If Dominion’s plan is so bad, is there a better one? (Spoiler alert: yes, there is.)

September 7, 2023 by Ivy Main

*Courtesy of Lowell Feld, Blue Virginia*

In my last column I took Dominion’s Integrated Resource Plan (semi-) seriously, giving the utility the benefit of the doubt in its projections for data center growth and the alleged need for more fossil fuels to keep up with the power demands of that ravenous industry. But as I also noted, Dominion doesn’t deserve to be taken seriously with this document.

Under Virginia law, an Integrated Resource Plan (IRP) is supposed to explain how the utility expects to meet demand reliably and at low cost within the constraints of the law. In this IRP, however, Dominion asked a different question: how to make Gov. Glenn Youngkin happy by keeping fossil fuels dominant regardless of both law and cost.

Coming up with a favorable answer required Dominion to ignore the Virginia Clean Economy Act (VCEA), create arbitrary limits on solar deployment, use wishful thinking instead of facts and, for good measure, do basic math wrong. They also assume the Youngkin administration will succeed in pulling Virginia out of the carbon-cutting Regional Greenhouse Gas Initiative (RGGI), a move that is being challenged in court. This makes Dominion’s IRP, with its plan to double carbon emissions, a sort of evil twin to a plan from any RGGI state.

Sure enough, the governor loves it. Elsewhere, however, this evil twin found a cold reception. Experts retained by environmental, consumer and industry groups all agree that this IRP should be chucked in the trash bin and Dominion told to start over.

It’s worth taking a look at the testimony from these groups to understand where Dominion went so badly wrong, and what a better plan might look like.

It’s all about the data centers

Northern Virginia data centers are the driving force behind Dominion’s plans to burn more coal and gas, but there is some disagreement whether their growth will be absolutely off-the-charts crazy, or merely eye-poppingly huge. Dominion’s IRP projects the data center industry’s power use in its territory will quadruple over the next 15 years, rising from 2,767 megawatts (MW) in 2022 to more than 11,000 MW in 2038. At that point it would represent close to 40% of Dominion’s load.

Experts testifying in the IRP case believe data center demand won’t reach the dizzying heights Dominion projects. They question whether Virginia communities will accept so much new data center development, given the pushback already evident in localities like Prince William and Fauquier Counties. Their thinking is essentially that if things can’t go on this way, they probably won’t.

They also suggest that some of the demand Dominion expects may also be reflected in the plans of other utilities serving Northern Virginia’s Data Center Alley, leading to double-counting. A load forecast published by grid operator PJM shows that Northern Virginia Electric Cooperative (NOVEC) projects its data center demand to rise from about 400 MW in 2022 to 4,000 by 2028 and 8,000 by 2034. Two other cooperatives project a combined 3,000 MW of data center development in the same time period.

Aside from data centers, demand for electricity in Dominion territory is flat or declining over the next fifteen years; presumably this is due to the increased efficiency of homes and businesses offsetting the increased demand from electric vehicles and building electrification.

If you were already experiencing vertigo over Dominion’s data center numbers, and you are now hearing for the first time that Dominion’s numbers represent only half of the total projected data center load coming to Virginia, maybe you won’t find it all that cheering that some of that added demand could be illusory. Still, it is a reasonable point. If you reduce demand by a few thousand megawatts here and there, pretty soon you might not “need” a new gas plant.

As an aside, one Virginia utility stands out for apparently not expecting much in the way of new data centers in its territory. Appalachian Power, which serves customers in Southwest Virginia, West Virginia and Tennessee, has experienced declining demand for years, and rural Virginia leaders would dearly love to see data centers come there. Yet the PJM forecast shows Appalachian Power’s parent company, American Electric Power (AEP), told grid operators it expected only about another 200 MW on top of the 500 MW of data center load it serves across its entire 11-state territory. AEP seems to regard this as quite a lot, which, when compared with what is happening in Northern Virginia, seems rather sweet.

I can’t help but wonder how Gov. Youngkin managed to make a deal with Amazon to bring $35 billion worth of new data centers to Virginia without securing a guarantee that many of the facilities would be located in a part of the state that actually has surplus energy capacity and desperately needs new economic development. Southwest Virginia voters may have put Youngkin in office; you’d think he’d be looking out for them.

Instead of real investment today, Youngkin promises the area a little nuclear plant a decade from now, when and if small modular reactors (SMRs) prove viable. Local leaders must be muttering, “Gee, thanks.”

And this leads to another point raised by several of the experts in the IRP case: All of the load growth Dominion projects is due to a single industry in Northern Virginia; elsewhere, demand is decreasing. Yet, instead of crafting a solution specific to the industry and region experiencing runaway growth, Dominion proposes to build a fossil fuel plant 140 miles away in Chesterfield and a nuclear plant 300 miles away in another utility’s territory.

Gregory Abbott, a former SCC Deputy Director, offers a particularly withering assessment of the IRP in his testimony on behalf of environmental advocacy group Appalachian Voices. Dominion’s computer model, he says, “is proposing supply-side solutions that are not focused on solving the actual problem, are likely unnecessary, and driving costs higher than they should be.”

Although Dominion insists this IRP represents just a “snapshot in time,” Abbott says that’s misleading: The IRP “sets the stage for multi-billion-dollar investments that Dominion’s customers will pay for decades to come. If a future snapshot in time changes, based on new public policy goals or market dynamics, ratepayers are stuck with paying for these sunk costs.”

Garbage in, garbage out

Abbott and others also note that unlike factories or other high consumers of energy, data center operators can shift some functions to other data centers elsewhere for short periods of time. Dominion could save money and reduce the need for new investments by capitalizing on this capability to develop demand-response programs tailored specifically to this industry.

Instead, Dominion treated the surge in demand as if it were statewide and spread across all its customers; then it used a computer model to figure out how to meet the soaring demand.

An expert for the Sierra Club, Devi Glick of Synapse Energy Economics, noted several problems with Dominion’s approach. Among them: the company told its computer model that it couldn’t select energy efficiency as a resource; it had to include gas combustion turbines in 2028; it had to adhere to artificial limits on solar, wind and battery storage; and it had to assume prices for solar that were “substantially higher than industry projections.” Dominion also did not instruct the model to account for proposed (and since finalized) new federal pollution limits that will raise the cost of burning fossil fuels, and miscalculated — by a billion dollars — the penalties associated with failure to meet the VCEA’s renewable energy requirements.

As they say, garbage in, garbage out. The model did what it was told, and produced plans that limited solar and battery storage, called for new gas combustion turbines and/or SMRs, and kept uneconomic coal plants running past their previously-planned retirement dates. Accordingly, none of the modeled scenarios complied with Virginia law and all would be unnecessarily expensive for customers.

Synapse ran its own computer model that kept most of Dominion’s load and cost assumptions but corrected for the company’s errors and artificial constraints. The results, not surprisingly, show that building more solar and storage and retiring coal plants earlier than Dominion wants to will lower carbon emissions and “reduce costs for Dominion’s ratepayers by between $4.1 and $9.0 billion over the 25-year study period.”

When Synapse then tweaked the model to reflect the new federal pollution rules and prices for solar and battery storage in line with industry projections, the results saw solar and battery investments soaring, while the “need” for firm capacity such as a new gas plant disappeared altogether during the planning period.

Clean energy, vindicated

So finally, we begin to see a path forward founded on real data and not constrained by political expediency. With none of its plans meeting the basic requirements of Virginia law, Dominion should be ordered to go back to the drawing board. The company should reexamine its data center load projections and design a demand-response program tailored to that industry. Then it should re-run its computer model with energy efficiency allowed as a resource, with no artificial constraints on battery storage and renewable energy,with federal and state compliance costs associated with fossil fuels fully included and with cost estimates for solar and storage consistent with industry norms.

The General Assembly has a role to play, too, in ensuring the data center industry does not shift costs onto other customers and cause Virginia to fall short of its carbon reduction goals. Data centers should be required to meet energy efficiency targets and to secure an increasing percentage of renewable energy on their own as a condition of obtaining generous state tax subsidies. Likewise, the State Corporation Commission should be required to ensure that data centers pay for the transmission upgrades they need. Finally, the General Assembly should pass the data center study bill adopted by the Senate this year before being killed in the House.

Finally, it’s clear that the computer models will select as much low-cost solar as they are allowed to, so the General Assembly should make it easier to build solar projects at competitive rates. They can do this by further opening the market to third-party developers, who are currently constrained by an interpretation of the VCEA that caps their share of the solar Dominion procures at 35%.

The SCC will hold a hearing on the IRP beginning September 18.

An earlier version of this article appeared in the Virginia Mercury on September 5, 2023.

Why are Dominion Energy’s customers footing the bill for Virginia’s data center buildout?

August 17, 2023 by Ivy Main

Dominion Energy headquarters, Richmond, VA

Virginia’s embrace of the data center industry produced new fallout this spring when Dominion Energy Virginia released its latest Integrated Resource Plan (IRP). With data center growth the “key driver,” Dominion projects a massive increase in the demand for electricity. As a result, the utility claims the state-mandated transition to clean energy is now impossible to achieve.

Jettisoning its commitment to the Virginia Clean Economy Act (VCEA), Dominion proposes to keep running uneconomic coal and biomass plants that were previously slated for closure, build a new fossil gas plant and pay penalties instead of meeting state renewable energy targets, all of which mean higher costs for customers.

As I said at the time, this IRP is primarily a political document aimed at currying favor with a gas-loving governor. It is not a serious plan. For example, a Sierra Club filing with the State Corporation Commission describes how Dominion put artificial constraints into its computer modeling (including limits on new solar) to ensure the plan came out fossil-friendly. Moreover, Dominion’s demand projections are inflated, according to the clean energy industry group Advanced Energy United.

But for the sake of discussion, let’s take the IRP at face value. And in that case, I have some questions. How did Dominion let itself get blindsided by the data center growth spurt? Why are the rest of us expected to pay for infrastructure that’s only needed for data centers? Does the Governor understand that his deal to bring another $35 billion worth of new Amazon data centers to Virginia is driving up energy rates for everyone else?

Oh, and while I’m at it, are tech company commitments to sourcing renewable energy just a pack of lies?

