Your electric bills are skyrocketing. Blame our failure to invest in renewable energy.

Photo by Pixabay on Pexels.com

Fossil fuel prices are higher everywhere, and the effect is hitting electric bills as well as prices at the gas pump. 

Utilities that generate power from natural gas and coal face fuel costs two or three times as high as they were just a couple of years ago —and those costs are passed on to customers. Some utilities employ hedging strategies and long-term contracts to reduce the impact of price spikes. But as a general matter, how painful your bill increase will be is a function of how much electricity your utility generates from fossil fuels. 

Gee, don’t you wish we had more renewable energy in Virginia? 

Let’s review the problem. Dominion Energy Virginia, our largest utility, generates most of its electricity from gas and coal, with 29 percent from nuclear and a tiny percentage from solar and biomass. Our second-largest utility, Appalachian Power, derives 85 percent of its power from coal and gas and only 15 percent from renewable energy, primarily wind and hydro. 

Both utilities are investing more in renewables now, but for years they lagged other states even as wind and solar became the lowest-cost sources of energy nationwide. Because the “fuel” for wind turbines and solar panels is free, those sources generate electricity at a stable price that looks even better when coal and gas prices go up. (Nuclear reactors are fueled by uranium, so they aren’t affected by the fossil fuel crunch either; even so, most of them need subsidies to compete in the wholesale market.) 

As previously reported in the Mercury, Dominion filed a request with the State Corporation Commission in May to increase the “fuel factor” portion of its customer bills, citing the higher prices. In the past year, according to Dominion, the price of the natural gas it bought has gone up 100 percent. High gas prices cause utilities to switch to coal generation when it’s cheaper, so the price of coal also rose by 92 percent. In all, the company said it incurred more than a billion dollars more in fuel costs over the past year than it budgeted for a year ago. 

Under Virginia law, Dominion and APCo “pass through” the costs of fuel directly to customers. They don’t collect a profit, but they don’t have to swallow unexpected increases themselves. Customers will have to pay higher rates for as long as it takes Dominion to recoup the extra spending. The only question for the SCC is how quickly Dominion should collect the money.

Consumers in other states are also being hit by higher electricity bills, but the effect is uneven across the country. States that built more renewable energy protected their residents from fuel price increases. 

Data collected by the U.S. Energy Information Agency shows that with few exceptions, states with lower electricity rates than Virginia’s have more renewable energy than we do. Since the EIA data doesn’t reflect all the planned increases due to rising coal and gas prices, the disparity will become even more pronounced over the coming year. 

States in the Pacific Northwest with a lot of inexpensive hydroelectric power have especially low rates, but wind and solar are the cheapest forms of new energy. The higher fossil fuel prices go, the better wind and solar look by comparison. 

States in the Great Plains have been building wind for years because it outcompetes everything else, so their rates are low and increasingly insulated from fossil fuel volatility. South Dakota residents pay less per kilowatt-hour than Virginians do, and the state gets a whopping 83 percent of its electricity from renewable energy, primarily wind. Even North Dakota, a deep red state wedded to fossil fuels, gets more than 35 percent of its electricity from wind and another 5 percent from hydro. Its rates are already much lower than Virginia’s, and its renewable energy will cushion fuel cost increases. 

Investments in solar are also paying off. Take Utah for example, where residential rates are also far lower than Virginia’s. Utah has a coal problem, with 61 percent of its electricity from that one dirty source, and another 24 percent from natural gas. But, as EIA reports, “almost all the rest of in-state generation came from renewable energy, primarily solar power.” Moreover, “solar energy powers about 93 percent of Utah’s electric generating capacity added since 2015.” Evidently, Utah spent the past seven years working to future-proof its energy supply, while Dominion kept building more gas plants. 

Virginia’s slow start on the transition to renewable energy is the direct result of poor investment decisions by our utilities and a disgraceful myopia on the part of the State Corporation Commission. Environmental advocates pointed out for years that our over-commitment to fracked gas meant we’ve been gambling on fuel costs and undervaluing price stability. But the SCC kept approving new fossil fuel projects, and actually urged Dominion to build more gas plants.

Indeed, our situation would be even worse if the General Assembly had not passed the Virginia Clean Economy Act in 2020. The VCEA requires our utilities to transition to carbon-free electricity by 2050 and establishes wind and solar targets for Dominion and APCo to achieve by 2035. The targets are still too low to meet the climate emergency — but until the VCEA became law, Dominion was planning to build even more gas plants

Now customers have to pay for Dominion’s folly. Dominion’s filing states that if it recovers the entire $1 billion shortfall over the coming year, residential bills would have to go up by 19.8 percent. Dominion instead proposes to spread the higher charges over three years to ease the shock, making the bill increase 12.2 percent.  The effect would be further moderated this year by other adjustments the company proposes, like moving the costs of participating in the Regional Greenhouse Gas Initiative into base rates, where they can be absorbed because those rates are so inflated. (On the other hand, the SCC just granted Dominion a separate rate increase for spending to extend the life of its aging nuclear plants—an undertaking projected to cost nearly $4 billion.) 

An SCC hearing examiner heard testimony in Dominion’s rate case on July 6 and 7. A ruling is expected later this summer, and the SCC seems likely to approve the three-year plan. 

Spreading the cost of higher fuel prices out over a longer time may reduce the rate shock, but there are drawbacks to this approach. First, Dominion will charge customers the financing costs of deferring collection on the full amount, adding to the total cost burden. (What, did you think the company was offering to absorb that cost itself?) The way it works is that ratepayers will borrow money to pay off our debt to Dominion, then repay the loan with interest over the next three years. 

The second problem is that if the high cost of fossil fuel isn’t temporary, extending the recovery period will lead to even greater shocks in coming years. If prices stay high and we keep kicking the can down the road, we will pay more financing costs and pile up more debt. Where does this end?

This is not mere speculation. Dominion’s filing already projects that “fuel costs will remain elevated over the next year,” and expert witness testimony in the case notes that Dominion revised its natural gas price projections upwards after it filed its request, without updating the amount it is seeking to collect to reflect the higher projections. 

Over at Appalachian Power the situation may not be any better. APCo typically seeks its fuel factor rate increases in September of each year. Last year the utility sought a $3 average increase in residential bills to cover higher fuel costs, at a time when coal and gas prices were still well below this year’s prices. When the company files for its next fuel factor increase two months from now, the rate increase it seeks is likely to pack a much bigger punch. 

What of other Virginia utilities? Our smallest publicly-owned utility, Kentucky Utilities (Old Dominion Power, which serves five counties in southwest Virginia), is also heavily dependent on fossil fuels although now planning to build more renewables. ODP filed for a modest rate increase in February of this year, just before Russia invaded Ukraine and sent world natural gas prices to heights not seen since the start of the fracking revolution. 

Chris Whelan, vice president for communications and corporate responsibility, told me ODP is able to dampen the effect of fuel price volatility through a “flexible fuel procurement strategy that includes long-term contracts to help hedge against price swings as well as the ability to purchase fuel on the spot market when prices drop.” Still, ODP will have to seek another increase next February unless prices suddenly plummet. The utility recovers excess fuel costs (or lowers rates if fuel costs fall) on an annual basis, so customers would pay off the full amount over 12 months. 

Electric cooperatives that buy electricity from Old Dominion Electric Cooperative also face price increases due to high fossil fuel prices and a paucity of renewables. ODEC’s 2021 energy profile shows it generates 38 percent of its electricity from gas, 14 percent from nuclear, and 4 percent from coal. It purchases the rest from the wholesale market (38 percent) and from renewable energy projects (6 percent). Electricity sold on the PJM wholesale market is generated mainly by natural gas, nuclear and coal, so wholesale market prices are also higher now.

