come.

What Needs To Come Next

MLGW has been rigorous in its IRP and RFP processes yet there are still very important information gaps that exist in the RFP evaluation. The evaluation so far has verified that there are large savings available to Memphians by switching electricity supplies and that companies are ready and willing to make huge investments in Memphis and Shelby County. MLGW’s validation of their preferred alternative energy portfolios also verifies that Memphis and Shelby County could benefit from billions of dollars of investment, new job opportunities, and major progress toward environmental goals by switching electricity suppliers. Yet the presentation last week overlooked key elements that need to be considered before MLGW makes decisions one way or another. Incorporating these elements outlined above will help the community better understand the benefits and risks of moving to new electricity suppliers and staying with TVA.

SACE staff gathers in Memphis for the RFP presentation on June 9. Left to Right: Brady Watson, Dr. Stephen Smith, Maggie Shober, Pearl Eva Walker.

Memphis Has the Power is a campaign to ensure Memphians have affordable, equitable, and clean energy. The campaign has worked in the Memphis community for several years, backstopped by the Southern Alliance for Clean Energy (SACE). Our work has lifted up Memphians who struggle with unaffordable energy bills and has helped result in large increases in funding to help Memphians with lower incomes reduce their energy bills. SACE is an appointed member of MLGW’s Power Supply Advisory Team, the community advisory team that helped shape MLGW’s integrated resource plan.

Join the Campaign

The post Evaluation Shows Memphians Would Benefit from New Power Supply, More Information Will Reveal Benefits appeared first on SACE | Southern Alliance for Clean Energy.

Global greenhouse gas emissions must peak by 2025, experience rapid and deep reductions, and reach net zero by the early 2050s to limit warming to 1.5 degrees C  in order to avoid the worst impacts of the climate crisis. Many utilities and municipalities have acknowledged this dynamic, but the Southern Alliance for Clean Energy’s fourth annual “Tracking Decarbonization in the Southeast“ report highlights that current utility resource plans are not in line with this overarching target. Obstacles to getting utilities on track that are discussed in our report include: increasing reliance on fossil gas, underutilizing energy efficiency, and placing limitations on popular technologies such as rooftop solar. There’s still a lot of work to do before any Southeast utility is on track to decarbonize.

Why focus on decarbonizing the power sector specifically?

While emissions reduction opportunities exist in many different sectors, our report focuses on the decarbonization of the electric power sector of the Southeastern United States. Decarbonization is the transition of our power supply to sources that emit lower CO₂ emissions, usually with the goal of using zero-carbon resources to power all sectors. Utilities can decarbonize by replacing fossil fuels with energy efficiency and energy from renewable sources. Other sectors can use a decarbonization strategy called electrification, which means switching from direct fossil fuel use to charging with electricity instead. For example, transportation emissions can be lowered by replacing vehicles that run on gasoline and diesel fuel to electric vehicles (EVs).

Decarbonizing the electric power sector holds great significance for utilities in the Southeast, as more consumers, businesses, and local governments are beginning to electrify. Power sector emissions have sharply fallen from their peak in 2007, to the point where the transportation sector is now the largest source of CO₂ in the Southeast – a trend across most states and regions in the U.S. The fact that transportation has eclipsed the power sector does not diminish the importance of decarbonizing the power supply – it actually underscores it. When EVs are plugged in to charge, drivers are using utility-generated power for their transportation needs. Therefore, the cleaner the electricity, the cleaner the EV. In fact, decarbonization of the power sector is a critical tool to reduce emissions in all sectors through electrification.

Source: SACE’s fourth annual “Tracking Decarbonization in the Southeast” report; June 2022, page 5.

How do we track decarbonization and why are we doing it?

The Southeast is home to some of the largest utility systems in the nation, many of which have been in the national spotlight for their professed commitment to decarbonization. Duke Energy, Southern Company, Dominion, NextEra Energy, and the Tennessee Valley Authority (TVA) have all established decarbonization goals. Of these, the two largest CO₂ emitters, Duke and Southern, have both made pledges to reach net-zero emissions by 2050, while NextEra recently set a target to get to zero without any carbon offsets by 2045. TVA has announced a series of coal retirements as part of its plan to reduce emissions 70% from 2005 levels by 2030 on the path to 80% by 2035 while saying it has an ‘aspiration’ to get to net-zero by 2050.