Virginia’s data center problem is well known. Northern Virginia has the largest concentration of data centers in the world, by far. Data centers are Dominion’s single largest category of commercial power users, already consuming more than 21% of total electricity supply and slated to hit 50% by 2038. In addition to the new generation that will be required, data centers need grid upgrades including new transmission lines, transformers and breakers, with the costs spread to all ratepayers.

Residents are not happy. Controversy around data centers’ diesel generators, their water use, noise and visual impacts have spread outward from Loudoun County into Prince William, Fauquier, and even other parts of Virginia as massive new developments are proposed.

Data center developers don’t build without assurance they will have access to the huge amount of electricity they need for their operations, so they have to start discussions with their utility early. Yet in July of 2022, Dominion stunned the data center industry by warning it would not be able to meet new demand in Loudoun County until 2025 or 2026. The utility said, however, that the problem was not generating capacity, but transmission. So, what gives?

Not that it would be better if Dominion anticipated the oncoming tsunami but kept it secret until this spring. You have to wonder whether the General Assembly would have approved hundreds of millions of dollars in grants and tax subsidies for new Amazon data centers in February if legislators understood the effect would be to upend the VCEA and drive up energy costs for residents.

Some Republicans are no doubt pleased that Dominion’s IRP undermines the VCEA, but they shouldn’t be. Dominion proposes keeping coal plants open not for economic reasons, but in spite of them. These plants were slated for closure in previous IRPs because they were costing ratepayers too much money. Now Dominion says it needs more generating capacity and can’t (or rather, won’t) build enough low-cost solar to keep up with new data center demand.

Dominion also proposes to build a new methane gas combustion “peaker” plant that wasn’t in its last IRP, and again the company points to data center growth as the reason. Peaker plants are an expensive way to generate power; on average, the cost of energy from gas combustion is about double that of a solar/storage combination, or even triple once you factor in federal clean energy incentives.

Keeping the fossil fuel party going instead of embracing more solar isn’t the only way this IRP drives rates higher for customers. Limiting its solar investments means Dominion expects to miss the VCEA’s renewable energy percentage targets by a mile. The shortfall would subject Dominion to significant penalties. The kicker is, Dominion can pass the cost of those penalties on to ratepayers, too.

Regardless of your political persuasion, then, this IRP is bad news for Virginia consumers.

It’s also concerning that the driver of all these higher costs and carbon emissions is the high-tech industry that is so eager to be seen as a leader in sustainability. If these tech companies were meeting their power needs with renewable energy, Dominion wouldn’t be able to claim a “need” to keep its old coal plants belching away.

Amazon, the number one beneficiary of state data center largesse, says it is the leading corporate purchaser of renewable energy globally. Its website claims the company is “on a path to powering our operations with 100% renewable energy by 2025.” A map shows it has developed around 16 solar projects in Virginia, adding up to over 1,100 megawatts. That’s great, but the company’s Virginia data centers are such energy hogs that they would need many times as much solar, plus a huge amount of battery storage to meet their 24/7 demand. And of course, Amazon’s demand will skyrocket with that next $35 billion in new data centers.

That same map, by the way, shows that Amazon has on-site solar at warehouses and Whole Foods stores all over the Northeast, but none in Virginia. Northeastern states have higher commercial power rates than Virginia does, so on-site solar means bigger bill savings in those states. One cannot help but suspect that Amazon’s commitment to renewable energy is really just a commitment to cheap energy.

The Data Center Coalition’s filing in the IRP case does nothing to reassure us otherwise. Instead of chiding Dominion for reneging on its clean energy commitments, the Coalition’s Josh Levi essentially argues data centers are so important it doesn’t matter.

I have no beef with data centers as a general proposition. They are an integral component of today’s economy, and the developments that now drive their explosive growth — machine learning and artificial intelligence — will also help us achieve a zero-carbon future.

I just think data centers should try a little harder to be part of the solution instead of part of the problem.

This article was first published in the Virginia Mercury on August 16, 2023.

Law? What law? Pandering to the governor, Dominion’s new plan ignores Virginia’s climate law

May 15, 2023 by Ivy Main

Last December, Dominion Energy produced a remarkable document: a climate report predicting that by 2040 its electricity supply will be dominated by renewable energy. Coal will be gone by 2030, and methane gas will hang around in ever-smaller amounts, just to fill in the energy gaps. Small modular nuclear reactors (SMRs) probably won’t play a role for at least 15 years, during which time solar will become the mainstay of the electricity supply. According to the report, this strategy will allow Dominion to meet its goal of becoming carbon-neutral by 2050.

Fast forward a few months, and the same company, using the same information, projects a future full of new methane-burning plants and SMRs. Dominion Energy Virginia’s 2023 Integrated Resource Plan (IRP), released May 1, now insists that the phenomenal growth of the data center industry and, to a lesser degree, the adoption of electric vehicles require so much energy that it can’t possibly meet legally-mandated climate goals. Accordingly, the plan doesn’t even try.

Instead of decarbonizing in accordance with Virginia’s role in the Regional Greenhouse Gas Initiative (RGGI) and the requirements of the Virginia Clean Economy Act (VCEA), Dominion now says it must build new methane-burning plants and keep old, expensive coal plants running “beyond statutory retirement deadlines established in the VCEA.” All the alternatives examined in the IRP “assume that Virginia exits the Regional Greenhouse Gas Initiative (‘RGGI’) before January 1, 2024,” in violation of Virginia law. Most of the alternatives include the same SMRs its Climate Report recognized as unready. Compared to Dominion’s 2022 IRP update (filed just last September!), now costs have ballooned and CO2 emissions will skyrocket.

What could possibly have happened in the course of a few months to produce this about-face? The astounding growth projections for the data center industry may be news to many Virginians, but not to the utility that provides their power. Vehicle electrification is hardly a surprise either. SMRs did not achieve any breakthroughs in technology or economics this winter, nor did anyone suddenly discover a way for new gas plants to make sense for the climate or ratepayers. Dominion makes a big deal out of the Christmas cold snap, but you have to try pretty hard to believe that requires upending all previous planning.

What did happen was the 2023 General Assembly session, in which Gov. Glenn Youngkin played a decisive role in handing Dominion a major – and unaccustomed – defeat. With Dominion Energy holding its shareholder meeting today, the company badly needs to show it is back in the governor’s good graces. And the governor, as we know, is not a fan of the energy transition.

In other words, the IRP is a political document, not a serious approach to meeting Virginia’s electricity needs, at a time when climate change is accelerating and fossil fuels are giving way to superior renewable energy technologies.

Market watchers will recall that Dominion’s stock price tanked in the fall of 2022, losing more than 30% of its value from August to November. So the company came up with a bill that would have increased the profit margin for its Virginia utility from 9.35% to 10.77%. This number was calculated to improve Dominion’s standing on Wall Street but would cost consumers an extra $4 billion, according to the State Corporation Commission’s estimate. The company also expected to be able to defeat pro-consumer legislation that would return more authority over rates to the SCC.

Dominion’s bill was widely panned, but that hardly made it a non-starter. In past years, the company has gotten what it wanted more often than not, thanks to powerful friends like Senate Majority Leader Dick Saslaw, D-Fairfax, and House Majority Leader Terry Kilgore, R-Scott. This is the beauty of doing business in a state that allows corporations, even public utilities, to supply unlimited campaign donations to elected officials. Over the years, Dominion’s contributions to Republican Kilgore nearly match its contributions to Democrat Saslaw. Most other General Assembly members get contributions from Dominion, too, helping to cement bipartisan support for the company’s priorities.

As the patrons of this year’s money bill, Saslaw and Kilgore should have been able to deliver enough votes from members of both parties to ensure a profitable outcome for their biggest campaign donor. They were not counting on the governor poking holes in the plan.

Dominion’s beating this year grew from seeds it sowed in 2021. That year, Dominion made a bad bet on Democrat Terry MacAuliffe to win the governorship, secretly funding a dark money group to run ads attacking Youngkin.

This year, Youngkin took his revenge. As a Wall Street guy himself, he knows how to hit a corporation where it hurts.

Youngkin forced Dominion to accept changes to the bill that increase the company’s return on equity modestly (and only temporarily), but take away other avenues of profit. Adding insult to injury, the General Assembly also adopted the pro-consumer legislation that allows the SCC to set “fair and reasonable” rates in the future.

Dominion declared itself satisfied with the result, but Wall Street judged otherwise. The company’s stock, which had started to rally in January, reached a ten-year low this spring.

Aside from punishing Dominion, the governor achieved none of his energy goals in the legislative session. Rolling back the VCEA, exiting RGGI through legislation, reversing the Clean Car Standard — none of that happened. And as long as the Democrats keep control of at least one chamber in the General Assembly in this fall’s election, none of that is likely to happen.

So Dominion’s IRP violates Virginia’s laws and the public’s trust (such as it is), makes a mockery of its own climate plan and proposes “solutions” that will drive up both costs and carbon emissions. As a plan, it can’t be taken seriously.

All that, however, is beside the point. It makes the governor happy. And what makes the governor happy, Dominion hopes, will make its shareholders happy.

That assumes the shareholders don’t care about climate change, or that they hold values that are as malleable as those of Dominion CEO Bob Blue and the rest of the company’s leadership.

Climate change? What climate change?

An earlier version of this article was published in the Virginia Mercury on May 10, 2023.

It’s time for Virginia to plan its next offshore wind farm

April 11, 2023 by Ivy Main

Virginia’s first commercial offshore wind farm is on track to start construction next year and to be fully operational in 2026. The Coastal Virginia Offshore Wind (CVOW) project being developed by Dominion Energy will be the single largest offshore wind farm in the U.S. and among the first full-scale commercial wind projects built in U.S. waters.

Yet it has taken us 10 years to get this far. Future projects will have shorter timelines now that the industry is gaining its footing and government bodies have figured out how to regulate it. Even so, the complexity of planning, permitting and building giant wind turbines 25 miles out in the ocean means Virginia needs to start planning the next project now to ensure that the supply chain businesses that have located here, and the workers we are training to build CVOW, still have reason to remain in Virginia come 2027.