According to Kirk Johnson, ODEC’s senior vice president for member engagement, ODEC has had to raise energy prices twice since the beginning of the year, effective May 1 and July 1. Assuming individual distribution cooperatives passed those costs through immediately, residential co-op customers will have seen a 16 percent increase in their electricity rates since Jan. 1. That’s a really steep increase, but Johnson notes ODEC will collect the full amount of the excess cost by Jan. 1, 2023. 

ODEC’s increase for six months is almost four percentage points lower than the increase Dominion would impose for 12 months if it were to collect its full $1 billion in the shortest time possible. Johnson said ODEC engages in a hedging strategy that acts like an insurance policy to limit the effect of fuel price volatility, and that this strategy has saved their ratepayers hundreds of millions of dollars.

So hedging and long-term contracts can smooth out fossil fuel volatility, but rates are going up everywhere in Virginia. The lesson is clear enough: “cheap” fracked gas was a bad bargain. Our utilities should have been building wind and solar over the last several years to protect us from fossil fuel price volatility, rather than waiting for the General Assembly to force them to act. 

Going forward, the more we invest in wind and solar, the more price stability we will have in our electricity rates, and the less we will have to worry about high fossil fuel prices in the future.  

This article originally appeared in the Virginia Mercury on July 18, 2022. I’ve corrected information for Utah.

*EIA’s webpage lists each state’s average residential price of electricity per kilowatt-hour, but finding the fuel mix for each state requires looking up each one separately. For those of you who like to dive into these details, I’ve assembled the information for you. Note that most of EIA’s data is for 2021, but some state data is for 2020. Unfortunately this includes Virginia.

StatePrice cents/kWh% REsource of RE
Virginia12.837biomass, hydro, solar
Idaho9.8674mostly hydro
Washington10.1275mostly hydro
North Dakota10.4840mostly wind
Utah10.6615mostly solar
Montana11.0052mostly hydro
Wyoming11.0619mostly wind
Nebraska11.1128mostly wind
Oregon11.2268mostly hydro, some wind
Missouri11.5412mostly wind
Arkansas11.7510mostly hydro
Louisiana11.984biomass
South Dakota12.0382wind, hydro
Iowa12.0960almost all wind
North Carolina12.2616mostly solar and hydro
Oklahoma12.3845mostly wind
Kentucky12.637hydro

Dear readers: Many of you know that although I write independently of any organization, I also volunteer for the Sierra Club and serve on its legislative committee. The Sierra Club’s Virginia Chapter urgently needs funds to support its legislative and political work towards a clean energy transition. So this summer I’m passing the hat and asking you to make a donation to our “Ten Wild Weekends” fundraising campaign. Thanks!

If you can’t beat ‘em, join ‘em? Dominion Energy now selling residential solar

Sierra Club members talk to Richmond homeowner Kevin Ciafarini about his experience with solar.

Dominion Energy never used to be happy about customers producing their own energy from solar. “Hostile” is more the word that springs to mind. The company has traditionally seen privately owned solar arrays as competition: The more solar panels people put on their roofs, the less electricity they buy from their utility.

But Virginia has long allowed net metering, and in 2020 our General Assembly came down firmly on the side of customers by expanding opportunities for onsite solar. Consumers responded with the enthusiasm legislators hoped for. Industry statistics show annual residential solar installations in the commonwealth roughly tripled from 2019 to today. 

If you can’t beat ‘em, join ‘em. Virginia homeowners and businesses in the market for a solar array can now buy it from a wholly-owned subsidiary of Dominion Energy called BrightSuite. The BrightSuite website touts some of the same customer benefits that solar advocates have been pointing out all these years: consumer savings, carbon reductions, stable electric bills. And why shouldn’t Dominion sell solar? As the website declares, “We embrace change with a commitment first and foremost to meet our customers’ evolving energy needs.”

Well, amen to that! With climate chaos impacting people’s lives and high fossil fuel prices driving up utility bills faster than the rate of inflation, customers’ energy needs certainly have evolved, and they do now include onsite solar arrays. We just didn’t expect to hear that from Dominion. 

But that’s okay, we welcome latecomers! Moreover, while Dominion’s entry into the residential market will make some people uneasy, it could goose demand, growing the distributed solar market for everyone while pushing out the price-gougers.   

First, though, let’s address that unease. Having an affiliate of the local utility compete for a homeowner’s business puts independent installers at a definite disadvantage. Dominion has a much broader marketing reach, and BrightSuite’s use of the Dominion name carries an implied promise of trustworthiness. In a market crowded with competitors, name recognition and the assurance that a company isn’t going away any time soon are distinct advantages. 

But Dominion’s entry into the retail solar business could ultimately be good for independent installers. Dominion doesn’t do anything inexpensively, and its home solar offering appears to be no exception. If Dominion persuades more customers to look into home solar, and those customers then comparison shop, companies that can offer a better deal will get more business.  

Sarah Vogelsong recently wrote about a project of the HR Climate Hub, which solicited quotes from solar installers for the same single-family home in order to compare prices and service, and to flag potentially predatory sellers. The website offers helpful advice to Virginia homeowners about how solicit and compare offers. It also lists prices and terms from a dozen companies, ranging from a low of $2.10 per watt from Tesla to a high of $5.62 from Power Home Solar. Two small, well-regarded Virginia Beach installers submitted bids of $2.80 and $2.85. BrightSuite’s quote (added after the Mercury article ran) came in at $3.25. 

HR Climate Hub’s figures square with information from the Solar Energy Industries Association, which provides advice for consumers and tracks the average cost of residential solar systems through a service called SolarReviews. According to the website, “As of Jun 2022, the average cost of solar panels in Virginia is $2.66 per watt making a typical 6000 watt (6 kW) solar system $11,797 after claiming the 26% federal solar tax credit now available.”

I asked HR Climate Hub for additional information about the BrightSuite quote and was glad to learn the company uses high quality REC solar panels that carry a 25-year warranty, along with microinverters made by Enphase, a top-quality American company. So, no bottom shelf components here. However, the quote did not mention warranty or maintenance information for the installation work. These do not appear on the BrightSuite website either, apart from a one-year performance guarantee. 

It goes without saying that anyone investing thousands of dollars on a major home improvement should shop around, compare prices, and read warrantees. Prices listed on HR Climate Hub and SolarReviews are a good starting point. Where available, bulk purchase programs like those offered by Solarize NoVa and Virginia Solar United Neighbors provide discounts as well as expert advice. 

But it wouldn’t be surprising if even well-informed consumers choose to pay a premium to get a solar installation from BrightSuite simply because the company is associated with their utility. Name recognition goes a long way in marketing, and a lot of customers will want the security of knowing Dominion Energy isn’t likely to take the money and disappear into the night. With this marketing advantage, I expect BrightSuite will quickly emerge as a market leader in spite of its higher-than-average price. 

Ultimately, however, Dominion’s entry into the market may grow the pie for everyone. Homeowners who have held back from installing solar because they don’t know who to trust may feel confident enough to call BrightSuite. Once they have one quote, many will comparison shop.  

At the very least, Dominion’s entry into the home solar market should set a price ceiling. Why would anyone pay $5 per watt or more for a solar array from a company they probably don’t know anything about, when they could get $3.25 from their utility? Price gougers, beware: your time here is up.

This article appeared in the Virginia Mercury on June 17, 2022.

Dear readers: Many of you know that although I write independently of any organization, I also volunteer for the Sierra Club and serve on its legislative committee. The Sierra Club’s Virginia Chapter urgently needs funds to support its legislative and political work towards a clean energy transition. So this summer I’m passing the hat and asking you to make a donation to our “Ten Wild Weekends” fundraising campaign. Thanks!

Not a great time to roll out Dominion’s pricey solar tariff

Photo by Pixabay on Pexels.com

Well, that didn’t take long.

