February 28th, 2026

To: Wilson Mallard, Georgia Power Company
Cc: Georgia Public Service Commission

Re: Urgent Needs for Georgia Power’s Behind-the-Meter (BTM) Solar Policies

Mr. Mallard,

On behalf of Georgia’s solar contractors, electrical firms, engineers, and the thousands of

Georgians employed in the clean-energy construction sector, we are writing to share a set of

recurring and systemic challenges our members are experiencing with Georgia Power’s

behind-the-meter (BTM) interconnection policies and practices. These issues are materially

affecting project timelines, customer decisions, and workforce planning across the state.

Our intent in sending this letter directly to Georgia Power is to provide an opportunity for

discussion, clarification, and corrective action where appropriate. We are copying the Georgia

Public Service Commission to ensure transparency and to reflect the statewide significance of

these concerns.

Georgia currently trails its peer states in customer-sited solar adoption despite having some of

the strongest economic potential in the Southeast. Georgia Power’s interconnection process

remains a major driver of delays, increased project costs, redesigns, and administrative burden.

These requirements add multiple months to project timelines, disrupt construction schedules,

and create uncertainty that contractors and customers cannot plan around.

At the same time, Georgia Power’s demand-charge ratchet practices have become a significant

barrier to the deployment of behind-the-meter solar paired with energy storage for large

commercial and institutional customers. Schools, manufacturers, churches, and

property-portfolio owners frequently decline to move forward with otherwise viable projects

because a single 15-minute demand event can determine demand charges for an entire year,

making bill savings unpredictable and exposing customers to disproportionate downside risk.

At a time when Georgia Power is projecting unprecedented load growth and has requested

roughly 10 GW of additional generation to meet rising demand, each abandoned

behind-the-meter solar-plus-storage project reduces the amount of local, customer-funded

capacity that could otherwise help meet the grid needs Georgia Power itself has identified.

The challenges outlined below are structural, not anecdotal, and are shared nearly universally

among behind-the-meter contractors operating in Georgia. Each issue includes a practical,

implementation-ready solution.

1. Unjustified Denial of Solar on Delta Services

Georgia Power has recently begun denying all behind-the-meter DER applications for

customers served by transformer banks with a delta configuration on the secondary side.

Georgia Power has indicated that this requirement is based on concerns associated with

open-delta conditions following a primary phase loss.

Open-delta operation is an inherent characteristic of delta transformer banks and exists

regardless of whether distributed generation is present. During such a contingency, transformer

capacity is reduced (to approximately 58%) and the affected primary conductor will remain

energized due to transformer coupling. That condition arises from the topology of the delta bank

itself, not from the presence of solar generation.

While an exporting DER can contribute current during an open-phase condition, that

contribution is negligible. It does not create the contingency and does not fundamentally alter

the nature of the underlying transformer condition. Further, any potential contribution from a

DER can be addressed through export limitations or non-export configurations rather than

categorical transformer replacement.

Impact:

• Customers with existing delta service—common in small commercial and light industrial buildings such as churches and rural businesses—are prevented from installing solar unless they fund transformer replacement.
  
  
• Customers must pay to replace utility-owned equipment or abandon projects entirely.
  
  
• Many viable projects have already been canceled due to added cost and uncertainty.

• Older commercial properties and rural facilities are disproportionately affected.

Requested Solution:
Georgia Power shall immediately rescind the blanket prohibition on solar interconnections behind delta transformer banks. Interconnections should be evaluated according to established national standards (UL 1741, IEEE 1547) and Georgia Power’s own historic technical practices. If Georgia Power believes a specific installation presents a legitimate engineering concern, it should provide written, technically defensible justification rather than relying on unsupported categorical bans.

2. Lengthy, Inconsistent, and Opaque Interconnection Application Process

Georgia Power’s behind-the-meter interconnection application process often requires weeks to

months to fully complete, preventing contractors from beginning on-site work, allocating

staffing, or coordinating effectively with construction schedules. While completed applications

may be reviewed quickly, the path to reaching a complete and accepted application has become

progressively longer and more difficult over the past decade.