However, there are often inconsistencies between stated goals and resource plans. So how do we track the progress of these attempts? We look at the emissions associated with what utilities are planning to do, not just what goal they have set. Let’s start with the generation mix, or the mix of resources utilities use to meet generation needs. The mix of resources that utilities use for power is more critical than ever, especially when plans show that utilities are planning to continue heavy fossil fuel use in the future.

Source: SACE’s fourth annual “Tracking Decarbonization in the Southeast” report; June 2022, page 6.

Current utility plans show that goals to decarbonize will be hindered by rising fossil gas consumption. Fossil gas plants are already fueling nearly half of the region’s total electric generation today, yet utilities plan to still increase reliance on gas generation in the coming years. Even utilities with zero-carbon goals such as Duke, Southern Company, and TVA are continuing to pursue fossil gas. This is troubling because utilities that are looking to decarbonize should not be making more long-term investments in fossil fuels that emit carbon. This is also troubling because the goal of decarbonization should be to switch to zero-carbon resources. When consumed, different fuels emit different amounts of carbon for each megawatt-hour (MWh) of electricity produced. This is known as carbon intensity, and it’s generally expressed in lbs of CO2/MWh. The carbon intensity of fossil gas plants is approximately half of coal plants, so during the past decade, utilities have generally switched from coal to gas. But even a utility or resource with a ‘lower’ carbon intensity can still contribute significantly when they are providing a large amount of electricity to a lot of customers, so it is important to look at who is contributing to total emissions.

Source: SACE’s fourth annual “Tracking Decarbonization in the Southeast” report; June 2022, page 7.

Since complete decarbonization is needed to avoid the worst impacts of the climate crisis, it is important to also look at total emissions reductions. While the per megawatt-hour emissions intensity can be useful for quickly comparing fuel types or utilities against one another, it doesn’t necessarily tell us anything about how close a utility is to reaching zero. We see that a noticeable drop in 2020 due to the pandemic is still only a drop in the bucket when compared to the path to zero. Looking at how quickly absolute emissions reductions occur over longer timeframes gives us a window into just how long it will take to reach zero emissions based on the resource plans utilities have submitted to regulators.

Source: SACE’s fourth annual “Tracking Decarbonization in the Southeast” report; June 2022, page 8.

Most utilities were reducing carbon at a higher rate in the last decade than they plan to do in the coming decade. This is because most emission reductions from 2010-2020 were the result of flat or declining utility load paired with retiring coal generation and replacing it with fossil gas. Fossil gas is now the dominant fuel in the region, with many utilities still planning to add new gas infrastructure in the future. As a result, planned future reductions are occurring much slower than in the past decade and at a rate that would miss even the latest decarbonization “deadline” by several decades. For utilities to decarbonize at the pace seen in the 2010s they will have to retire remaining coal plants at a steady pace and replace fossil gas with clean, zero-carbon energy sources like wind, solar, storage, and energy efficiency.

What Utilities Say vs. What They Do

There’s a growing consensus from customers, investors, and regulators: everyone wants utilities to provide a carbon-free power supply. Utilities have begun catering to this want by publicizing emissions reductions and in some cases announcing decarbonization goals with various stylings (net-zero, low to no carbon, carbon-free). However, scientists have been clear that decarbonizing isn’t really a want, it’s a need. And it’s becoming increasingly clear that utilities’ actions are not meeting this need.

Source: SACE’s fourth annual “Tracking Decarbonization in the Southeast” report; June 2022, page 12.

While many electric utilities are eager to make it known they’ve reduced emissions in the past, fewer have announced a goal that takes scientific guidance into consideration. Notably, TVA tends to tout its emission reductions over the last 10-15 years without laying concrete plans to continue to reduce emissions at that same rate. Only one utility, Duke’s two subsidiaries in the Carolinas, has taken the step to include its net-zero decarbonization goal in its Integrated Resource Planning (IRP), or long-term energy resource, planning process (though even that can fall short in some areas) and based on current resource plans, none are on track to decarbonize by 2035, 2040, or even 2050. When announcing its goal to achieve zero emissions by 2045, NextEra laid out a set of interim targets and high-level generation mixes for its regulated utility FPL. This is a step in the right direction, and we look forward to working with FPL and Florida regulators on the details for achieving this goal in an equitable manner, such as through the inclusion of energy efficiency.