A few weeks after I wrote about rising natural gas prices, Dominion Energy Virginia asked the SCC for permission to raise the price of electricity by about $9 per month for the average residential customers, citing higher fuel costs. Virginia law allows utilities to pass through its fuel costs to customers, without a profit margin, making it unlikely the SCC will turn down the request. Natural gas is Dominion’s largest fuel source, so its electricity rates are highly vulnerable to price swings in the market for fracked gas.

That makes this a really peculiar time for Dominion to launch a new solar energy purchase option that will add about $20 per month on average for customers who elect to meet their entire electricity demand with solar, without exempting them from the coming bill increase due to higher gas prices. If the company were trying to discourage people from signing up for its solar product, it could hardly have chosen a better time. The fact that the company delayed the launch of this program for more than three years, only to offer it now, makes it all the more suspect.

Dominion’s solar option, confusingly (and wrongly) called “Community Solar” is the product of legislation passed in 2017, three years before the General Assembly authorized private solar developers to sell to Virginia customers. The 2020 legislation dubbed the private program “shared solar,” and it remains mired in SCC rulemaking.

But Dominion Community Solar is different. As I wrote back in 2018, when the SCC approved the program (and its launch seemed imminent), this program is really a solar tariff. Dominion generates electricity from solar and puts it on the grid, and customers who want to run their homes and businesses on solar pay extra on their bill.

As part of the deal, participants also get the renewable energy certificates (RECs) associated with the solar energy. That prevents Dominion from selling the RECs to anyone else or using them to show compliance with Virginia’s new renewable portfolio standard (RPS). This is important to avoid double-counting and ensure that solar paid for by the voluntary market is in addition to the solar developed to serve customers under the RPS.

The $20 premium for the program will sound unreasonably high to people who have experience with community solar in other states, where it is typically offered at a discount to regular grid power. In many states, private developers build the solar facilities and sell the output to participants. The rate is typically fixed for many years, because solar has low O&M costs and uses no fuel. Customers still pay their utility for transmission and distribution, but the community solar fee replaces utility-delivered generation rates. Accordingly, participating customers are insulated from price increases due to higher natural gas (or coal) costs.

That is not Dominion Community Solar. Dominion’s program requires customers to pay for all the utility’s costs of running its generating plants and purchasing fuel and paying for rate adjustment clauses (RACs), including those for new renewable energy facilities that serve the entire rate base and RECs bought for the RPS. These solar-only customers will also have to pay Dominion’s costs for buying carbon allowances in the RGGI market, which the company incurs as a result of generating power from fossil fuels. (Dominion is hoping Governor Youngkin will succeed in pulling Virginia out of RGGI and has suggested shifting compliance costs from riders to base rates in the meantime, clearly as a way to mitigate the rate increase due to high gas prices.)

Dominion Community Solar customers will pay for all these costs of fossil fuel generation, and the cost of Dominion building renewable energy facilities for all its other customers. And then on top of all that, they will pay an extra $20 per month.

Let’s leave aside the question of whether $20 is even a fair premium for a solar tariff. Ultra-high gas prices, RPS riders and RGGI compliance costs are all new since the SCC authorized Dominion’s program in 2018. It’s hard to imagine the SCC agreeing today that program participants should pay all these costs in addition to the cost of developing community-sized solar arrays.

But something else has changed too: The shared solar legislation passed in 2020 promised customers the alternative of being able to buy solar from a third-party provider, unhooking participants from the roller-coaster ride of fossil fuel prices. As I noted before, though, shared solar is mired in proceedings at the SCC, where Dominion is seeking to impose such high fixed costs on participants as to make the program impossible to offer.

Right now, Dominion has an SCC hearing examiner mostly on its side.

If the SCC commissioners accept the hearing examiner’s recommendations, that could spell the end of shared solar—or at any rate, make Dominion’s $20 look good by comparison.

This article originally appeared in the Virginia Mercury on May 16, 2022.

Dear readers: Many of you know that although I write independently of any organization, I also volunteer for the Sierra Club and serve on its legislative committee. Today, the Sierra Club’s Virginia Chapter urgently needs funds to support its legislative and political work towards a clean energy transition. So for the first time I’m passing the hat and asking you to make a donation to our “Ten Wild Weekends” fundraising campaign. And if you’re free on June 12, come join the Solar Walk in Richmond that I’ll be co-leading!

Is offshore wind expensive? Not compared to the alternatives

offshore wind turbines

A massive wind farm 27 miles off the coast of Virginia Beach moved one giant step closer to reality last November when Dominion Energy filed its Coastal Virginia Offshore Wind development plan with the State Corporation Commission. Dominion expects to begin construction on CVOW in 2024, and have all 2,587 megawatts of power connected to the grid in 2026.

But the wind farm’s price tag of $9.8 billion, and its $87 per megawatt hour levelized cost of electricity (LCOE), is causing heartburn over at the attorney general’s office. Scott Norwood, an expert for the Division of Consumer Counsel, criticized the project on three main grounds: that the cost of building CVOW is more than building a new nuclear reactor and 2-3 times as much as building solar facilities; that Dominion has overstated the benefits of the project; and that in any event, Dominion doesn’t need the energy before at least 2035. 

Recognizing that the General Assembly already made most of these points moot by declaring the project to be in the public interest, however, Norwood also recommended the SCC adopt consumer safeguards including periodic status reports and cost oversight. 

Anyone familiar with Dominion’s tendency to pad profits will say “Amen” to the call for strict SCC oversight. With a project this huge, the SCC must be especially vigilant.  Some of Norwood’s criticisms, however, seem more calculated for effect, while others miss the point. 

Norwood certainly knows his comment that CVOW is more expensive than nuclear is not true. The price tag of the only two nuclear reactors under development in the U.S. has ballooned so high ($30 billion and counting) that it almost makes Dominion’s former dream of a third nuclear reactor at North Anna look good. Norwood’s own devastating testimony likely helped kill the North Anna 3 project, which would have delivered electricity for $190 per megawatt-hour.

Norwood says Dominion has fudged the CVOW numbers and the project will cost customers more than the company admits, but still, Dominion would have to gold-plate every turbine before it could touch the cost of nuclear. 

This wasn’t the first time the General Assembly put its thumb on the scale for a Dominion project. The habit goes back to 2008, when a Dominion coal plant, the Virginia City Hybrid Energy Center, became the first project legislatively deemed “in the public interest.” Even back then its projected levelized cost of electricity was $93/MWh. Today, VCHEC loses so much money for customers that Dominion faces pressure at the SCC to close the plant. 

For that matter, I also see that my latest electricity bill from Dominion includes a non-bypassable charge for coal ash disposal of $5.68—an amount that exceeds the charges for participation in RGGI, new solar projects and the RPS program, combined. Pollution is also a cost of using fossil fuels, but it’s never included in the LCOE. 

Mr. Norwood did not suggest Dominion pursue new nuclear or new fossil fuel plants instead of offshore wind. If Dominion needed new generation, he says, solar is the low-cost alternative. It’s cheaper to build, and it produces electricity at a lower cost than offshore wind. He’s right: if all you cared about was LCOE, no one would build anything but solar in Virginia. 

But as critics never tire of pointing out, solar can’t provide electricity 24/7. Offshore wind has a hidden superpower: while solar production peaks in the middle of the day, the wind off our coast can produce electricity both day and night, is often strongest in the evening when demand rises, and is stronger in the winter when solar is less productive. Solar and offshore wind are complementary, and we can’t get to a carbon-free grid without both. So yes, we need CVOW.

Virginia’s leaders are also taking the long view on cost. In any new industry, early projects are more expensive than later ones. Europe’s 30 years of experience developing an offshore wind industry shows costs fall steadily as project experience and new technology enable developers to produce more energy with fewer turbines. States up and down the East Coast are pursuing offshore wind projects not only because they want clean energy, but because they expect these early investments to lead to lower-cost power as the industry achieves scale. 