The process itself is frequently inconsistent and subject to change. Commercial systems, in

particular, have at times remained with Georgia Power’s internal legal review team for months

without explanation or clear feedback, leaving customers and contractors unable to move

forward. In recent years, GPC has increasingly demanded impact studies without explanation

for very small commercial, and even residential, systems. Projects can sit in this status for 60

days or longer  without explanation.

The administrative burden has been further exacerbated by the recent requirement for all

battery storage systems to submit a supplemental DB18-23 form. This 15-page document

largely duplicates technical data already captured within the PowerClerk application. This

redundant step adds hours of unnecessary paperwork for installers and confusion for

customers, without providing any additional safety or grid-reliability data that isn't already on file.

Georgia Power generally requires permanent utility power and an active customer account

before reviewing a residential solar interconnection application. As a result, solar work is often

delayed until late in the construction timeline, forcing contractors to return to completed

buildings, increasing costs, and discouraging builders from incorporating solar altogether.

From an installer’s perspective, an application is considered “smooth” when it requires

approximately five hours of administrative work to complete. Applications that do not proceed

smoothly can require multiple days of staff time, repeated revisions, and extensive

back-and-forth communication to navigate evolving requirements and unclear expectations. This

causes frustration and confusion for installers and customers, increases soft costs, and

disproportionately impacts solar projects on new construction sites where timelines are critical.

Impact:

• Contractors are unable to reliably plan staffing, construction schedules, or capital deployment
  
  
• Many projects experience extended delays with no clear explanation or timeline
  
  
• Soft costs increase significantly and customers experience confusion and uncertainty regarding project feasibility and timing
  
  

Requested Solution:
Georgia Power shall improve transparency and predictability in the interconnection application process by:

• Publishing and maintaining a clear, stable, and streamlined application process that eliminates redundant paperwork and provides a predictable timeline for approval.
  
  
• Providing written explanations and firm timelines when applications are delayed for legal, engineering, or impact-study review
  
  
• Establishing a pre-application review pathway (for all customer classes, including residential) using basic project information (project address, system size, etc), with feedback provided within two weeks.  If no issues are identified then the project shall be permitted to proceed with installation ahead of the rest of the process, however the application must be satisfactorily completed by both parties before the system may be energized.
  
  
• Reviewing interconnection applications for buildings that are in the construction phase prior to permanent power being established and before a Georgia Power account is active.

3. Demand-Charge Ratchet Practices That Discourage Behind-the-Meter Storage

Georgia Power’s 12-month demand-charge ratchet makes ESS-based peak shaving economically risky by allowing a single 15-minute event to determine demand charges for an entire year, discouraging customers from deploying storage even when it would otherwise reduce peak load.

Impact:

• Customers face disproportionate financial exposure from short-duration events, such as brief ESS outages, maintenance periods, or abnormal operating conditions
  
  
• A single 15-minute peak can lock customers into elevated demand charges for 12 months, even when storage systems perform as intended for the remainder of the year
  
  
• Commercial and industrial customers decline to deploy ESS due to asymmetric downside risk that cannot be reasonably mitigated, limiting peak-load reduction, grid resiliency, and customer-funded capacity benefits.
  
  

Requested Solution:
Georgia Power shall modify its demand-charge ratchet structure for customers deploying behind-the-meter energy storage by:

• Basing demand charges on the highest 15-minute demand measured over a rolling 30-day period, rather than a 12-month lookback; or
  
  
• Providing an ESS-specific demand-charge option that limits the ratchet duration to reflect the operational realities of battery systems; or
  
  
• Allowing customers with verified ESS peak-shaving controls to exclude isolated abnormal events from ratchet calculations

4. Unnecessary Equipment and Infrastructure Costs

Georgia Power sizes its distribution transformers using load diversity and acceptable overload factors to safely serve customer consumption, knowing customers will not use their full service capacity all at once. However, when customer generation is introduced, Georgia Power applies a materially more conservative standard by modeling solar interconnections based on theoretical maximum continuous export rather than realistic operating conditions. This inconsistent application of engineering assumptions forces solar customers to pay for unnecessary transformer upgrades.