For most Virginians, offshore wind may still feel experimental because it has produced only two small projects in the U.S.: a 5-turbine wind farm off of Rhode Island’s Block Island built in 2016 and a two-turbine pilot project 27 miles out from Virginia Beach that started generating power in 2020. But at least 30 other projects are underway up and down the East Coast, including one currently under construction off Massachusetts and another off of New York that will begin construction this year. Plans are also underway for wind farms in the Great Lakes, off the West Coast and in the Gulf of Mexico.

Together these projects add up to more than 53,000 megawatts (MW), exceeding the Biden Administration’s 30,000 MW by 2030 goal – enough to power 10 million homes with clean, renewable energy. According to the U.S. Department of Energy, independent forecasts show that goal to be solidly realistic. The U.S. offshore wind industry itself recently announced a longer-term target of 110,000 MW, reflecting the business community’s expectations for growth.

The industry is also far more mature in other parts of the world. Global capacity passed the 50,000 MW milestone last year, and the global pipeline stands at more than 368,000 MW. (Surprise, surprise: China is eating our lunch, installing 13,790 MW in 2021 alone.)

Perhaps the most compelling evidence for the promise of the offshore wind industry in the U.S. is the size of industry events. In the course of a dozen years, U.S. offshore wind conferences have gone from gatherings of a few hundred academics, environmentalists and entrepreneurs in a hotel ballroom to the nearly 4,000 business people and hundreds of exhibitors who packed the Baltimore convention center at the end of March for the Business Network for Offshore Wind’s International Offshore Wind Partnering Forum (IPF).

Often the governor of a state hosting one of these annual conferences uses the occasion to unveil new goals or infrastructure investments; Maryland Gov. Wes Moore did not miss his chance this year. He announced that Maryland plans to develop 8,500 MW once the federal Bureau of Ocean Energy Management makes new lease areas available, a goal behind only New Jersey’s 11,000 MW target and New York’s 9,000 MW. Virginia’s goal begins to look cautious by comparison.

The industry does face challenges. Inflation and supply chain issues have disrupted timelines and threatened profitability. There aren’t enough workers. Transmission constraints hinder the ability to get power to customers. Permitting is a pain in the neck. Here in the mid-Atlantic, it’s hard to identify new areas of the ocean suitable for wind farms, in large part because the Department of Defense wants it all for itself.

Other challenges are more of the good kind, such as the fact that wind turbine sizes are increasing faster than ships capable of transporting and installing them can be built. Larger turbines mean more power at less cost, and no one is quite sure what the upper size limit might be. On land, the difficulty of transporting blades that can be the length of a football field means turbines are limited to about 3 MW. Fabricating parts at coastal facilities allows turbines to scale up as far as physics and advanced material manufacturing allow.

Dominion installed 6-MW turbines for its pilot project, which was seen as the new standard a few years ago. Today the company plans to use 15-MW turbines. Each one of these massive turbines is said to produce enough energy to power 20,000 European households. I have not seen that figure translated into U.S. suburban McMansions, but it is still an eye-popping amount of emissions-free power from a single structure.

Oh, and Dominion handled the installation ship issue by building its own vessel, which it will rent out for the Massachusetts and New York projects until it is needed for Virginia’s and others in the queue. Problem solved, at least for Virginia, though the industry needs many more ships.

Will the cost of energy come down?

Virginia’s CVOW project has been criticized for its high overall cost, largely the result of our immature domestic industry. The Biden Administration has set a goal to lower costs by one-third by 2030. If history is any indication, this should be readily achievable. A National Renewable Energy Laboratory (NREL) analysis shows costs have fallen by more than half since 2016, and projects that by 2030, the levelized cost of energy from offshore wind turbines will fall by another third.

Scaling up turbines to capture more wind energy is one approach to bringing the per-kilowatt-hour price down. Economies of scale, a U.S. supply chain, and a range of innovative technologies are all expected to contribute. And of course, the Inflation Reduction Act, with its tax credits for domestic manufacturing and renewable energy, is creating a gold rush of sorts, as companies compete to get a piece of the action.

Another significant factor in reducing costs is automation and machine learning. Some of the gains are incremental, such as optimizing turbine operation and improving turbine siting through improved wind and wake modeling. Other advances seem like windows into a future where robots take charge. Multiple exhibitor booths at IPF displayed crewless, self-piloting survey and depth-monitoring vessels and underwater robots capable of doing more tasks than humans can. Biologists and geologists stay comfortably ashore while on-board computers collect information at sea around the clock and send the data back.

Today’s innovation will inform the next great leap forward for the industry: floating wind turbines that open deep water to energy production. Right now, floating turbines must be tethered to the seafloor and connected to cables to bring power to shore. For various reasons this technology is more expensive than fixed-foundation turbines, but here, too, the industry expects to become competitive in the future.

Some people are thinking much bigger. Walt Musial, a principal engineer at NREL who is one of the top researchers in the field, gave an IPF audience a look into the future. There, automation and AI could make it possible for unmoored, cableless turbines to pilot themselves around the oceans, chasing the best winds, avoiding hurricanes and turning electricity into liquid fuels like ammonia to drop off at ports of call or offshore “energy islands.” Musial even referred to these turbines as “vessels,” evoking a whole new kind of wind-powered transportation.

A display at the Business Network for Offshore Wind’s IPF conference exhibits an autonomous wind turbine that could contribute to the nation’s future wind energy capacity. (Ivy Main/The Virginia Mercury)

It’s a great time for workers entering the industry — if you can find them

Though un-crewed, AI-directed traveling wind turbines may be the future, the present still requires foundations, cables, service vessels and, especially, a large workforce. Attracting and training an offshore wind workforce has become such an urgent issue that the topic earned its own track at IPF.

To its credit, this heavily male, heavily white-dominated industry says it is committed to recruiting a diverse workforce and ensuring equitable development of offshore wind, also a goal of the Biden Administration. It will have to; right now, no one has enough workers, so finding them means recruiting from overlooked communities and addressing the social and economic barriers that have kept many people out of the skilled labor force.

While not new to other large infrastructure projects, Community Benefit Agreements with detailed commitments covering local job creation and other investments, are new for offshore wind. Dominion has not entered any such agreement in Virginia, but as part of its case before the State Corporation Commission last fall in which it received permission to proceed with CVOW, the company signed a stipulation agreeing to an extensive and diverse community outreach program. Eileen Woll, Offshore Energy Program Director for the Sierra Club’s Virginia Chapter, told me Dominion is following through on this pledge.

Woll is also part of a task force made up of academic and community groups from the Hampton Roads area that has developed a plan for community engagement and outreach to identify potential workers from harder-to-reach demographic groups. She told me the “Breaking Barriers” project team has applied for a $500,000 grant from the U.S. Department of Energy to fund their work.

Halting steps towards Virginia’s next project

The Virginia Clean Economy Act made special provision for Dominion’s CVOW project as part of an overall target of 5,200 MW. If CVOW makes up 2,600 MW, where will the rest come from? A project under development off Kitty Hawk, North Carolina, would connect to the grid in Virginia Beach, but Dominion has shown no interest in buying the power; nor has Duke Energy. Dominion makes more money acting as its own developer. Huge energy users like the data centers operated by Amazon Web Services in Virginia could absorb all the energy from several Kitty Hawks, but Amazon hasn’t stepped up either.

Meanwhile, the federal Bureau of Ocean Energy Management (BOEM) has identified 1.7 million acres offshore North Carolina, Virginia, Maryland and Delaware with potential for new leasing. The challenge is to make space for wind in an area already claimed by fishing interests, the Coast Guard, and the Department of Defense. If Virginia leaders are serious about building an enduring offshore wind industry here, they will have to engage in some tough negotiations.

For his part, Gov. Glenn Youngkin seems to be trying to ensure that the next Virginia project will be subject to competitive bidding to avoid a repeat of the process that made Dominion Energy the sole developer and holder of the only Virginia lease area. The governor amended an offshore wind bill from Sen. Mamie Locke, D-Hampton, that was something of a nothingburger as passed by the General Assembly. Youngkin’s amendment turns the legislation into a plan requiring Dominion to work with the State Corporation Commission and other government agencies on a competitive solicitation process for the next offshore wind project.

There is no guarantee that this will work, given that BOEM awards leases to high bidders. But if BOEM offers multiple wind energy areas for lease near Virginia, and awards the leases to multiple developers, then an SCC-led competitive process seems feasible, with a better result for consumers.

The governor’s language may have been inspired by a House bill from Del. Suhas Subramanyam, D-Loudoun, that would have had the SCC study the ownership structure of offshore wind projects and report on how to achieve the best outcome for consumers. Republicans killed that bill, but presumably they will be more open to promoting competition when the idea comes from their own party.

The General Assembly will consider the governor’s amendment when it reconvenes on April 12. Let’s hope his amendment indicates that Youngkin is ready and willing to start the next phase of Virginia’s offshore wind industry.

This article was originally published in the Virginia Mercury on April 10, 2023.

Is your electricity bill keeping you in the dark?

March 17, 2023 by Ivy Main

A seemingly simple question came across my desk a few weeks ago: What does Dominion Energy Virginia charge residents per kilowatt-hour (kWh)? Given how frequently I write about Dominion, I was embarrassed not to have a quick answer. In my own defense, though, Dominion makes it hard to find out. And when you do find out, the answer is, it depends.

Examine a recent bill, and you will see the number of kilowatt-hours you used in the preceding month, a confusing list of charges and the dollar amount that you owe. You can do the math to figure out what you paid this month per kilowatt-hour, but that’s more of a snapshot than the whole picture.

*A Fairfax resident’s Mar. 6, 2023 Dominion Energy electricity bill. (Ivy Main/The Virginia Mercury)*

I asked colleagues to send me their utility bills to see what people were actually paying, and I got out my calculator. Everyone’s rate was different, and the more electricity they used, the less they paid per kWh. Even after I removed state and local taxes from the equation, rates ranged from a low of 12.2 cents per kWh for a home that used 2930 kWh in February, to a high of 17.3 cents for a home that, thanks to solar panels, drew just 179 kWh from the grid in the same time period.

As that solar home shows, the flat rate of the basic customer charge skews the average price higher. That basic charge is currently $6.58 per month, according to Dominion’s residential rate schedule, but you won’t see it on your bill.