What’s at stake? What next?

As we’ve said in the past, every year matters, and every choice matters when it comes to acting on climate change. Delaying further decarbonization until the next year, or the next IRP cycle or the next decade is too risky for residents of a region expected to feel the impacts of climate change first and worst. The Southeast is home to many frontline communities that are already being negatively affected by fossil fuels and the climate crisis. Stronger and more frequent extreme weather events, coastal flooding, poor air quality, and unpredictable energy prices are likely to continue to harm our communities.

Although it is difficult to fully represent the relationship between delayed climate action and all impacts, it is possible to look at the increased cost of failing to act. Namely, that weather disaster are expected to become more frequent and intense due to climate change. In the last five years, the U.S. has averaged at least $148.4 billion dollars worth of weather and climate damage each year. But likely more, as NOAA mainly catalogs climate and weather disasters that cost one billion or more dollars. Smaller disasters, and costs associated with resulting health care needs from these events, are not included. If that $148.4 billion is spread out evenly across the year, that means the cost of inaction would increase by $4,706 every second. To see what that looks like, a cost of inaction tracker shows why climate action can’t wait.

With so much at stake, what is the region to do? Although SACE primarily intervenes in state-level utility regulation and contends that utility resource planning is one of the best opportunities to put decarbonization goals into practice, we can still see that action is not happening fast enough. Engaging on multiple levels, including federally is necessary for concerned citizens.

Take Action: Urge Your Members of Congress to Take Climate Action

The post Tracking Decarbonization in the Southeast: 2022 Annual Update appeared first on SACE | Southern Alliance for Clean Energy.

“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 (bryan@cleanenergy.org) or Will Collier (wcollier@southface.org) for more information, and if you’d like to learn more about Georgia Power’s 2022 IRP, read our other blog posts:

• Georgia’s Energy Future Is Being Planned at the PSC
• Unboxing Georgia Power’s 2022 Integrated Resource Plan
• Georgia Power Has Failed to Achieve (or Pursue) Higher Efficiency Savings
• Georgia Residents Continue Speaking Up about the IRP

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.

Endnotes:

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:https://eta-publications.lbl.gov/sites/default/files/lbnl-1007060.pdf.
3. See, for example, https://www.cpr.org/2021/03/11/colorado-utilities-massive-natural-gas-costs-february-
   cold-snap/.

The post Georgia Power’s 2022 Integrated Resource Plan in the Home Stretch: Yet Key Issues Remain  appeared first on SACE | Southern Alliance for Clean Energy.

On June 1, more than a dozen Kingston coal ash workers and their families showed up at the Tennessee Supreme Court in Nashville. With them was an incredible showing of faith, labor and environmental justice advocates, many of whom had traveled from across the state after participating in solidarity events in advance of the hearing.

The group gathered in the lobby for a prayer led by the Rev. Gordon Myers of Memphis. There in spirit were many other workers’ families who were too sick or otherwise unable to attend. Together, they filled every seat of the Tennessee Supreme Courtroom.

Family, friends, and advocates stand in solidarity with Kingston Coal Ash workers at the Tennessee Supreme Court on June 1.

They were there to watch attorneys argue over an appeal that threatens the workers’ ability to seek financial claims for the injuries they sustained while cleaning up toxic coal ash near the Kingston Fossil Plant.

Workers allege that during the six-year cleanup of the Kingston spill, supervisors told them they could eat a pound of coal ash a day without harm. Supervisors even destroyed respirators and masks that their employees brought to the work site. Since the Kingston coal ash spill in 2008, which was the largest industrial disaster in US history, nearly 60 workers have died and hundreds more are sick.

Support the workers! Sign the workers’ petition demanding that TVA provide the healthcare coverage it promised!

On one side of the courtroom was counsel for Jacobs Engineering, the contractor hired by the Tennessee Valley Authority to lead the years-long cleanup that involved more than 900 workers. Jacobs has already been found guilty by a federal court of failure to exercise reasonable care in keeping the workers safe.

This hearing dealt with one of the contractor’s recent appeals — Jacobs’ claim that the Kingston workers should have to prove silica-specific injuries like pulmonary fibrosis in order to seek damages because of a state law called the Tennessee Silica Claims Priorities Act.