State leaders also see economic development and job growth as important benefits, and those aren’t reflected in LCOE either. This is another area where SCC oversight can ensure the greatest public benefit from CVOW. Testimony filed by a Sierra Club expert urges that Dominion’s economic development plan be revised with specific metrics around the VCEA’s goals for diversity, equity and inclusion in the offshore wind workforce. Like reducing pollution, creating jobs for residents from low-income and minority communities adds to CVOW’s overall value.

Having criticized the VCEA’s overly-generous cost cap myself at the time, I agree with the AG’s office that the SCC has to keep a tight watch on expenses as Dominion moves forward with CVOW. But move forward it should, because Virginia needs offshore wind. 

This commentary originally appeared in the Virginia Mercury on April 1, 2022.

Dominion’s proposed charge for solar program is absurdly high

Solar panels are well suited to the flat roofs of apartment buildings like this one in the Bronx, but they remain a rarity in Virginia despite a new law designed to open the market. Photo by Bright Power, Inc. – U.S. Department of Energy from United States, Public domain, via Wikimedia Commons

A Dominion Energy customer wrote me recently to ask what her condo association could do to go solar. The building’s roof can hold many more solar panels than needed to power the needs of the common area. Is it possible to sell the excess electricity to individual residents to power their units?

I get this question a lot, and in 2020, the Virginia General Assembly tried to change the answer from “no” to “yes.” As part of the Solar Freedom legislation, the State Corporation Commission was tasked with creating a shared solar program for residents of multifamily buildings like condominiums and apartment buildings, with orders to make the program available beginning in January 1, 2021. In other words, it ought to be available today.

And yet I still have to tell people they can’t do it now, and may not be able to ever, unless the SCC changes course. Would-be customers will have just one final chance this month to try to save the program. On March 25, the SCC will take public testimony at an evidentiary hearing to address the seemingly simple question threatening the viability of the Multifamily Shared Solar Program. The law allows Dominion to collect an administrative fee from customers who participate in the program. How much should that be? 

An administrative fee doesn’t sound like it could be enough to stall a program for more than a year, let alone deep-six it altogether. Dominion’s role in the Multifamily Shared Solar Program is limited to doing the accounting to make sure every unit gets credit for the share of the electricity the resident buys. That shouldn’t cost very much—perhaps a buck or two per month per customer. 

Yet Dominion proposes to impose an administrative fee of more than $87 per month—a charge so absurdly high that it would result in participants paying far more for electricity generated on the roof of their building than for the electricity Dominion delivers to them from elsewhere in the state. The SCC temporarily stopped the utility from implementing that fee, but it also stacked the deck to make a high fee almost inevitable. 

And that’s a program killer. Rooftop solar is still a lot more expensive than large, offsite solar facilities, so keeping fees low is critical to making the economics work. It’s also a matter of equity. Owners of single-family homes with rooftop solar benefit from Virginia’s net metering program, which guarantees them a one-for-one credit for any surplus electricity generated. Multifamily residents deserve something similar.

Indeed, the entire point of putting the Multifamily Shared Solar Program in Solar Freedom—a law otherwise focused on removing barriers to net metering—is to benefit Virginians who’ve been shut out of the solar market because they don’t own their own roofs. Renters in particular are more likely to have lower incomes than owners of single-family homes, so making the program available to them is important to the goal of reducing the energy burden on low- and moderate-income residents and ensuring that the transition to clean energy benefits people at all income levels.

I’m not just guessing about the intent behind Solar Freedom. I know the point is to offer residents of multifamily buildings an analog to net metering because I wrote most of the legislation as it was introduced, in collaboration with allies in local government and the legislators who introduced it. We wanted building owners and occupants to be able to work together to install onsite solar, free of SCC meddling and without the utility demanding a cut of the action. 

But as so often happens with legislative sausage-making, the bill changed as it went through negotiations and emerged from committees. The SCC was charged with developing a formal program, and Dominion was given a role in administering it. Yet the new language made clear that the original purpose remained. The SCC is to write regulations that “reasonably allow for the creation and financing of shared solar facilities” and “allow all customer classes to participate in the program, and ensure participation opportunities for all customer classes.” 

The legislation provides for participants to be credited on their utility bills with their share of the electricity generated by the solar panels. The SCC is to make an annual calculation of the bill credit rate “as the effective retail rate of the customer’s rate class, which shall be inclusive of all supply charges, delivery charges, demand charges, fixed charges and any applicable riders or other charges to the customer.” To the definition of “bill credit rate” is added the admonition that the rate “shall be set such that the shared solar program results in robust project development and shared solar program access for all customer classes.” 

This language is consistent with a goal of putting multifamily buildings on par with single-family homes in making rooftop solar affordable. But, unlike the original legislative language, and unlike the rules of net metering, the final version of Solar Freedom instructs the SCC to “allow the investor-owned utilities to recover reasonable costs of administering the program.” 

And that’s the opportunity Dominion wants to exploit. As soon as the SCC began the process of writing rules for the Multifamily Shared Solar Program, Dominion advanced the claim that the administrative fee should be based on essentially all of the costs of operating an electric utility. Instead of the multifamily program mirroring net metering, Dominion took as its model a larger program under a very different law. The Shared Solar legislation, also passed in 2020, creates a program for community solar facilities that can be onsite or offsite, can serve many more customers anywhere in Dominion’s territory, and can even be carved out of a utility-scale solar facility. The shared solar law specifically allows Dominion to charge most customers a “minimum bill” with a list of components, and also an “administrative fee.” 

Things aren’t going well for the Shared Solar program at the SCC. A hearing examiner recently recommended the commission adopt a minimum bill of more than $55, based on an SCC staff recommendation. It did not trouble the hearing examiner or the staff that the number puts the cost of shared solar above the cost of Dominion’s own electricity, a program killer according to community solar developers.

But cramming the minimum bill elements into the multifamily program’s administrative fee would be an even greater blow to a program whose economics are already constrained by the smaller size of onsite projects. It also seems obvious from a plain reading of the two laws that the General Assembly did not intend to burden multifamily residents with the fees it authorized for the Shared Solar participants.

Unfortunately for customers, the SCC approved the cramming in concept last July, ignoring this plain legislative intent. Based on that, SCC staff proposed options for the administrative fee of either $16.78 or $57.26, with the higher fee using the same reasoning that just led to the hearing examiner’s $55 recommendation in the shared solar program. 

The SCC ought to reject these numbers and instead adopt the dollar or two that running the multifamily shared solar program will actually cost Dominion. But to do so, commissioners will have to reverse their earlier, egregious decision and embrace what seems to be (for them) the novel concept that the General Assembly intended the plain meaning of its words. Only then will residents of multifamily buildings gain their solar freedom. 

Note: those wishing to testify at the SCC hearing must sign up by March 22.

This article originally appeared in the Virginia Mercury on March 10, 2022.

Looking backward, Virginia Republicans attack climate action and coddle coal

Photo credit: Mark Dixon from Pittsburgh, PA, CC BY 2.0 , via Wikimedia Commons

Even before taking office, Governor Glenn Youngkin made two rookie mistakes: he declared his intention to pull Virginia out of the Regional Greenhouse Gas Initiative (RGGI) by executive order, not realizing it can only be done by legislation; and he nominated the much-reviled Trump-era EPA chief Andrew Wheeler to be his Secretary of Natural Resources, apparently unaware the appointment would need approval from the Democratic-led Senate he had just infuriated with the RGGI announcement. 

Evidently not a man to admit a blunder, on his first day in office Youngkin signed an  executive order directing the Department of Environmental Quality to notify RGGI of his intent to withdraw Virginia from the carbon-cutting program, and to develop an “emergency regulation” to send to the Air Pollution Control Board for the same purpose. The language in the order is a little less than he pledged, and yet still not legal.