The rate schedule reveals other information your bill doesn’t tell you, and that’s where the real impact lies: you pay less per kWh, in both generation and distribution charges, for the electricity you use in excess of 800 kilowatts per month from October through May. From June to September, you pay less in distribution charges for every kilowatt over 800, but more in generation charges.

You’re also charged a single rate year-round for transmission, which is different from distribution. Plus, every kilowatt-hour is subject to a list of riders – “charges applied to certain rate schedules to recover various costs associated with Dominion Energy’s electric operations and electricity production,” according to Dominion – and non-bypassable charges. The rate schedule doesn’t identify these charges, but the bill does, albeit with no explanation for how the amounts are determined. Your bill also lists fuel as a separate charge under Electricity Supply, though fuel does not appear in the rate schedule.

Still with me? No? All of this must make sense to the State Corporation Commission, which approved the rate schedule, but it is thoroughly opaque to customers.

The sufficiently dogged can find a worksheet on Dominion’s website that breaks out all these costs. If you plug in the month and a number of kWh you used, it will calculate a bill. You still need to do the math yourself to arrive at the price per kWh, but you can then play with numbers to see how usage affects rates.

Doing that confirms what I saw in my colleagues’ bills. Assuming 1,000 kWh, the number Dominion uses to represent the “typical” customer, the price works out to 14 cents in winter. Change that to a frugal 500 kWh and you get 15 cents. Raise it to 2,000 kWh, and it goes down to about 13 cents.

When challenged about this in the past, Dominion justified its buy-more, pay-less winter rate structure by arguing it was needed to make bills affordable for customers with electric heating, whose use can double or triple in the wintertime. The company didn’t mention that it also benefits wealthier people with large homes, and decreases the incentive for customers to conserve energy.

It also turns out that large homes do well in summer, too. According to the worksheet, a customer using 1,000 kWh in June would pay 14.6 cents per kWh. For 2,000 kWh, it rises slightly to 14.7 cents. The customer who uses only 500 kWh pays the highest rate, at 15 cents. Energy efficiency, alas, is not rewarded.

So Dominion’s bills aren’t just confusing, they mask a perverse incentive in the rate structure that rewards people who use more electricity. This year’s utility legislation changes a lot of things, but it doesn’t require greater clarity in billing, nor does it fix that upside-down incentive.

All utility bills are not equal

This perverse incentive is shared by some other Virginia utilities, though not all, and not all hide the ball the way Dominion does. Appalachian Power’s website shows it charges a single rate no matter how much you use. There’s neither a price break nor a penalty for higher consumption. The website provides two examples, for customers using 1,000 and 2,000 kWh, respectively. This makes it easy to calculate what you’re paying per kWh (about 16.5 cents), though you won’t find that number on either the website or the bills themselves. But neither the bill nor APCo’s website mentions the existence or amount of the basic customer charge, which can only be inferred from the website examples.

I also looked at February bills sent me by customers of Northern Virginia Electric Cooperative (NOVEC) and Rappahannock Electric Cooperative (REC). In both cases the bills were easy to understand. They identify the flat monthly charge, though in both cases the charge is unfortunately more than twice as high as Dominion’s. The bills also list the rates applicable per kWh for generation, transmission and distribution. Both utilities give a year-round volume discount on the distribution charge for higher levels of usage, another regrettable feature. However, REC’s SCC filing shows it imposes a higher electricity supply charge in summer for monthly usage over 800 kWh. I could not find current information about NOVEC’s rates online; I hope its customers have better access.

Being able to understand your electric bill matters. Virginia’s average residential rates increased 20% between December 2021 and December 2022, according to the U.S. Energy Information Agency, mostly due to last year’s spike in the price of methane gas and coal. Even before last year, our bills were higher than those in most other states.

Consumers have an array of options to help them lower their energy costs, including new federal and state programs and incentives for weatherization, energy efficient appliances and renewable energy. But customers who are confused about what they currently pay are less likely to act.

For the same reason, utility rate structures should incentivize customers to take steps that conserve energy. Lower rates for using more electricity undercut the value of investments in energy efficiency.

If utilities want to help their customers, they can start by sending the right message.

This article was originally published in the Virginia Mercury on March 16, 2023.

A dog, a food fight and other highlights from the 2023 General Assembly session

March 3, 2023 by Ivy Main

Cartoon describes Amazon replacing Dominion as the major political power in Virginia

For followers of Virginia energy policy, 2023 will be remembered as the year Dominion Energy lost its stranglehold on the General Assembly. The utility’s all-out campaign to boost its return on equity earned it little more than crumbs. By contrast, a bill to return authority over rates to the State Corporation Commission garnered overwhelming support.

Another surprise loser was the nuclear industry. Gov. Youngkin and boosters of small modular reactors (SMRs) expected a lot more love, and incentives, than legislators proved willing to dole out this early in the technology’s development.

Less noticed was the rise to political power of one of Dominion’s largest customers, Amazon Web Services. Many legislators may still not have caught on, but the corps of lobbyists who haunt the hallways of the General Assembly building know a 500-pound gorilla when they see one. As one lobbyist put it: “Amazon is the new Dominion.”

These are the standout takeaways from a legislative session in which, otherwise, few significant energy bills emerged from the scrum. Senate Democrats ably protected the energy transition framework established in 2020 and 2021, but modest efforts to accelerate the transition mostly failed. Of the roughly 60 bills I followed this session, only a handful made it to the governor’s desk.

Republican attacks on the energy transition failed

The three foundational bills of Virginia’s energy transition — the Regional Greenhouse Gas Initiative (RGGI), the Virginia Clean Economy Act (VCEA) and Clean Cars — all came under attack this year, as they did last year. And again, repeal efforts failed every time.

Senate Democrats blocked the one bill that would have pulled Virginia out of RGGI. Gov. Youngkin remains bent on achieving the pullout by regulation through Department of Environmental Quality rulemaking.

In the transportation sector, every bill to repeal the Air Pollution Control Board’s authority to implement the Advanced Clean Car Standard failed in the Senate as Democrats held the line.

Efforts to undermine key parts of the VCEA failed, including House and Senate bills that would have given the State Corporation Commission more authority over closures of fossil fuel plants and require it to conduct annual reviews designed to second-guess the VCEA’s framework for lowering emissions and building renewable energy.

A House bill that would have exempted certain industrial customers categorized as “energy-intensive trade-exposed industries” from paying their share of the VCEA’s costs passed the House on a party-line basis. However, with the bill facing certain death in Senate Commerce and Labor, patron Lee Ware, R-Powhatan, requested it be stricken. At the time, he had reason to expect that a compromise approach proposed by Sen. Jeremy McPike, D-Prince William, would pass. McPike’s bill would have had the SCC put together a group of experts to study the issue and make recommendations. After passing the Senate, however, McPike’s study bill went to House Energy and Commerce, which insisted on amending it to mirror Del. Ware’s bill. That did not go over well in the Senate, where the House substitute was unanimously rejected. McPike then asked the Senate to kill his own bill, and the energy-intensive trade-exposed industries got nothing.

Raids on the VCEA produced mixed results

One of the VCEA’s strengths is in creating incentives for clean energy. That’s also a vulnerability, because everybody and their brother wants in on the incentives — and this year, once again, the brothers came peddling some pretty sketchy stuff.

In the end, however, the VCEA sustained little damage. An effort to open up the renewable energy category to coal mine methane was modified to become simply a policy to encourage the beneficial capture and use of methane that would otherwise escape from old coal mines into the air. However, methane extraction jobs in four Southwest Virginia counties will now qualify for a “green jobs” tax credit.

More successful was an effort by the forestry industry to allow more woody biomass to qualify for the renewable portfolio standard (RPS); this was in spite of drawbacks including high levels of pollution, expense and large climate impact. As passed, the House and Senate bills will allow Dominion-owned biomass plants to remain open and have their output qualify for the RPS, so long as they burn only waste wood from forestry operations. Climate advocates opposed the change, but remain hopeful that Dominion and the SCC will want to close these uneconomic biomass plants to protect ratepayers.

Two different House bills that tried to shoehorn nuclear and hydrogen into the RPS failed in the Senate. A third bill promoting small modular nuclear reactors (SMRs) got more traction initially; it would have had the SCC develop a pilot program for SMRs with a goal of having the first one operational by 2032. After it passed the House, the Senate Commerce and Labor committee adopted amendments to require the SCC to examine the cost of any SMRss relative to alternatives, and to prevent ratepayers from being charged for the costs if an SMR never became operational. The Senate voted unanimously for the bill with these protections included, but the House rejected them. Ultimately, the bill died, a remarkable setback for the governor’s nuclear ambitions.

Utility reform consumed most of the session (again)

Dominion’s money grabs have turned into near-annual food fights. This one almost wrecked the cafeteria.

The action proceeded along two fronts. One consisted of bipartisan, pro-consumer House and Senate legislation promoted as the Affordable Energy Act, intended to return ratemaking authority to the SCC. As passed, it merely authorizes the SCC to modify Dominion’s or Appalachian Power’s base rates going forward, if it determines that current rates will produce revenues outside the utility’s authorized rate of return. If that strikes you as hard to argue with, you’re not alone; no one in either chamber voted against it.

Far more divisive was Dominion’s own effort to secure an increased rate of return on equity (ROE). This legislation earned its own bipartisan support from Dominion loyalists, led by Senate Majority Leader Dick Saslaw, D-Fairfax, for the Senate bill and House Majority Leader Terry Kilgore, R-Scott, for the House bill.

As initially drafted, it probably should have been called the Unaffordable Energy Act instead of the reassuringly bureaucratic-sounding Virginia Electric Utility Regulation Act. The bill described a formula for determining Dominion’s allowed ROE that SCC staff calculated could result in an ROE as high as 11.57%, up from the currently-allowed 9.35%. SCC staff told legislators this could cost ratepayers $4 billion through 2040. In return, the bill offered some near-term savings for customers but also would have removed the last vestige of retail competition and opened VCEA coal plant retirement commitments to second-guessing by the SCC.