The workers’ counsel argued that because their clients were seeking claims for injuries caused by other harmful coal-ash constituents such as mercury, arsenic and lead, the TSCPA should not apply. Though the five Supreme Court justices asked discerning questions during the hearing, a ruling is not expected for weeks or even months.

Waiting is something the workers and their community allies have become accustomed to, but never has it been done idly.

In December 2018, the 10th anniversary of the Kingston Coal Ash Spill and one month after Jacobs had been found guilty by a federal court, TVA placed an ad in the Roane County News describing events after Kingston as a “Legacy of Promises Kept” and included contractors in their thanks for the work on the cleanup.

At that time, the workers and their families had endured years of doctors appointments and bills, court dates and pending attorneys’ fees. Since then, they have suffered unimaginable losses of loved ones in their journey for justice and accountability for their mistreatment during the clean up.

While juggling these enormous challenges, families and advocates have organized memorial events, healthcare funds, rallies and newspaper ads in honor of the workers, and have demanded that TVA provide the healthcare coverage it promised to the workers back in 2009.

Looking back, some folks say that the reason the workers weren’t protected after Kingston was because of a financial calculation that determined the workers and their families were expendable, that someone, or some people, decided that providing workers with full protective equipment would incite fear and lawsuits from the public, and that worker safety wasn’t worth that cost.

The Kingston disaster was one of the largest environmental catastrophes in US history.

Today, coal ash workers and communities in Tennessee know that our collective safety won’t happen without solidarity and looking out for each other. We want coal ash communities in other states to know that the same is true for them.

Leaky coal ash storage ponds and landfills impact thousands of communities across the country.

Along Lake Michigan, locals are concerned that if Northern Indiana Public Service Company moves forward with its plan to leave its coal ash in place, a leaking seawall could rupture and release 2 million tons of coal ash into the lake and a nearby creek.

In Tennessee, local communities who rescued the Memphis Sand Aquifer from TVA’s leaking coal ash at the Allen Fossil Plant are now fighting a backroom decision to truck that ash through an environmental justice community to a nearby landfill.

Coal plants across the country are closing, and a huge component of that transition is deciding how to permanently store coal ash and what steps will be taken to protect workers and communities as the toxic ash is excavated and moved out of water tables and flood zones to drier locations.

If the Tennessee Supreme Court rules in favor of Jacobs, none of the Kingston workers involved in the lawsuit will be compensated for their years of medical bills, funeral costs and suffering.

Such a ruling could embolden companies across the country to neglect coal ash worker safety, and would also set a negative precedent for future coal ash injury cases among workers and community members in Tennessee. So much hinges on this ruling for the workers — the awaited outcome can’t be taken lightly.

Still, as advocates, friends and loved ones, we won’t give up on justice for the first responders at Kingston.

Take Action

Please share this article with the hashtag #RememberKingston, and demand justice for the Kingston coal ash workers.

Sign the Petition

Organizations and community members from across Tennessee stood in solidarity with the Kingston Coal Ash Workers and their families during a state supreme Court Hearing on June 1st. Educator, activist and organizer Fran Ansley (narrator) made a powerful opening statement at a solidarity action held for the Workers in Knoxville on May 31st. Video by Robert Winslow with Southern Dialogues.

The post We Won’t Give Up on Justice for the Kingston Coal Ash Workers appeared first on SACE | Southern Alliance for Clean Energy.

Highlights for the FPL System

The goal is focused on the following plan:

• FPL plans to be 36% decarbonized by 2025 (using a 2005 emission baseline), 52% by 2030, 62% by 2035 and 83% by 2040, culminating in 100% decarbonization by no later than 2045. It plans to reach these interim targets through modernization of its generation fleet, which will consist of a mix of solar, battery storage, existing nuclear, green hydrogen, and other renewable sources.
• By 2045, FPL would significantly expand its solar capacity, increasing the amount of solar generation on FPL’s system from approximately 4,000 MW today to more than 90,000 MW.
• FPL’s plan is to add more than 50,000 MW of battery storage to its grid, up from 500 MW today.
• FPL would convert 16,000 MW of existing fossil gas units to run on green hydrogen. FPL states that the conversion of these units to green hydrogen is expected to be “cost-effective” for customers. By 2045 FPL’s plan includes 30 GW of excess solar, which it would use to produce approximately 500 million kilograms of green hydrogen through electrolysis. 
• FPL will plan to generate up to 6,000 MW of carbon-neutral power with renewable natural gas, which would is equivalent to 2.4% of the volume of fossil gas presently used in FPL plants.
• There are references in the plan about the need for a constructive regulatory environment and approval by regulators, acknowledging that these investments will have to be found reasonable and prudent by the Florida Public Service Commission.