These are unfortunate signs that Youngkin, who ran for governor as a moderate Republican, intends to govern as a burn-the-house-down extremist when it comes to the environment. 

It’s surprising to see Youngkin pursuing Trumpist energy policies, and not just because they failed so dismally when Trump tried them. As the former CEO of a multibillion-dollar private equity investment company, Youngkin is, presumably, not an idiot. He has acknowledged climate change is real and affecting Virginia, and he has access to the same polls the rest of us do that show Americans are concerned and want government action to address the crisis. Corporate America is also calling for action; CEOs of more than 70 of the world’s largest corporations wrote a letter last June calling on governments to adopt policies capable of capping the global rise in temperature at no more than 1.5 decrees Celsius. 

The legislation that put Virginia into RGGI will lead to a 30 percent cut in the Commonwealth’s electric sector CO2 emissions by 2030. Companion legislation, the Virginia Clean Economy Act (VCEA), extends the carbon cutting out to 2050, to hit zero carbon emissions from the electric sector. Youngkin complains that RGGI costs ratepayers money, but it’s not like the money raised through carbon allowance auctions disappears into the ether: it pays for coastal flood-control projects and low-income energy efficiency programs that Virginia wasn’t funding before. Maybe Youngkin intends to replace these hundreds of millions of dollars with some of the federal funding coming to Virginia through the federal infrastructure bill—you know, the legislation that Virginia’s Republican congressmen voted against

Or maybe he doesn’t really care about the human consequences of his actions, since Virginia governors can’t run for reelection. Even last fall Youngkin was being talked about as a potential presidential candidate based on his ability to say nothing of substance for an entire campaign season. It was a good trick, but it’s a hard one to pull off twice. If Youngkin runs for president, he’ll be doing it as the guy who started his governorship by torching Virginia’s climate action plan.

Whether they are fellow flame-throwers or not, General Assembly Republicans are rallying around the new governor. Two bills filed last week seek to do legally what Youngkin wanted to do by executive fiat. SB532 (Stuart) and HB1301 (Kilgore) would repeal the Clean Energy and Community Flood Preparedness Act, direct DEQ to suspend the Commonwealth’s participation in the Regional Greenhouse Gas Initiative and remove provisions for using revenues from the auctions. 

SB81 (Stanley) would prohibit the Air Pollution Control Board from considering health, environmental, scientific, or economic factors when making regulations—an attack on both RGGI and clean car regulation, as well as on the independence and very mission of the Air Board. SB657 (Stuart) also attacks the Air Board’s authority (and that of the Water Board for good measure).

HB118 (Freitas) goes bigger. It repeals key features of the VCEA, including achieving zero carbon emissions by 2050; allowing the SCC to approve new fossil fuel plants only if a utility has met energy-saving goals and can prove cost-effectiveness; allowing utilities to recover costs of compliance with Virginia’s new renewable portfolio standard; and making wind, solar and offshore wind projects “in the public interest,” magic words that assure utilities they will get paid for making these investments.

The Freitas bill might pass the House, now that Republicans hold a slim majority, but neither of these two bills should pass the Senate with Democrats in charge. Creating the framework for the energy transition was a signature success for Virginia Democrats, and it’s hard to imagine a scenario in which they will let it be taken from them. 

That isn’t stopping other Republicans from taking their own shots. Several bills seek to undermine the energy transition in various ways; all of them are bad policy.

  • HB74 (also Ware) would subsidize certain large industrial customers by allowing them to share in the benefits, yet exempting them from the costs, of the energy transition, shifting their share of the costs onto all other customers. 
  • HB5 (Morefield) raids the RGGI funds to get money for his own district. 
  • HB892 (Kilgore) and SB398 (McDougle) subsidize RGGI costs for certain fossil fuel generators, another raid on the funds. 
  • HB1204 (Kilgore) prevents the RPS from taking effect until 2025 and guts the carve-out for distributed generation permanently. It also removes the authority of the Air Pollution Control Board over air pollution permits for “minor” sources of pollution.
  • HB1257 (Kilgore, on a roll!) guarantees customers access to natural gas in the name of “energy justice,” banning local electrification efforts, and making it really hard for the city of Richmond to terminate its gas utility.
  • HB1261 (Bloxom) also strips the Air and Water Boards of their permit-granting authority. 
  • HB73 (Ware) and SB761 (Sutterlein) eliminates language putting wind, solar and offshore wind in the public interest, undercutting the market certainty that put Virginia into the top ranks for solar energy in the past year and attracted a major offshore wind turbine blade manufacturing facility to Portsmouth. (The bill also lets the SCC put costs of new facilities into a utility’s rate base instead of tacking on a rate adjustment clause. If this were the only thing the bill did, it would be worth supporting.)

Not all the bills we are likely to see this year have been filed yet, so there is a good chance we will see further attacks on climate action, all with the pretense of saving money. I will continue updating this post when I hear of other bills like these. 

“Virginia is no longer anti-coal,” — new Virginia Attorney General Jason Miyares. 

Speaking of things that cost ratepayers money, bills to subsidize coal are back this year. As we have all learned, coal is no longer a competitive fuel in Virginia. It lost out first to fracked gas, and more recently to solar. But in a compromise with coalfields Republicans, the VCEA excluded one coal plant, the Virginia City Hybrid Energy Center (VCHEC) in Wise County, from a requirement that Dominion Energy Virginia close its Virginia coal plants this decade. In theory, VCHEC could stay open until 2045, when the VCEA requires Dominion to reach zero carbon across all its generation.

In reality, though, the reprieve isn’t enough to save the coal plant. Dominion’s own analysis, from its 2020 Integrated Resource Plan case, assigned VCHEC a net present value of negative $472 million just for the ten years from 2020-2029. Dominion didn’t try to extend that analysis out to 2045, but clearly the cost to customers from running a money-losing coal plant for 25 years would top a cool billion. Not surprisingly, the SCC is considering requiring Dominion to retire VCHEC to save money for its customers.

Given concerns about RGGI’s cost to consumers, you might think Southwest Virginia Republicans would lead the charge to retire the money-losing coal plant in their midst. You would be wrong. To understand why, it will help you to know that the counties making up Southwest Virginia are not in Dominion’s service territory, but in Appalachian Power’s. The people who benefit from keeping a coal plant open in Wise County are not the same people who have to pay for the plant’s spectacular losses. 

As an excuse to keep the plant open, coalfields Republicans claim it’s to help the environment. Yes, really. Some of VCHEC’s fuel is waste coal excavated from the piles of mining waste that litter the coalfields, a toxic legacy of the era when coal was king and environmental regulations went unenforced. Burning the waste coal is one way to get rid of it, though not the only way or, for that matter, the right way. 

As a new report from the Appalachian State School of Law discusses, the federal infrastructure bill (again, the same one Virginia Republicans voted against) will provide millions of dollars to Virginia to remediate abandoned minelands, including these piles of toxic waste. (The report, titled Addressing Virginia’s Legacy GOB Piles, has been sent to General Assembly members but is not yet available online.)

In a letter to Senator John Edwards, report lead author Mark “Buzz” Belleville expressed his strong disagreement with bills aimed at encouraging the burning of waste coal. As he wrote, “Waste coal is of lower quality, requiring additives for combustion and resulting in even greater CO2 emissions and traditional air pollution than newly-mined coal. As the report notes, existing GOB piles can be disposed of or remediated in other manners that do not undermine Virginia’s commitment to a transition to clean energy.”

Rather than use the coming federal funds to remediate GOB piles, Republicans would prefer that Dominion customers be forced to pay hundreds of millions of dollars in higher energy costs and put more pollution into the air. 

So at the same time they rail against the costs of RGGI and VCEA, Republicans are using waste coal as a reason to raise costs even more. 