Dominion pulled out all the stops. The company supplemented its own in-house lobbying corps of 13 with another 17 top lobbyists from around Richmond. Former senator John Watkins signed on, as did former FERC commissioner Bernard McNamee. CEO Bob Blue showed up personally to push the bill. Dominion ran full-page ads in the Washington Post and Virginia newspapers touting a provision of the bill that would save ratepayers $300 million (neglecting to mention that it was the ratepayers’ own money). The ad featured a dog so people could be sure Dominion was being friendly.

It didn’t work. The consumer advocates hung tough, and Gov. Youngkin, possibly a cat person, added his weight to the resistance. As the Mercury reported, the “compromise” that all parties now swear they are delighted with gives Dominion very little kibble. The coal plants will be retired on schedule, ratepayers will see savings and a larger percentage of over earnings will be returned to customers in the future. In exchange, Dominion’s future return on equity will be bumped up to 9.7%, but only for two years, after which the SCC will have discretion to set the ROE as it deems fair. (That is, if Dominion doesn’t start the next food fight first.)

Appalachian Power had its own troubles this session. APCo-only legislationthat would have replaced the requirement for an integrated resource plan with an “annual true-up review” was radically amended to become an entirely different bill. It now allows both utilities to finance the high fuel costs they’ve incurred due to soaring natural gas and coal prices. The amendments were welcomed both as a way to handle the fuel debt and so that no one had to figure out what a true-up review is. The bills passed handily.

One other successful piece of legislation may help avoid future food fights. Sen. Scott Surovell, D-Fairfax, and Del. Kilgore worked together to resuscitate the Commission on Electric Utility Regulation (CEUR) and create more transparency around utility planning. The original bill also created a structure for state energy planning, but that proved too much for House Republicans, who amended it down to the lean bill that passed.

Over the years CEUR earned a bad reputation as an entity that rarely met but that served as an excuse for legislators to defer action on pro-consumer bills. That makes advocates somewhat wary of this bill. On the other hand, provisions welcoming stakeholders into the utility integrated resource planning process seems likely to benefit the public, if not the utilities.

Elsewhere, consumers did poorly

Dominion may have taken a drubbing on its money grab, but it did pretty well in guarding its monopoly. The Dominion-friendly Senate Commerce and Labor committee killed a bill to allow customers to buy renewable energy at a competitive rate from a provider other than their own utility. Bills to expand shared solar passed the Senate but died in the House.

Indeed, the House turned into a killing field for any bill with the word “solar” in it, no matter how innocuous or popular. A House Rules subcommittee killed a bill that would have helped schools take advantage of onsite solar, though it had passed the Senate unanimously. A resolution to study barriers to local government investments in clean energy was left in House Rules. A bill to create a solar and economic development fund passed the Senate but was tabled in House Appropriations. A resolution directing the Department of Transportation to study the idea of putting solar panels in highway medians never got a hearing in House Rules. A consumer-protection effort for buyers of rooftop solar was tabled in House Commerce and Energy. A bill clarifying the legality of solar leases passed the Senate unanimously, only to be left in House Commerce and Energy.

Do we detect a little frustration on the part of House Republicans at the complete failure of their anti-clean energy agenda? Why, yes. Yes, we do.

The only pro-consumer legislation to pass was a very modest bill requiring the SCC to establish annual energy efficiency savings targets for Dominion customers who are low-income, elderly, disabled or veterans of military service. But legislation that would have made homeowners eligible for low-cost loans through property-assessed clean energy (PACE) programs failed.

Offshore wind remains on track

Dominion beat back an effort to make it hold ratepayers harmless if its Coastal Virginia Offshore Wind project fails to produce as much energy as expected. A bill to allow the company to create an affiliate to secure financing for the project passed.

Legislation to move up the VCEA’s deadline for offshore wind farm construction from 2034 to 2032 passed; the law now also requires that the SCC consider economic and job creation benefits to Virginia in overseeing cost recovery. However, a bill that would have required the SCC to issue annual reports on the progress of CVOW failed. That bill would also have required the SCC to analyze alternative ownership structures that might save ratepayers money.

The gas ban ban fails again

This year’s attempt to bar local governments from prohibiting new gas connections passed the House on a party-line vote but was killed in Senate Commerce and Labor. A Senate companion bill from Democrat Joe Morrissey, which had caused something of a tizzy initially, was stricken at Morrissey’s request.

And this year’s big winner is … Amazon!

With data centers now making up over 21% of Dominion’s load and since they have already sucked up over a billion dollars in tax subsidies, this should have been the year Virginia government woke up to the need for state oversight of the industry. Alas, no. Bills that would limit where data centers could be sited failed. Senate legislation that would have simply tasked the Department of Energy with studying the impact of data centers passed the Senate on a voice vote but was killed in a subcommittee of House Rules on a 3-2 vote, the same fate suffered by a similar House bill.

Who could be against studying the impact of an industry this big? Aside from the data center industry that is enjoying the handouts, the answer is the Youngkin administration. The governor is so pleased with Amazon’s plan to spend $35 billion on more data centers across Virginia that he promised the company even greater handouts.

Those handouts take the form of a bill creating the Cloud Computing Cluster Infrastructure Grant Fund, with parameters that ensure only Amazon gets $165 million. In addition, the far more impactful sales and use tax exemption, currently set to expire in 2035, will be continued out to 2040 with an option to go to 2050; again, this is all just for Amazon, unless some other company manages to pony up $35 billion in data center investments. In return, Amazon must create a total of just 1,000 new jobs across the entire commonwealth, and only 100 of them must pay “at least one and a half times the prevailing wage.” A jobs bill, this is not.

With the sales and use tax exemption already costing Virginia $130 million per year and growing rapidly, this legislation will be very costly. You would not know it, though, from the budget analysis performed for legislators. Through the magic of accounting rules, that analysis managed to conclude that the budget impact of this legislation would be zero.

As preposterous as that is, it may explain why only a few legislators voted against the bill. They have no idea what the governor is getting us into.

Attacks on Virginia’s climate laws are front and center at the General Assembly

January 19, 2023 by Ivy Main

People gathered in a square listening to speakers. — Climate advocates gathered at the Virginia Capitol on Friday to defend Virginia’s clean energy laws. Speakers included Senators Creigh Deeds, Ghazala Hashmi, David Marsden and Scott Surovell, and Delegates Rip Sullivan, Nadarius Clark, Rodney Willett and Alfonso Lopez. Photo courtesy of Mary-Stuart Torbeck, Virginia Sierra Club.

Every year I do a round-up of climate and energy bills at the start of the General Assembly session. This year, as expected, Republicans continue their assault on the hallmark legislation passed in 2020 and 2021 committing Virginia to a zero-carbon economy by 2050. In addition, this year features the usual assortment of bills doing favors for special interests, efforts to help residents and local governments go solar and a brand-new money and power grab by Dominion Energy.

Republicans are not down with the energy transition

Dominion Energy may have baked the transition to renewables into its planning, but unsurprisingly, the Virginia Republican Party thinks the fight to preserve fossil fuel dependence is a winning issue. The three foundational bills of Virginia’s energy transition — the Regional Greenhouse Gas Initiative (RGGI), the Virginia Clean Economy Act (VCEA) and Clean Cars — all come in for attack, either by outright repeal or death-by-a-thousand-cuts.

Senate Bill 1001 (Richard Stuart, R-Westmoreland) would repeal the Clean Energy and Community Flood Preparedness Act, the statute that propelled Virginia into the Regional Greenhouse Gas Initiative. Participation in RGGI is the vehicle by which utilities buy allowances to emit carbon pollution. Under RGGI, the number of allowances available declines every year, and Virginia’s power sector would reduce CO2 emissions 30% by 2030. The allowance auctions have already raised hundreds of millions of dollars that by law must be used for low-income energy efficiency programs and flood resilience projects. A similar bill failed last year, and Senate Democrats have pledged to block the effort again. Meanwhile, Gov. Glenn Youngkin is trying to withdraw Virginia from RGGI administratively, a move that former Attorney General Mark Herring ruled wasn’t legal.

Carbon allowance auctions are a foundational piece of the VCEA as well, but it is a much bigger law that touches on too many aspects of energy regulation for repeal of the whole thing. This isn’t stopping Republicans from trying to undermine key provisions. House Bill 2130 (Tony Wilt, R-Rockingham) and Senate Bill 1125 (Travis Hackworth, R-Tazewell) would give the State Corporation Commission more authority over closures of fossil fuel plants and require it to conduct annual reviews aimed at second-guessing the VCEA’s framework for lowering emissions and building renewable energy. Achieving the VCEA’s climate goals is decidedly not the purpose; meanwhile, the legislation would remove business certainty and undercut utility planning.

Other attacks on the VCEA take the form of favors for specific industries, but would effectively make the VCEA’s goal of reaching 100% carbon-free electricity by 2050 at the least cost to consumers impossible. I’ve dealt separately with small modular reactors, hydrogen and coal mine methane below.

In addition, House Bill 1430 and House Bill 1480 (Lee Ware, R-Powhatan) exempt certain industrial customers categorized as “energy-intensive trade-exposed industries” from paying costs that the VCEA makes all customers pay. The exemption would last four years. The result would be nice for those industries but would shift costs onto everyone else. The bill seems likely to pass the House, but the same bill last year died in the Senate. However, Senate Bill 1454 (Jeremy McPike, D-Prince William) proposes the SCC put together a group of experts to study the issue and make recommendations.

In the transportation sector, no fewer than seven bills sought to repeal the Air Pollution Control Board’s authority to implement the Advanced Clean Car Standard: House Bill 1372 (Buddy Fowler, R-Hanover), House Bill 1378 (Wilt), Senate Bill 778 (Stuart), Senate Bill 779 (Stephen Newman, R-Bedford), Senate Bill 781 (Bill DeSteph, R-Virginia Beach), Senate Bill 782 (Bryce Reeves, R-Fredericksburg) and Senate Bill 785 (Ryan McDougle, R-Hanover). The Senate bills were killed in committee on Tuesday. The House bills are likely to pass that Republican-led chamber, but it appears clear that Senate Democrats intend to hang fast to Clean Cars.

Although so many identical bills might look like a failure of legislators to coordinate efforts, in fact the senators all signed on as co-patrons to each other’s bills, along with a dozen House Republicans. Republicans think they have a winning issue for the November election, and lots of them want to claim they filed “the” legislation attempting to repeal Clean Cars.