Source: NextEraEnergy Investor Conference, June 2022, slide 69

In response to the NextEra decarbonization goal announcement, Southern Alliance for Clean Energy Executive Director Dr. Stephen A. Smith said, “We are pleased to see NextEra and FPL set an ambitious carbon target with significant investment in additional solar power. We continue to believe that solar power is a workhorse technology in reducing carbon emissions, and FPL’s goal advances this commitment. We will continue to study and watch the development of “green hydrogen” technology, this is clearly a work in progress technology. Noticeably missing from these goals is a commitment to more energy efficiency to help customers reduce their power consumption while saving money. Additionally, we hope FPL will abandon their attacks on customer owned solar systems as all forms of clean energy will be needed to meet these goals.”

Green hydrogen component of the plan – is it ready for primetime?

NextEra defines green hydrogen as hydrogen produced by using zero-emission electricity to run an electrolyzer, which splits water molecules (H2O) into hydrogen and oxygen. FPL’s plan appears to rely heavily on green hydrogen as an element to achieve its decarbonization goal. The NextEra Investor Presentation appears to forecast approximately 7% of FPL’s total generation coming from green hydrogen in 2031. Its important to note that the ratio of emission reductions from blending hydrogen into gas is not one-to-one, as shown by a demonstration project by Georgia Power that fueled a power plant with 20% hydrogen and 80% fossil gas for a 7% reduction in carbon emissions compared to running the plant on 100% fossil gas. So it is unclear how FPL is calculating its decarbonized energy, and whether it plans to replace 7% of its gas use with hydrogen or 20% by 2031.

Source: Florida Power & Light filing at the Florida Public Service Commission, March 12, 2021, Exhibit MV-8

FPL has a demonstration project of its own already under construction. As part of last year’s rate case settlement agreement, FPL received approval from the Florida Public Service Commission (PSC) to invest $65 million in a green hydrogen pilot project to be in service in 2023. The project will utilize a 25 MW electrolyzer powered by solar-generated electricity to convert water to hydrogen at its Okeechobee power plant. The hydrogen will be blended, up to 5%, with fossil gas to run a combustion turbine. FPL stated last year that the “project is a first step in learning about how hydrogen technology can benefit customers and potentially help unlock a day when electricity is 100% carbon-free.” While SACE is supportive of technologies that can pave a path to a clean energy future, it begs the question, if FPL is currently constructing an electrolyzer to test green hydrogen as a fuel source, how can it place so much reliance on a resource for which it has yet to gain important operational and cost information?

FPL plans to transition away from its reliance on fossil gas to generate electricity, almost 70% now, to generate 83% of its power from solar, battery storage, and green hydrogen in 24 years. Its nuclear power generation remains fairly steady through this time period. It is too early to tell whether hydrogen will be a viable fuel source for electricity generation, especially because it is likely to be a key resource in decarbonizing hard-to-reach sectors like steel, chemical, and cement production. While FPL doesn’t specify the proportion of solar, it’s clear that the workhorse for this transition will be solar power.

Solar – the workhorse technology of the plan

The plan calls for a massive increase in solar capacity – well above the Company’s current rate of solar additions. FPL has approximately 4,000 MW of utility-scale, utility-owned solar on its system today. Prior to the announcement, FPL was projecting approximately 11,000 MW of solar on its system in 2031. The “Real Zero” goal calls for 90,000 MW (90 GW) of solar by 2045. Assuming it was to begin constructing solar installations next year at the rate to reach 90 GW by 2045, it would entail bringing 3.7 GW of solar online every year until 2045. There is no precedent for this rate of utility-owned solar development.

It appears that while much of the solar power will be fed directly to the grid, a considerable amount will also be used to charge battery storage and produce green hydrogen. In fact, FPL states, in its investor conference presentation, that about “30 GW of excess solar and electrolyzer capacity will produce approximately 500 MM kg of green hydrogen.“

What’s missing? 