  • HB656 (Wampler) dangles a tax credit for using waste coal. 
  • SB120 (Hackworth) and HB657 (Wampler) declare waste coal a “renewable energy” source and exempts VCHEC from the requirement that it close by 2045. 
  • HB894 (Kilgore) outright prohibits the SCC from requiring Dominion to retire VCHEC “before the end of its useful life.” (Would that be before or after Virginia becomes so hot we all move to Canada?)
  • HB1326 (Kilgore, trying everything he can think of) makes it “in the public interest” for utilities to use waste coal, and gives utilities a way to charge ratepayers extra for doing so.

Electricity customers had better get used to being used as a political football by legislators who attack the costs of the energy transition but have no qualms about making ratepayers subsidize coal. 

This post originally appeared in the Virginia Mercury on January 20, 2022. It has been updated to include bills filed since then.

A divided General Assembly can find common ground on clean energy

Almost two years ago, Virginia’s General Assembly made history with a series of laws shepherding Virginia towards a future of clean, low-cost wind and solar energy. During this year’s election campaign, Republican talking points included attacks on the Virginia Clean Economy Act (VCEA), the law at the center of the transition. But talk, as they say, is cheap. With the VCEA protected by the Democratic majority in the Senate, Republicans didn’t have to put forward a serious alternative, and they didn’t.

Now that the Republicans have won the governorship and a majority in the House of Delegates, passing any new legislation (or repealing anything already in place) will require bipartisan action. Democrats want to protect Virginia’s progress in tackling carbon emissions and putting equity into energy planning. Republicans want to reduce burdens on industry. Both sides want affordable electricity and a robust economy that creates jobs. Rhetoric aside, there is much to agree on.

Solar is wildly popular with conservatives as well as liberals, in part because it saves money. With no fuel costs, and ever-falling prices of solar panels, solar arrays are now the go-to choice for utilities that need more power. It is cheaper for a utility to build a new solar facility today than to operate an existing coal plant in Virginia. 

As for existing gas plants, they compete with solar only when the price of fracked gas is low. Gas prices have doubled in the past year, so Virginia’s current reliance on natural gas for 60% of our electricity generation hurts everyone’s wallets. 

And while fracked gas is imported from other states, we can build solar and wind facilities here in the Commonwealth and off our coast, so our own workers and businesses benefit. The faster we bring on the energy transition, the better for our economy. 

The energy transition also means cleaner air and water for our children, improving the efficiency of homes to make them more comfortable and less costly to live in, reducing the energy burden on low-income residents, helping coastal communities adapt to rising sea levels, and giving people greater freedom to invest their own money in solar panels on their own property. All of these are part of the VCEA and the other bills that guide our energy transition, and repealing them now would be shooting ourselves in both feet.

Nonetheless, there is room for improvement. Last year legislators established a fund to put renewable energy on abandoned mine sites and other brownfields, but didn’t allocate money. Under the bipartisan infrastructure bill just passed in Congress, Virginia will receive an estimated $23,579,905 annually in federal abandoned mine land funding. Once former mine sites are cleaned up, they will be ideal locations for solar facilities, and the General Assembly should make sure that happens. 

Other federal funding will support smart grid and transmission investments. Some of these projects are already underway in Virginia, and the General Assembly should make sure that savings go to ratepayers, not to utilities.

Solar on schools has been one of the greatest success stories of the past few years in Virginia, with more than 45 jurisdictions signing contracts that will put solar panels on school roofs at no up-front cost, and with energy savings every year. But some schools are still built with roofs that aren’t designed to support solar. That has to change. 

Indeed, in 2019 the General Assembly passed a Republican-sponsored bill that went further, declaring it “the intent of the General Assembly that new public school buildings and facilities and improvements and renovations to existing public school buildings and facilities be designed, constructed, maintained, and operated to generate more electricity than consumed.” In 2022, legislators could turn this into a requirement, saving money for taxpayers across the Commonwealth. 

Community solar offers another money-saving opportunity. Legislation passed in 2020 will allow residents and businesses to buy electricity from shared solar projects developed by private companies. The initial program is small and confined to customers of Dominion Energy, which is trying to persuade regulators to mandate crushingly high minimum bills. Legislators can fix these problems by expanding the program statewide and capping the minimum bill. 

The General Assembly has repeatedly failed to rein in the power of utilities like Dominion, which uses its influence to protect its profits at the expense of consumers. The ability to make unlimited political contributions backfired on Dominion when its $200,000 contribution to an anti-Youngkin campaign was exposed. But public utilities should not be allowed to buy influence, period. Let’s make this the year that stops.

This op-ed appeared in the Richmond Times-Dispatch on November 27,2021. 

Dominion-funded group adds more fuel to its campaign against utility reform, and a legislator responds

Four things happened after I wrote last week about Power for Tomorrow’s strange advertising campaign attacking Clean Virginia: the Fredericksburg Freelance-Star ran an op-ed from Power for Tomorrow’s executive director, Gary C. Meltz, opposing deregulation in the electric sector; the Virginia Mercury ran a response to my article from Mr. Meltz; another mailer arrived from Power for Tomorrow, even more unhinged about Clean Virginia and what it calls “their Texas-style policies”; and the Roanoke Times ran an op-ed from Republican Senator David Sutterlein in favor of electricity choice. 

Mr. Meltz’ Freelance-Star op-ed argues that regulated monopolies produce lower cost power for consumers than competitive markets. Instead of developing the argument, however, most of the op-ed is devoted to horror stories about Texas and Maryland.

In both states, poor regulation unquestionably led to high bills, in Texas because customers were allowed to choose “low-cost” billing options that charged them astronomical real-time power costs during the winter freeze, and in Maryland because unscrupulous power providers lured low-income customers into overpriced contracts with up-front goodies like gift cards. Power for Tomorrow would like you to think these abuses are the inevitable result of deregulated markets, but it doesn’t follow.

Coming from the opposite direction, Senator Sutterlein’s op-ed argues that Dominion has abused its political power for private gain. He cites legislation like the notorious 2015 “rate freeze” bill that allowed the company to hang on to over-earnings it would otherwise have had to refund to customers. His cure for these abuses is deregulation, allowing customers to choose other electricity providers. But again, it’s not obvious that curbing Dominion’s excessive profits requires deregulation, rather than better regulation by the General Assembly and the SCC.

Personally, I’m agnostic on this issue. I would welcome a data-driven discussion of whether carefully-designed free markets deliver more for the public than a well-regulated monopoly system coupled with a ban on campaign contributions from public utilities. 

But if Power for Tomorrow is really interested in consumer protection, it’s just plain weird that its ads are so squarely focused on trying to take down Clean Virginia, an organization whose entire purpose is to secure lower costs for consumers. It’s hard not to suspect that the real point of the attack ads is to protect the high profits of Power for Tomorrow’s utility funders. 

According to Mr. Meltz, those over- the-top mailers are indeed getting results for Power for Tomorrow. In his Virginia Mercury letter, Meltz says his organization’s “education campaign” has produced 4,324 letters to elected officials and 1,607 petition signatures. Meltz also says Power for Tomorrow’s funding (and spending) will become a public record when they submit paperwork to the IRS. He doesn’t say when that will be; and he isn’t telling us the answers now.

What’s with the scary ads about threats to your power service?

A mailer sent out to Virginia residents from “Power for Tomorrow”

It’s campaign season in Virginia, with primary elections coming up on June 8. But in addition to all the candidate flyers arriving in mailboxes, Virginia residents have been receiving another kind of mailer with a message unrelated to the election.

Oversized, campaign-style postcards from an entity calling itself Power for Tomorrow warn, “Clean Virginia wants to end customer protections on electricity — leaving Virginians stuck with #BigBills like Texas!” Quotes from headlines about last winter’s disastrous power outage in Texas sprinkle the page to drive home the message that “It happened in Texas. Don’t let it happen in Virginia.” 