Raiding the store for polluter interests

If the VCEA is here to stay, there are some decidedly non-green industries that want to claim the green mantle to get in on the action. It’s not about making themselves feel better about their high greenhouse gas emissions. It’s about getting a piece of the market for renewable energy certificates and undermining the integrity of the renewable energy label.

House Bill 1643 (Terry Kilgore, R-Scott) and Senate Bill 1121 (Hackworth) proclaim coal mine methane a renewable energy. House Bill 2178 (James Morefield, R-Tazewell) makes coal mine methane a qualifying industry for Virginia’s green job creation tax credit.

Burning wood for electricity produces as much CO2 as coal, at a cost much higher than solar energy today. Yet House Bill 2026 (Israel O’Quinn, R-Bristol) and Senate Bill 1231 (Lynwood Lewis, D-Accomack) remove the requirement in the VCEA for the retirement of Dominion’s generating facilities that burn wood for electricity and allow these generating plants to qualify as renewable energy sources.

SMRs and hydrogen

Speaking of raiding the store, House Bill 2197 (Kathy Byron, R-Bedford) allows “advanced nuclear technology” to qualify for Virginia’s renewable portfolio standard (RPS). The bill defines the term as “a small modular reactor or other technology for generating nuclear energy,” which looks like an opening for existing nuclear plants as well. Even if it isn’t, treating any kind of nuclear technology as a renewable resource upsets the VCEA’s calibrated approach to nuclear as a zero-carbon technology alongside renewable energy, not in place of it.

House Bill 2311 (Kilgore) goes a step further, declaring both nuclear and hydrogen to be renewable energy sources and making them eligible for the RPS. Hydrogen, of course, is a fuel made from other sources of energy, which can be renewable but are more typically fossil fuels currently. Given Youngkin’s interest in seeing hydrogen made from coal mine methane, you can see where this is headed.

House Bill 2333 (Danny Marshall, R-Danville) calls on the SCC to develop a pilot program to support building small modular nuclear reactors, with a goal of having the first one operational by 2032. In spite of the word “pilot,” the bill is ambitious. It contemplates four sites, each of which can have multiple reactors of up to 400 megawatts each.

Utility reform

Some of these bills are reform bills; some are “reform” bills. To recognize the difference, it helps to know whether the proponent is a public interest organization or the utility itself. When Dominion tells you it has a bill you’re going to love, you can be pretty sure the result will be bad for ratepayers.

Senate Bill 1321 (Jennifer McClellan, D-Richmond, and Creigh Deeds, D-Charlottesville) and House Bill 1604 (Ware), billed as the Affordable Energy Act, is real reform legislation that gives the SCC authority to lower a utility’s base rates if it determines that existing rates produce “unreasonable revenues in excess of the utility’s authorized rate of return.”

Other straightforward measures include House Bill 2267 (Wilt) and Senate Bill 1417 (David Suetterlein, R-Roanoke), which allow the SCC to decide to add the cost of a new utility generation project into base rates instead of granting a rate adjustment clause (RAC), and House Bill 1670 (Marshall), which returns rate reviews to every two years instead of the current three years.

Dominion, however, has its own “reform” bill, introduced by its favorite Democratic Senate and Republican House leaders. As is typical for Dominion, Senate Bill 1265 (Dick Saslaw, D-Fairfax) and House Bill 1770 (Kilgore) is long, dense and deadly effective in crushing competition and protecting profits. The bitter pill is sugarcoated with short-term rebates and concessions to minor reform proposals, such as biennial rate reviews in place of triennial reviews and consolidating many RACs into base rates. A somewhat less objectionable substitute moved forward in Senate subcommittee this week, but further negotiations are expected to produce yet more changes.

The warring factions may be able to find common ground in House Bill 2275 (Kilgore) and Senate Bill 1166 (Scott Surovell, D-Fairfax), legislation creating a structure for state energy planning.

House Bill 1777 (O’Quinn) and Senate Bill 1075 (Frank Ruff, R-Mecklenburg) change how the SCC regulates rates of Appalachian Power – but not Dominion. They require the SCC to conduct “annual rate true-up reviews (ART reviews) of the rates, terms and conditions for generation and distribution services” by March 31, 2025 and annually after. They also remove the requirement for an integrated resource plan.

Retail choice

Past years have seen efforts to restore the ability of customers to buy renewable energy from providers other than their own utilities, an important option for a resident or business that wants to buy renewable energy at a competitive rate. Senate Bill 1419 (Suetterlein) marks at least the fourth year in a row for this effort. A Senate subcommittee voted against it this week.

Dominion’s “reform” bill, on the other hand, clamps down further on retail choice. In light of Youngkin’s support for retail choice in his energy plan, it is interesting to see Republicans like Kilgore instead enabling Dominion’s anticompetitive efforts.

solar panels on a school roof — Wilson Middle School, Augusta County. Photo courtesy of Secure Futures.

Goosing investments in solar and efficiency

With the passage of the federal Inflation Reduction Act last summer, renewable energy and energy efficiency tax credits are more generous and easier to access than ever before. Senate Bill 848 (Barbara Favola, D-Arlington) and House Bill 1852 (Suhas Subramanyam, D-Loudoun) direct the Commission on School Construction and Modernization to figure out how to help schools take full advantage of onsite solar.

House Joint Resolution 545 (Briana Sewell, D-Prince William) directs the Department of Energy to study barriers to clean energy investments by localities and their residents and issue recommendations to help.

Senate Bill 1333 (Ghazala Hashmi, D-Richmond) creates a program within the Department of Energy to be known as the Commonwealth Solar and Economic Development Program. The program will implement solar, energy efficiency and other economic development projects in specified census tracts.

Senate Bill 1323 (McClellan) requires the SCC to establish for Dominion Energy Virginia annual energy efficiency savings targets for customers who are low-income, elderly, disabled or veterans of military service.

Senate Bill 984 (Monty Mason, D-Williamsburg) clarifies that lease arrangements for onsite solar are legal, whether or not they’re net metered, including when battery storage is part of the project. (For context: Leasing has always been an option for onsite solar, but the IRA has increased interest in this approach. It is considered especially attractive for residential projects that, except when the customer is low-income, are barred by Virginia law from using third-party power purchase agreements.) The bill also ensures owners can be paid for grid services using the facilities. Another welcome provision of the bill is removing standby charges for residential customers who have batteries along with their solar panels. Currently, residents with systems over 15 kW must pay hefty standby charges.

House Joint Resolution 487 (Marshall) directs the Department of Transportation to study the idea of putting solar panels in highway medians.

Meanwhile, House Bill 2355 (Jackie Glass, D-Norfolk) is a consumer-protection effort for buyers of rooftop solar and other small arrays, who have sometimes been the victims of unscrupulous companies that overcharge and under-deliver.

Shared solar

Virginia has been wading into community solar like a child at the seashore, dipping a toe in and then running away again and again, without ever truly entering the water. A 2020 law establishing a “shared solar” program in Dominion territory was supposed to get us swimming. At the SCC, however, Dominion won the right to impose such a high minimum bill as to make the program unworkable for any but low-income customers, who are exempt from the minimum bill.

Senate Bill 1266 (Surovell) attempts to address the problems with the shared solar program in Dominion territory. Surovell was the author of the 2020 law and criticized the SCC’s action for making shared solar unavailable to anyone other than low-income residents. His approach would limit the minimum bill to more than twice the basic customer charge, while also increasing the size of the program to at least 10% of the utility’s peak load and allowing non-jurisdictional customers like local governments to participate.

Senate Bill 1083 (Edwards and Surovell) creates a shared solar program in Appalachian Power territory. It builds on the framework of the existing program in Dominion territory, but the minimum bill is limited to $20. It also seeks to prevent the interconnection problems that industry members have complained about by limiting costs and requirements to those “consistent with generally accepted industry practices in markets with significant penetration levels of distributed generation.”

On the House side, House Bill 1853 (Suhas Subramanyam, D-Loudoun) combines both Senate bills into one bill that addresses both Dominion and Appalachian Power. For both, it limits the minimum bill to two times the basic customer charge, and it includes the interconnection language.

Offshore wind

Senate Bill 1441 (Mamie Locke, D-Hampton) moves up the VCEA’s deadline for offshore wind farm construction from 2034 to 2024, a change I don’t understand at all, given that the current timeline calls for completion of the Coastal Virginia Offshore Wind Project (CVOW) in 2026. The bill also requires that when Dominion seeks cost recovery, the SCC must give preference “for generating facilities utilizing energy derived from offshore wind that maximize economic benefits to the Commonwealth, such as benefits arising from the construction and operation of such facilities and the manufacture of wind turbine generator components.” I look forward to learning what’s behind that, too.

Senate Bill 1854 (Subramanyam) seeks annual reports from the SCC on the progress of CVOW, including “the status and the anticipated environmental impacts and benefits of such projects” that “analyze the current and projected capital costs and consumer rate impacts associated with such projects.” It also wants “an analysis of the ownership structure chosen by an electric utility for previously approved wind energy projects and the costs, benefits, and risks for consumers associated with utility-owned and third-party-owned projects.” This analysis would compare the Virginia project with other U.S. projects, potentially a useful analytical tool for the next offshore wind project that comes along.

House Bill 1797 (Nick Freitas, R-Culpeper) declares that ratepayers will be held harmless if CVOW’s annual net capacity factor falls below 42% as measured on a three-year rolling average. The capacity factor is the average output of the wind turbines as a percentage of their full potential. In its filing with the SCC, Dominion projected CVOW would hit that 42% mark. If wind speeds turn out to be stronger than projected, the turbines will produce more energy at a lower cost. If the wind (or the machinery) doesn’t meet expectations, the capacity factor will be lower and costs will be higher. The bill would make Dominion absorb the loss in that event. However, the SCC did just resolve this issue in a way that takes account of both ratepayer interests and the newness of the technology, making it unlikely that many legislators will want to revisit this topic.

Senate Bill 1477 (Lewis) allows Dominion, subject to SCC approval, to create an affiliated company to build some or all of its offshore wind project, with the purpose of having the affiliate secure equity financing.