The “Real Zero” goal misses some very real cost-effective policies in decarbonizing FPL’s system: scaling up energy savings from utility-sponsored energy efficiency programs and rooftop solar development.  It is well established that the cheapest kWh is the one that is never used. Yet FPL’s energy savings achievements pale in comparison to other Florida, regional, and national utilities. By not investing in helping customers reduce energy use, the Company is missing out on both the economic benefits to its system and helping families make their homes more efficient, safe, and secure. FPL should leverage that opportunity by scaling up its energy efficiency goals and programs for families and businesses.

Another distributed energy resource that is underutilized on FPL’s system is customer-owned rooftop solar. Rooftop solar generation by FPL customers represents less than one percent of the total generation produced by FPL’s entire system: an adoption rate much lower than many other utility service territories in Florida and beyond. The Company should view customer rooftop solar as a resource in reaching decarbonization goals. Yet, FPL set out last year to cripple the cornerstone policy for rooftop solar adoption, net metering. It should reverse course on its predatory posture toward rooftop solar. After all, all sizes and ownership models of solar development will be needed to meet the climate challenge.

Stay tuned

FPL does not provide details on how it will present the elements of this plan to state regulators. As always, we will keep you updated on this important development. We look forward to learning more about the details of the plan and tracking elements as they unfold.

Unfortunately, FPL leadership has not always been a reliable utility partner to work with in the past. While this proposal appears to be a bold and ambitious program to address carbon emissions, we will have to wait and see if FPL leadership will work constructively with stakeholders to lay a cost-effective path to a clean energy future.

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Congresswoman Kathy Castor and U.S. Secretary of Energy Jennifer Granholm

Working Well: Education, Infrastructure and Good Policy

The Clean Cities Coalition presentation by Alex Kolpakov and Austin Sipiora spotlighted SACE’s Driving on Sunshine Program – I was able to further describe the program and how we work to educate decision-makers from the state to the local level on how electric transportation brings cost, public health, environmental, and economic development benefits to their communities, all while they are driving an EV.

USF Transportation Day

Another topic of discussion was the adoption of EV-ready ordinances by over a dozen local municipalities across the state. These ordinances are one of the specific strategies identified by the Florida Department of Transportation in the EV Infrastructure Master Plan as a means for increasing infrastructure. The perennial concern of preemption by state lawmakers was raised as a threat to these proactive steps.

Laura Thomas, Sustainability Program Administrator with the city of Largo explained how their recently adopted EV-ready policy will increase EV charging infrastructure available in the community redevelopment area in a more ubiquitous and accessible way.

When Secretary Grandholm asked about state incentives for the purchase of EVs (or infrastructure) it was noted that while Florida lacks incentives, unlike many other Southeastern states the Sunshine State does have a direct sales and service provision, which makes it easier for consumers to purchase EVs directly from manufacturers.

Opportunities Going Forward: Additional Sound Policy, Renewables, Skilled Labor

The conversation then turned to supporting future actions and policies needed to reach carbon emission reduction goals. To help stretch federal dollars that stem from the Bipartisan Infrastructure Bill, Florida could allow utilities to offer cost recovery programs for customers who install EV infrastructure. Programs like Duke Carolinas’ Make-Ready Rebate Program allow site hosts to recuperate costs for installing on their side of the meter.

Representative Castor also noted the opportunity for Florida to live up to its moniker the’ Sunshine State’ by vastly increasing solar adoption, and pairing that with storage for charging equipment. Other opportunities discussed include the increased need for skilled electricians to install charging equipment and the need for a just transition for our labor force.

Preparation Needed Now for Upcoming Opportunities

In sum, the discussion was an exercise in listening and learning. More opportunities than ever before for electric transportation will stem from the influx of federal Bipartisan Infrastructure Law funding. Meeting these opportunities with preparation will be key if we hope for funding to flow efficiently, equitably, and efficiently. The critical need for maintaining ongoing dialogue and building trusted relationships between the various agencies, municipalities, school districts, service providers, utilities, workforce groups, non-profits, and the federal government is essential. SACE will continue to fill this supportive role and identify new ways to encourage an all-hands-on-deck approach.

Electrify the South​ is a Southern Alliance for Clean Energy program that leverages research, advocacy, and outreach to promote renewable energy and accelerate ​the ​equitable ​transition to ​electric transportation throughout the Southeast. Visit ElectrifytheSouth.org to learn more and connect with us.

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