The flip side of the postcard reads, “We can’t allow so-called ‘Clean Virginia’ to spend millions to influence Richmond politicians and make hardworking Virginians pay more for electricity.” The cards then urge people to join a texting campaign targeting legislators. 

What’s going on here? According to the nonprofit Energy and Policy Institute, Power for Tomorrow is a utility front group that is “Virginia-based and Dominion Energy-connected.” Power for Tomorrow “opposes efforts to introduce greater competition to monopoly utilities and provides a platform for former regulators to advocate for utility interests.” Its directors and experts are mostly lawyers and lobbyists who represent utility interests. Its website claims the Texas power outage “catalyzed the launch” of the group, but Energy and Policy Institute notes that the website first launched in 2019, and only re-launched this year following the Texas debacle. 

In addition to the postcard mailer, Power for Tomorrow has also run television and Facebook ads. According to Virginia Public Media, as of May 14 the organization had spent at least $220,000 on TV ads and at least another $90,000 on Facebook ads. Dominion Energy spokesperson Rayhan Daudani told Virginia Public Media that Dominion is “proud to support Power for Tomorrow and its efforts to educate people about the dangers of electric deregulation.” He also asserted Dominion’s political contributions, including those to Power for Tomorrow, were “bipartisan and transparent.” 

The bipartisan part is true; Virginia Public Access Project records show Dominion gives money to both Democrats and Republicans. Doing so ensures the company has influence no matter which party holds power. Dominion’s political donations to Virginia elected leaders add up to over $3 million in just the last year and a half (making its criticism of Clean Virginia’s spending more than a little hypocritical). “Transparent” is another matter, however; neither VPAP nor any other source I could find reveals how much money Dominion has provided to Power for Tomorrow.  

As for the claims about customer protections, the mailer’s message stands Clean Virginia’s purpose on its head. Clean Virginia advocates for decreasing the influence of utilities on the General Assembly and increasing regulatory oversight by the State Corporation Commission. The legislation it supported in 2021 uniformly would have returned more money to customers.  The reason Clean Virginia “spends millions to influence Richmond politicians” is to counter Dominion Energy’s spending and political influence in Richmond. There would be no need for Clean Virginia if the General Assembly weren’t already under the utility’s thumb. 

According to Clean Virginia’s website, the five energy reform bills the group supported in 2021 were:

  • HB2200, restoring SCC discretion over Dominion rate-setting and accounting practices
  • HB1984, allowing the SCC to set future rates to reflect the true cost of service
  • HB1914, giving the SCC the ability to set the time period for utilities to recover large one-time expenses, eliminating an accounting gimmick that benefited utilities at the expense of customers
  • HB2160, requiring utilities to return 100% of overcharges to customers, instead of being allowed to keep 30 percent
  • HB2049, also aimed at supporting rate reductions or refunds

All of these bills passed the House with bipartisan support but failed in the Senate, where the Commerce and Labor committee remains Dominion-friendly. 

The Power for Tomorrow ads don’t try to defend Dominion’s opposition to customer-friendly legislation. Instead, they reference a broader effort by Clean Virginia and an unusual alliance of several progressive and conservative free-market groups to restructure Virginia’s utilities. Calling themselves the Virginia Energy Reform Coalition, the allies supported legislation in 2020 that would have separated the generation and transmission functions of Dominion and Appalachian Power and introduced competition in the sale of electricity. 

Whether the long-term effects of this kind of energy deregulation would be good or bad for Virginia residents is a matter of furious debate, but clearly the legislation would have hurt Dominion’s profits. In any event, the bill never even got a vote last year, and was not brought back in 2021. 

The Power for Tomorrow campaign deliberately muddies the water. While mentioning only the stillborn deregulation effort, its attacks on Clean Virginia are meant to undercut support for other legislation that increases utility regulation. 

So what about the threat of Texas-style power outages? Where is the connection? Power for Tomorrow would like you to believe that competition leads to disaster. But the mailer is vague about how what happened in Texas might happen here, and for good reason: It won’t. 

What happened in Texas was due to generating facilities (mostly natural gas) freezing up and failing to deliver electricity to the state’s isolated power grid. With too much demand and not enough supply, short-term power costs soared, and people who’d opted for electricity plans that tracked real-time prices received astronomical bills. Simple regulatory fixes could have avoided both the blackouts and the sky-high bills, but Texas politicians and grid operators shied away from imposing those requirements. Failure to regulate, not deregulation, was to blame. 

When the lights go out in Virginia, by contrast, downed power lines and blown transformers are typically to blame. In other words, the problem is in the delivery, not the generation. Our electricity supply is more secure than Texas’ because Virginia is part of the larger PJM transmission grid that covers all or parts of 13 states from the East to the Midwest. Not only does PJM have a huge excess of generating capacity, but generators have to guarantee they will deliver electricity when called on, and would be penalized by failure to winterize their facilities. Those guarantees are absent in Texas.

Introducing competition to the Virginia utility market would not change any of this. Some states within PJM have deregulated utilities, others have vertically-integrated utilities like Virginia’s. The Texas blackouts were scary; they are also a red herring.  Apparently the cynics at Power for Tomorrow think there is nothing wrong with a non sequitur if it gets people’s attention. 

But is it getting their attention? I checked with a couple of legislators, neither of whom had received any texts or emails from constituents generated by the advertising. Either the campaign isn’t working, or Power for Tomorrow is just building out a mailing list to deploy later, perhaps in the next legislative session when regulatory reform bills come up again.  

At that point we may find out whether Dominion has built an anti-reform constituency with these misleading ads, or just added fuel to the fire. 

This article originally ran in the Virginia Mercury on June 2, 2021. It has been updated to correct the day of the June primary. It is June 8, not June 6.

Why most ‘renewable energy’ options don’t add new wind and solar to the grid

bucket of green paint with spill
Photo credit: Neep at the English Language Wikipedia.

Virginia residents who want to do right by the planet are confronted with a bewildering array of renewable energy and “green power” options. Unfortunately, few of these programs actually deliver renewable energy. People who want the gold standard — electricity from new wind and solar projects — are completely out of luck if their utility is Dominion Energy Virginia or Appalachian Power. 

To understand how there can be so many options and none of them good, we first have to talk about renewable energy certificates.  RECs are a topic that is way more interesting than it sounds because — well, it would have to be, wouldn’t it? RECs are how we know that some electricity can be attributed to a renewable source. If you want to know what kind of renewable energy your utility is buying, or if you yourself want to buy renewable energy, RECs matter.

RECs are not electricity; they aren’t even real certificates. They were conceived of as an accounting tool enabling a utility to show it is in compliance with a state mandate to include a percentage of renewable energy in its mix. A utility amasses RECs associated with its own renewable generating sources, or buys them from renewable sources it doesn’t own, and then “retires” them to show compliance with the law. Since RECs are separate from the electricity itself, they can be bought and sold independently. There is even an online marketplace for your REC shopping convenience. 

RECs are also how voluntary buyers of renewable energy, like customers of Arcadia or Dominion’s Green Power Program, know they’re actually getting what they pay for —assuming they understand that what they pay for is not actually energy, and may have no relationship to the electricity powering their home or business. If you buy RECs, you are still using whatever electricity your utility provides, but you are also paying a premium on top of your regular bill. 

There is no nationwide, generally accepted definition of “renewable energy,” just as there is no definition of “natural” in food labeling. In Virginia, there is a state law defining what counts as renewable, and it includes not just solar, wind and hydro, but also a range of burnable fuels like biomass and municipal solid waste that foul the air and contribute to climate change. Buyer beware!  

The Virginia Clean Economy Act narrowed the list of sources that Dominion and APCo can use to meet the law’s new renewable portfolio standard, and also limited the locations of qualifying facilities. After 2025, happily, most of the RECs retired by Dominion and APCo under the VCEA will come from Virginia wind and solar facilities. 