House Bill 2444 (Bloxom) moves up the timeline for Virginia offshore wind projects under the VCEA from 2034 to 2032 (I wonder if this is what Senator Locke’s bill was supposed to say). It also requires the SCC to give preference to requests for cost recovery by Dominion for “generating facilities utilizing energy derived from offshore wind that maximize economic benefits to the Commonwealth.” I don’t understand if this is intended to discourage Dominion from pursuing projects off the shores of other states, or if it is a poorly-worded way to support in-state manufacturing of components.

Residential PACE

Senate Bill 949 (Petersen) makes homeowners eligible for property-assessed clean energy (PACE) programs, which provide low-cost financing for energy efficiency and renewable energy upgrades. Currently PACE loans are only available to commercial customers.

Data centers

Virginia has a data center problem. Northern Virginia hosts the largest concentration of data centers in the world, and the energy they consume now amounts to 21% of Dominion’s load. This growth has happened with no state oversight; indeed, it’s been goosed by a billion dollars’ worth of state tax incentives over the past decade. Meeting the energy demand of data centers requires more generation and more transmission lines, usually paid for by all utility customers.

Senate Joint Resolution 240 (Chap Petersen, D-Fairfax), and House Joint Resolution 522 (Danica Roem, D-Manassas) task the Department of Energy with studying data centers’ impact on Virginia’s environment, energy supply, electricity rates and ability to meet climate targets. The bills also ask for recommendations on whether tax incentives should be conditioned on use of renewable energy or on meeting siting criteria.

Both Roem and Petersen also have bills that deal with specific siting issues, mostly unrelated to energy. Senate Bill 1078 (Petersen) limits areas where data centers can be sited (e.g., not near parks and battlefields, a barb likely aimed at the Prince William Gateway project). However, it also requires localities to conduct site assessments for impacts on carbon emissions as well as water resources and agriculture.

Meanwhile, though, legislators seem determined to increase taxpayer handouts to data centers. Following Governor Youngkin’s announcement about Amazon’s plans to invest billions of dollars in new data centers in Virginia, Delegate Barry Knight (R-Virginia Beach) filed House Bill 2479, creating the Cloud Computing Cluster Infrastructure Grant Fund to throw more money at a corporation that seems likely to have more money already than Virginia does.

Return of the gas ban ban

Last year the natural gas industry tried to get a law passed to ban localities from prohibiting gas connections in new buildings. Some cities in other states have done that to protect the health and safety of residents and protect the climate; meanwhile, about 20 red states have passed laws to prevent their local governments from doing it. But no Virginia locality has attempted to ban gas connections, in part because as a Dillon Rule state, our local governments don’t appear to have that authority. That isn’t stopping the gas industry from seeking to ban bans here; House Bill 1783 (O’Quinn) and Senate Bill 1485 (Morrissey) would do just that. Obnoxiously, it calls the right to use gas “energy justice,” which is surely the best reason to oppose it.

A version of this article appeared in the Virginia Mercury on January 18, 2023.

Update January 19: Two new bills have been added since yesterday. Senator Morrissey filed SB1485 (gas ban ban), and Senator Lewis filed SB1477 (Dominion offshore wind affiliate).

Update January 23: Delegate Bloxom filed HB2444, added to the offshore wind section above. Delegate Knight filed HB2479, a bill to enrich Amazon; see data centers.

Dominion Energy says solar will dominate by 2040

January 9, 2023 by Ivy Main

When the Virginia General Assembly convenes this week for the 2023 session, Republicans will once again try to undo the commonwealth’s framework for a transition to renewable energy. Led by Gov. Glenn Youngkin, they will attack Virginia’s participation in the Regional Greenhouse Gas Initiative and the Virginia Clean Economy Act (VCEA) and continue seeking ways to keep a money-losing coal plant in Wise County in operation.

Meanwhile, Virginia’s largest utility has already decided that renewable energy, especially solar, is the future. Dominion Energy’s just-released Climate Report 2022 projects that under every set of assumptions modeled, solar energy will become the mainstay of its electricity generation fleet no later than 2040.

As for coal, it disappears from the energy mix by 2030 even in a scenario that assumes no change from present policy, in spite of the fact that the VCEA allows the Wise County coal plant to operate until 2045. As for fracked gas, it hangs on longer but in ever-smaller amounts, mostly to help meet winter peak demand.

Dominion modeled three scenarios for this report. The “current policy” scenario assumes the policy landscape and technology options stay the same as they are presently, and that Dominion does its part in driving a global temperature increase of 2.1°C by 2050. That’s in keeping with Virginia’s climate law, and also with Dominion’s internal commitment to achieve net-zero emissions by 2050.

That much warming is not a good outcome, considering the climate chaos the planet is experiencing today with barely over 1 degree of warming. Yet even under a 2.1°C scenario, Dominion’s model predicts solar energy will provide 40% of the electricity supply by 2040, followed by nuclear at 30% and (offshore) wind at 19%.

The “emerging technologies” scenario also assumes a temperature increase of 2.1°C by 2050, but adjusts for the likelihood that technological change will lead to “advanced dispatchable zero-carbon technology” options that could displace much of the need for energy storage. These might include hydrogen, carbon sequestration and storage, and methane gas produced as the result of poor animal waste disposal practices at factory farms — what Dominion calls renewable natural gas, or RNG.

Small modular reactors, SMRs, are not included in this scenario (and are hardly mentioned at all in the report), perhaps because operating them as peaker plants would be crazy expensive. Even without SMRs, though, the report says overall cost savings would be slight for this scenario, and solar would still be the leading source of electricity by 2040.

Finally, the report models an “accelerated transition” scenario that reduces emissions more aggressively, in line with an effort to keep the global temperature increase to 1.5°C by 2050. This is the upper bound of warming considered tolerable by many climate scientists, but it would require Dominion’s electricity business to reach net zero by 2035. Dominion’s model shows solar would make up nearly two-thirds of the electric supply in that scenario. Offshore wind would be held to just 17%, apparently because at that point more wouldn’t be needed.

I’d argue that offshore wind should carry more of the load to create a more balanced portfolio, but it’s a moot point: The report writers clearly think this scenario is just a thought exercise. The scenario consistent with keeping global warming to 1.5°C is described in a way that seems intended to discourage anyone from pursuing the matter.

“The heavier reliance on renewable capacity in this scenario,” it warns, “would require significantly greater capital investment at a much more rapid pace in preparation for a net zero mix by 2035. … Achieving such a rapid pace of emissions reductions would require predictable, dependable, and rapid wholesale shifts in public policy and technology advancements capable of maintaining system reliability and customer affordability. Also necessary would be supportive regulatory treatment and timely permitting for significant near-term zero-carbon infrastructure development and transmission system enhancements.”

In other words, the report seems to say, fuggedaboutit. It’s just too hard.

If that feels defeatist, it’s worth remembering how far Dominion has come to reach a point where it is even writing climate reports, not to mention declaring on page 1 that “climate change presents one of the greatest challenges of our time, and we take seriously our leadership role in helping to mitigate it.”

This is new, and you have to look back only a decade to appreciate how radical this declaration is. When 2013 opened, Dominion had just completed construction of that regrettable coal plant in Wise County and had begun a fracked gas plant building spree that would continue even after solar emerged as the cheapest source of new electricity in Virginia. Climate activists like myself were dismissed when we warned that new gas plants would be reduced to giant concrete paperweights well before the end of their design life, leaving ratepayers paying off stranded assets.

Even in 2016, when now-CEO Bob Blue was president of Dominion Virginia Power, Blue was proclaiming natural gas “the new default fuel” for electric generation. As late as the spring of 2020, the company’s integrated resource plan still called for building more gas plants. That plan acknowledged the strategy would violate Virginia’s new climate law, so it argued against the law.

Yet I suspect Blue may deserve credit for the remarkable about-face at Dominion beginning in 2020. That summer Dominion Energy began significantly reducing its investments in fossil gas outside of the electric sector, scrapping plans for the Atlantic Coast Pipeline and selling off its gas transmission and storage assets. That year it also sold half of its interest in the Cove Point liquified natural gas export facility. It is reportedly considering selling the other half now as part of what Blue called in November “a ‘top-to-bottom’ business review aimed at ensuring that it is best positioned to generate substantial long-term value for shareholders.”

Maybe Blue got religion on climate, maybe he’s just a savvy businessman. It’s a really good sign of the times that you can’t always tell the difference.

But of course, Dominion is stuck with a heck of a lot of gas generating plants that it has to justify post hoc, which helps to explain its lack of enthusiasm for the 1.5°C scenario. Another part of the explanation lies in Dominion’s remaining gas investments outside the electric sector. Although Dominion Energy Virginia is solely an electric utility and does not supply gas to retail customers in Virginia, a separate Dominion Energy subsidiary sells gas in other states. So far these assets don’t seem to be going the way of the gas transmission business and Cove Point.

Dominion’s climate report tries valiantly to justify holding onto its retail gas business. The report declares, “Natural gas is also part of our long-term vision and consistent with our Net Zero commitment.”

Sure, and the Tooth Fairy is real. Of the greenhouse gas reduction approaches cited — fixing leaks, making “renewable” methane from waste products, blending hydrogen into pipelines, and using creative carbon accounting with “offsets” — none make sense either economically or from a climate standpoint.

Maybe he cares about climate, but apparently Blue doesn’t want to give up yet on a profitable business. Fortunately, at least for the planet, the retail gas business is about to enter a terminal decline as homes and businesses electrify. Getting out now would be the smart move from both the business and climate perspective.

Because what will eventually power all these homes, no matter which scenario you choose? Renewable energy, and especially solar.

This article was originally published in the Virginia Mercury on January 6, 2023.

Shared solar launches in Virginia but still faces an uphill battle

November 30, 2022 by Ivy Main

Wildflowers in front of solar panels illustrate pollinator plantings around solar panels — Photo credit Center for Pollinators in Energy, fresh-energy.org

After years of wrangling, Virginia finally allows certain customers of Dominion Energy Virginia to buy solar energy from independent providers of shared solar, also known as community solar.

