Dominion to offer community solar, minus the community and the solar

The Emperor's New Clothes. By Vilhelm Pedersen (1820 - 1859) [Public domain], via Wikimedia Commons

The Emperor’s New Clothes. By Vilhelm Pedersen (1820 – 1859) [Public domain], via Wikimedia Commons

In the children’s story The Emperor’s New Clothes, a couple of shysters convince an insecure monarch to fork over gold in exchange for what they assure him are the most beautiful clothes ever made—clothes with the remarkable quality of being invisible to stupid people. Too embarrassed to admit he can’t see the clothes, the emperor allows the fraud to proceed. Public humiliation ensues.

Perhaps the fairy tale inspired Dominion Virginia Power’s new scheme to extract money from customers who want to buy solar power, without actually selling them solar power. The solar hopefuls are to be bilked of extra payments on their utility bills by the promise of having their drab fossil electricity turned into golden sunlight-powered electrons.

As in the children’s story, the customers will be fooled into thinking they have bought something special. Instead, they will have bought invisible clothes.

The program is called “Dominion Community Solar” (or Rider DCS), though it has nothing to do with true community solar.

Publicly, Dominion has described it this way: Dominion will build a 2-megawatt (MW) solar facility and put the electricity it produces onto the grid. Customers can buy it by paying an extra 4 cents per kWh (in $4 blocks) on top of the regular retail rate of about 11 cents.

If this were an accurate description, the program would be a valid offering. In fact, I might have gone for it myself. As someone with a shaded roof, it would be the only way for me to buy solar, given Virginia’s backward policies. And buying solar matters to me because I want to be part of the solution to the climate disruption caused by our burning of fossil fuels.

But it seems to be an article of faith among utility executives that people’s intelligence is inversely related to their desire to do good in the world. If we’re dumb enough to pay extra for solar electricity, they figure, maybe we’re dumb enough to pay extra for what we’re persuaded to think is solar electricity, even if the premium really buys us nothing at all.

This program presents the chance to test their theory. As the filings in the SCC case reveal, Dominion will not actually sell solar energy to participants. (See SCC Case PUE-2015-00005.) It will use their “contributions” to “offset” the costs of its Solar Partnership Program, which will enable it to build an extra 2 MW of solar capacity and put that electricity onto the grid. Then it will sell the renewable energy certificates (RECs) associated with that electricity to someone else—not to the people who are funding the facility.

The result is that although Dominion will bill the do-gooders extra to build a solar facility, it won’t deliver solar energy to them. The altruists will pay 15 cents/kWh for the same drab fossil fuel electricity everyone else buys for 11 cents/kWh.

Imagine Exxon soliciting motorists to pay an extra dollar per gallon for gas so the company can build a biofuel facility to sell renewable fuel to other customers. If you would contribute to such a scheme, please email me, as I have some other great offers for you.

The most remarkable thing about Dominion’s plan is not its cynicism, but the fact that the State Corporation Commission approved it. The SCC should understand that the program will work only to the extent customers are deceived into thinking they are buying solar energy. Indeed, lawyers for the Attorney General’s Office of Consumer Counsel actually pointed this out.[1]

The SCC’s order, dated August 7, 2015, notes that the Consumer Counsel “remains concerned that the DCS Pilot, if approved, may not be marketed clearly by the Company,” and that it “wishes to ensure that the DCS Pilot will not be marketed as a solar energy tariff or as an option for consumers to purchase electric energy output from a renewable energy facility.”

The SCC’s response to this concern was to tell Dominion it has to be really clear that participants are merely “supporting” Dominion’s development of solar energy, and to require it to submit to the SCC staff its marketing and promotional materials prior to publication.

But of course, accurate marketing information wouldn’t sell this program. Imagine the shysters telling the emperor, “See, Your Majesty, we’ll pretend to make clothes for you, and you’ll pretend you’re wearing clothes. Then while you march around naked, we’ll use your gold to fund our business selling real clothes to smart people.” Even a stupid emperor would know enough to keep a tight hold on his purse.

[1] From the Consumer Counsel’s Comments on Hearing Officer’s Report: “Dominion has not described the DCS Pilot program accurately . . .” In reality, “DCS Pilot customers would continue to purchase 100% of their energy requirements under their standard service tariff and would not be allocated any power from a renewable energy facility. DCS participants would be making a voluntary contribution to Dominion, which the company claims would be used to support the future development of solar. But Rider DCS participants would not be purchasing any solar energy output. The Commission should direct the Company to not market the program in a manner that leads potential customers to believe that by participating in the DCS program they would be purchasing renewable energy.”