But crucially, the VCEA didn’t change the definition of renewable energy in the code. Dominion won’t be able to use RECs from its biomass plants to meet the VCEA, but it can still sell them to anyone else and label the product “renewable” without falling afoul of the law. Anyone buying a renewable energy product from Dominion had better check the list of ingredients. 

It’s not just Dominion. Anyone buying RECs from Arcadia or anywhere else should take a good look at what they are getting, and ask themselves if the money they spend means new renewable energy will be added to the grid. 

The answer is probably no. If the RECs come from a wind farm in Texas or Iowa, the electricity from those turbines doesn’t feed into the grid that serves Virginia, so you can’t even pretend it is powering your house. It also doesn’t mean anyone built a wind farm because of REC buyers like you. Wind energy is already the cheapest form of new energy in the central part of the U.S. People build wind farms because they are profitable, not because they can sell RECs. In fact, those wind farms are swimming in surplus RECs, because states in the center of the country don’t have renewable energy mandates to make their own utilities buy them.  

For that matter, a lot of RECs come from facilities that were built before the idea of RECs even existed. Hundred-year-old hydroelectric dams can sell RECs; so can fifty-year-old paper mills that sell biomass RECs from burning wood. 

With this background, let’s look at the offerings available in Virginia and see which are worth paying more for. 

Dominion Energy Virginia

In theory, Dominion customers will have the ability to buy real solar energy directly from independent providers beginning as early as 2023, thanks to shared solar legislation sponsored by Sen. Scott Surovell and Del. Jay Jones and passed in 2020. The law envisions independent solar developers building solar facilities in Virginia and selling the electricity (and the RECs) to subscribers who are Dominion customers. But the SCC opened a Pandora’s box last fall by allowing Dominion to propose the rules, and in an act of classic Dominion overreach, the utility has now proposed to collect an average of $75 a month as a “minimum bill” from every customer who buys solar energy from someone else. A fee like that would end the program before it ever started.

 The matter is hardly settled. The solar industry has asked for an evidentiary hearing and suggested that the minimum bill should be set at a single dollar. If all else fails, the program may go forward serving only low-income customers, whom the legislation exempts from the minimum bill. 

Dominion customers can hope for the best, but any shared solar option is still at least two years away. 

In the meantime, the utility’s website lists four renewable energy options: two that sell RECs, one that sells actual energy (and retires the RECs for you) and one that doesn’t exist. 

• The REC-based Green Power Program has been around for a decade, and as of 2019 it had more than 31,000 subscribers. Dominion’s “product content label” projected that for 2020 the program would likely consist of 56 percent wind RECs, 34 percent biomass RECs, and 10 percent solar RECs. Facilities are advertised as being “in Virginia and the surrounding region,” but the fine print reveals sources as far away as Mississippi, Georgia, Missouri and Alabama, none of which are part of the PJM transmission grid that serves Virginia.  (Side note: the biomass icon is a cow, not a tree, which is misleading but charming, unless they might be burning cows, in which case it is deeply disturbing.) With the website out of date, I contacted Dominion for current content information: solar is now up to 13 percent, but, sadly, biomass still makes up 35 percent of the mix (but now it has a leaf icon!).

• REC Select. When I say “buyer beware,” I have this offering in mind. Dominion has been authorized to go Dumpster diving to buy the cheapest RECs from around the country and from any facility that meets Virginia’s overly-expansive definition of renewable energy. The website implies that so far the company is only buying wind RECs from Oklahoma and Nebraska, an indication of just how cheap those are. But under the terms of the program, the RECs could come from 50-year-old paper mills in Ohio or hundred-year-old hydroelectric dams. No educated consumer would buy this product, and both Dominion and the SCC should be ashamed of themselves for putting it out there.

• The 100% Renewable Energy Program delivers actual energy from Virginia, and retires RECs on your behalf. That’s the good news. But only a few of the solar farms are new; the rest of the energy comes from old hydro plants and, worse, from biomass plants that are so highly polluting that they don’t qualify for Virginia’s renewable energy mandate under the VCEA. The inclusion of biomass makes the program more expensive than it would be otherwise. So why include biomass when no one wants it? Because Dominion doesn’t really care if you sign up for this program. The company only offers it to close off a provision in the law that allowed customers to buy renewable energy from competitors if their own utility doesn’t offer it.

• Dominion’s website does list one attractive program under the name “community solar.” Like the shared solar program already discussed, it would deliver actual solar energy from new facilities to be built in Virginia, while retiring the RECs on your behalf. This would pass all our tests, except that it doesn’t exist. The SCC gave Dominion the green light to offer the program more than two years ago, and we’ve heard nothing since, even though the enabling legislation appears to make it mandatoryfor both Dominion and APCo. 

Appalachian Power

APCo never developed a community solar program either, and the shared solar program discussed earlier would not be available to APCO customers even if it gets off the ground. But APCo does have two renewable energy offerings. 

• For its Virginia Green Pricing program, APCo put together wind and hydro from its own facilities. That means it’s actual energy and reasonably priced, at less than half a cent per kWh. But these are existing facilities that all its customers had been paying for until APCo figured out how to segment the market and make more money, and the hydro is old. (As with Dominion’s renewable energy program, the real purpose of the new product was to close off competition.) 

• Even cheaper is Alternative Option-REC, the RECs for which “may come from a variety of resources but will likely be associated with energy from waste, solid waste and hydro facilities.” No biomass, anyway, but I still have trouble imagining who would pay extra for (literally) garbage. 

Virginia electric coops

Some electric cooperatives offer real renewable energy to customers, and a couple have community solar programs that are quite attractive.  

• Central Virginia Electric Cooperative and BARC Electric Cooperativeoffer community solar programs that not only deliver actual solar energy, but also let customers lock in a fixed price for 20-25 years. Four other coops also offer a solar energy option, and at least one other is working on it.

• Many coops also sell RECs, of mixed quality. Shenandoah Valley Electric Cooperative offers RECs generated by wind farms owned or contracted byOld Dominion Electric Cooperative, the generation cooperative that supplies power to most Virginia coops. Rappahannock Electric Cooperative, however, sells only biomass RECs.

• Bottom line: if you are a member of an electric cooperative, you may have better options than either Dominion or APCo is offering — and if you don’t, hey, you’re an owner of the coop, so make some noise!

Arcadia

 If you like RECs, you don’t have to buy them from your own utility. The folks at Arcadia have struggled for years to offer products that put new renewable energy on the grid. In states that allow community solar, Arcadia now offers wind and solar from projects in those states. Everywhere else, they just sell RECs. The website provides no information indicating where the facilities are, meaning they could be out in the same central plains states that are awash in surplus wind RECs. Their game plan appears to be for all the nice liberals with climate guilt to throw enough money at red state RECs that eventually the day will come when demand exceeds supply and drives the price up enough to incentivize new projects. The plan sounds self-defeating to me, but in any case, buyers should keep in mind that the RECs bought before that glorious date will have incentivized precisely nothing. 

Other options

Obviously, if you have a sunny roof, you can install solar onsite and net-meter. Of all the programs available today, that’s the one that will save you money instead of making you spend more. 

If you don’t have a sunny roof, but you’d still like to see your money put solar onto the grid, consider contributing to a church, school or non-profit that is going solar, or to an organization that puts solar on low-income homes. Two that operate in Virginia are Give Solar, which puts solar on Habitat for Humanity houses, and GRID Alternatives, which trains workers to install solar on low-income homes here and abroad. If everyone in Virginia who is currently buying RECs were to choose this alternative instead, it would put millions of dollars to work building new solar in Virginia, and lowering the energy bills of people who most need the help.

And that might make it the best option of all.

A version of this article first appeared in the Virginia Mercury on May 21, 2021.