Another example is Georgia Power’s refusal to allow meter collars, which are allowed by many other utility companies and save the customer thousands of dollars by utilizing existing infrastructure in their home to connect the DER more easily.

Impact:

• Customers face unnecessary, unexpected charges that can kill projects
  
  
• Unequal treatment between solar and non-solar customers
  
  
• The prohibition of certified meter collar adapters forces invasive, high-cost electrical work for automatic transfer functions that could be handled by simpler, manufacturer-certified hardware.

Requested Solution:
Georgia Power shall evaluate transformer adequacy using the same load-diversity and operating assumptions applied to customer consumption, rather than assuming continuous full-capacity export. Where legitimate transformer constraints exist, customers shall be permitted to avoid upgrades through verified export-limiting controls rather than being required to fund full transformer replacement.

Behind-the-meter energy storage systems (ESS) configured for non-export operation shall not be included in the AC capacity used for transformer upgrade determinations, as such systems do not export power to the grid.

Furthermore, Georgia Power should permit the use of UL-listed meter collar adapters from reputable manufacturers. These devices provide a safe, standardized, and cost-effective method for implementing automatic transfer functions, reducing the need for the expensive service-entrance modifications currently required by GPC policy.

5. Excessive and Redundant Witness Test Requirements

Georgia Power requires costly and disruptive witness tests even though the inverters are UL1741 SA-SB / IEEE1547-certified. For systems over 250 kW-AC, GPC requires up to a 4-hour customer power shutdown and charges $3,900–$4,400 per test. If the system does not reach 85% of its AC rating due to weather conditions or a narrow DC to AC ratio (sometimes that’s the customer preference and legal right), the customer must pay again and again for the test until it passes GPC’s highly restrictive parameters. The nationally recognized UL and IEEE standards exist to certify safety and grid-interconnection compliance, therefore, requiring a witness test is operationally redundant. 

Impact:

• This unnecessary power outage causes large facilities to have to schedule a shutdown
  
  
• Commercial and industrial customers abandon or downsize projects
  
  
• Lost economic development opportunities for Georgia businesses
  
  
• Contractor scheduling disruptions and increased project risk
  
  

Requested Solution:
GPC shall eliminate witness tests for systems with grid-interactive inverters that are third-party certified for UL1741SA/SB and IEEE1547 compliance. Alternatively, allow an expedited witness test for all systems, including those that are 250kW-AC and over.

Conclusion

Georgia’s behind-the-meter solar workforce—comprising electricians, engineers, project managers, skilled laborers, equipment distributors, and support staff—stands ready to deliver thousands of additional jobs and hundreds of millions in local investment annually. But some of Georgia Power’s policies suppress this growth.

Every issue listed above has a clear, implementable solution that preserves safety, grid reliability, and customer protection while restoring fairness and economic opportunity.

We respectfully request the opportunity to discuss these issues with Georgia Power staff and leadership, including potential near-term process improvements and longer-term policy adjustments. Our members are eager to work collaboratively to reduce friction, improve predictability, and enable behind-the-meter solar and storage to support Georgia Power’s reliability and capacity objectives.

Georgia’s solar industry is ready to work collaboratively with the Commission and Georgia Power to ensure the state remains competitive, innovative, and economically vibrant. To be clear, we are not asking for new incentives, taxes, or ratepayer money; we are simply asking for the removal of the artificial and unnecessary technical and administrative barriers that currently stifle private investment and customer choice.

Respectfully submitted,
Georgia Solar Energy Association Policy Committee

C.C.: Georgia Public Service Commission

The Following Georgia Solar Installers Stand in Support of These Recommendations:

1. Alternative Energy Southeast
2. Better Tomorrow Solar
3. Sun Path Solar
4. Southern View Energy
5. Zero Grid Power Solutions
6. Creative Solar USA, LLC
7. Hannah Solar
8. Solar Sun World, LLC
9. Colite Technologies
10. Sun Harvesters, Inc.
11. Solar Crowdsource