Don’t applaud yet, though. Dominion has used the rulemaking process and its control over project interconnection to create hurdles for shared solar that lawmakers never anticipated. High minimum bills, prolonged interconnection study requirements and expensive equipment demands are stalling projects and could drive away all but the most tenacious developers.

The blow that received the most attention came during the rulemaking process. The State Corporation Commission decided Dominion could impose a minimum bill averaging $55 per month on most customers. The minimum bill is added to the cost of the electricity itself, making shared solar so expensive that the program simply won’t be offered to the general public.

However, lawmakers had included a provision exempting low- to moderate-income (LMI) participants from the minimum bill requirement. In effect, then, the SCC’s order turned the shared solar program into a program just for LMI residents.

Indeed, the first shared solar project for LMI Virginians launched on Nov. 9 in Dumfries as a partnership between community solar developer Dimension Renewable Energy and low-income housing provider Community Housing Partners. Subscribers are told to expect savings of 10% on their electricity bills. The partners are signing up participants now but have not broken ground on a solar facility to serve them.

Sen. Scott Surovell, D-Fairfax, the author of the law creating the shared solar program, attended the launch of Dimension’s project to share in the celebration. But he still believes the program should be available to everyone. He confirmed to me he is working with the community solar industry to develop legislation addressing the minimum bill problem.

Surovell says he continues to think a minimum bill is necessary; the question is what fee is “commercially feasible to community solar programs” while still capturing “a fair amount of system costs and legacy expenses” borne by Dominion in providing service to participants when the solar facility isn’t generating electricity.

Interconnection woes: delays, high costs and ‘dark fiber’

Even if Surovell can thread that needle, the minimum bill is only the most visible problem facing shared solar in Dominion’s territory. The solar facilities have to connect to the grid, which puts Dominion in charge of the interconnection process. Developers say they are encountering long delays, high costs and unreasonable equipment requirements.

Earlier this year, the State Corporation Commission opened a docket to solicit feedback on the interconnection process — and the result was an outpouring of complaints.

As described in comments from the solar industry, Dominion requires cost-prohibitive “dark fiber” for grid protection in place of a much less expensive industry-standard approach. Dominion also lags in conducting the studies that every new project proposal must undergo at the developer’s cost, resulting in timelines that stretch 16 months or more. Additional facilities that would use the same substation aren’t considered until the study process for the first one is complete, creating further delays.

Developers also aren’t told until the final stage how much Dominion expects to charge them to interconnect their array — and even then, Dominion adds a disclaimer that its estimate is not binding. That uncertainty, says the industry, makes projects hard to finance and risky for developers.

These inefficiencies and unnecessary expenses drive up project costs and make distributed solar more expensive for customers, when it is possible at all. Tony Smith, president of solar developer Secure Futures, told me his company wanted to build a 1 megawatt shared solar facility to serve LMI customers in Augusta County. They secured the site and permits before learning that Dominion would require dark fiber and planned to charge them $1 million for the interconnection, an amount so high as to scuttle the project.

(For context, solar industry estimates put the entire cost of developing community-scale solar at an average of $1.4 million per megawatt.)

Smith says larger projects may be able to absorb exorbitant interconnection fees, but smaller projects cannot. In any case, high interconnection costs inevitably mean higher costs for customers.

Industry comments note areas where Dominion has tried to resolve issues, in particular to speed up the study timelines. But regarding other requirements, particularly those that impose the highest costs, the utility shows little willingness to budge. In some instances, the company even seems to be using its interconnection power to make private developers shoulder its own grid upgrade costs. It’s hard not to suspect that Dominion is perfectly happy making other people’s solar projects more expensive.

The solar industry’s brief describes steps taken in other states to make the process fairer, faster and less expensive. But if the staff report of the Division of Public Utility Regulation is any indication, the SCC is more likely to take a slower approach involving working groups, pilot studies and a multistep process. Smith says all this will take many years, by which time shared solar developers will have given up on Virginia and taken their business to friendlier states. He’d like to see the General Assembly address the worst problems.

Surovell says he has “heard about” the interconnection issues but “ha(s)n’t focused on it yet.” Charlie Coggeshall, mid-Atlantic director of the Coalition for Community Solar Access, told me that “interconnection is a hurdle for shared solar in Virginia and absolutely in need of improvements,” but said his organization is focused on the SCC process and for now has no plans to pursue a legislative fix.

Dominion serves about two-thirds of Virginia customers, so solving the minimum bill and interconnection problems would open shared solar to a broad swath of residents across the state. That still leaves out the other third. Advocates hope to expand the availability of shared solar into Appalachian Power territory and that of Virginia’s electric cooperatives.

A few co-ops launched their own community solar programs pre-pandemic, but most don’t offer one and apparently don’t want to. As for Appalachian Power, it has consistently opposed community solar, saying it can’t afford to lose customers. (On the other hand, Appalachian Power does not require installation of dark fiber as a condition of interconnection, in that respect making it friendlier to distributed generation — just not shared solar projects.)

Multifamily shared solar scores a win, regardless of income level

Apartment building with solar panels on the roof. — An apartment building in the Bronx. Under the multifamily shared solar program, apartment buildings in Virginia could host solar arrays for the benefit of tenants. Photo by Bright Power Inc. via Wikimedia.

While shared solar faces an uphill battle, some good news came in a second case implementing a related program, this one authorized by 2020’s Solar Freedom legislation and designed for onsite solar at apartment buildings and condominiums. The multifamily shared solar (MFSS) program makes it possible for a landlord or condo association to install a solar facility to serve just its own residents. This program occupies a middle ground between community solar and net metering, and the enabling legislation allows Dominion to impose an administrative fee but not a minimum bill or any other charges.

Early on, the SCC had indicated a willingness to allow Dominion to shoehorn the components of the shared solar law’s minimum bill into the MFSS administrative fee. That would have certainly been the end of the program right there. In its final order, however, a common-sense definition of “administrative fee” prevailed, and the SCC ruled that Dominion could not stuff its costs of doing business into the fee.

The SCC still set the MFSS administrative fee at a curiously high $13.40 per month, accepting Dominion’s argument that it would have to do all this billing manually. The SCC also decided customers should pay certain “non-bypassable charges” amounting to an average of about $3 per month. The law doesn’t authorize these charges, but the SCC reasoned that it doesn’t prohibit them, either.

Even with Dominion taking $16 or so, the economics would not seem prohibitive. Developers caution, however, that the limited subscriber base for any MFSS project makes this program difficult to work with, even if the building is large and the property can accommodate a fair-sized solar facility. And even onsite solar arrays aren’t necessarily immune to interconnection woes.

Still, there is plenty of customer interest in the multifamily program, especially from condominium associations that may be able to finance the projects themselves. With any luck, they will pave the way for others to follow.

This article first appeared in the Virginia Mercury on November 29, 2022.

You call that an energy plan?

October 20, 2022 by Ivy Main

Protesters outside the Virginia Clean Energy Summit on October 21.

Governor Glenn Youngkin issued a press release on October 3 presenting what he says is his energy plan. Accompanying the press release was 26 pages labeled “2022 Virginia Energy Plan,” but that can’t be what he’s referring to. I mean, the Virginia Code is pretty specific about what makes up an energy plan, and this isn’t it.

Under Virginia law, the energy plan must identify steps the state will take over the next 10 years consistent with the Commonwealth Clean Energy Policy’s goal of a net-zero carbon economy by 2045 “in all sectors, including the electric power, transportation, industrial, agricultural, building, and infrastructure sectors.” Not only does Youngkin’s document not do that, it doesn’t even mention the policy it’s supposed to implement.

It’s also missing critical pieces. The plan is supposed to include a statewide inventory of greenhouse gas emissions, but it’s nowhere to be found. The inventory is the responsibility of the Department of Environmental Quality, which reports previous inventories on its website from 2005, 2010 and 2018. The one specifically required to be completed by October 1, 2022 isn’t there, nor is there any indication it’s in the works and just unfortunately delayed. Did I miss some fine print about how the requirement doesn’t apply if the governor is a Republican?

In fact, there is no discussion about climate change in Youngkin’s energy plan. The word “climate” appears nowhere. He simply ignores the problem: a modern Nero, fiddling while the planet burns.

Instead, Youngkin’s document mostly attacks the laws Virginia has passed in recent years to implement its decarbonization goals, including the Virginia Clean Economy Act, legislation allowing the state to participate in the Regional Greenhouse Gas Initiative and the Clean Cars law. In their place he offers a bunch of random ideas — some with merit, some without, some spinning off on tangents.

I did not really expect a conservative Republican with presidential aspirations to embrace all the recommendations for the energy plan that I laid out last month, or those from the many environmental, faith and consumer groups that support Virginia’s clean energy transition. Going further and faster down the road to decarbonization is a tall order for politicians beholden to fossil fuel interests, no matter how much it would benefit the public.

Yet Youngkin doesn’t have a lot of ammunition to use against the switch to renewable energy. With soaring coal and natural gas prices, it’s hard to keep pretending that fossil fuels are low-cost. The insistence that we need them for reliability is the only straw left to grasp at.

https://www.virginiamercury.com/blog-va/regulators-approve-dominion-bill-increase-for-rising-fuel-costs-appalachian-power-also-seeking-hike/embed/#?secret=Vd8muOhz01

And indeed, underlying Younkin’s attack on the VCEA is a misunderstanding of how grid operators manage electricity. The critique boils down to “baseload good, intermittent bad.” But baseload is not the point; meeting demand is the point. Demand fluctuates hugely by day and hour. If grid operators had nothing to work with but slow-ramping coal plants or on/off nuclear reactors and no storage, they’d have as much trouble matching demand as if they had nothing but renewable energy and no storage. Pairing low-cost wind and solar with batteries makes them dispatchable — that is, better than baseload.

That’s not to say there aren’t good reasons to invest in higher-cost resources, but “baseload” is a red herring that stinks up Youngkin’s entire argument.

To his credit — and notwithstanding his “baseload” fixation — Youngkin supports Virginia’s move into offshore wind energy even with the high cost of the Coastal Virginia Offshore Wind project and other early U.S. developments. (The plan notes that Virginia’s project will be the largest “in the Free World,” a weirdly retro way to tell us China has leapt far ahead in installing offshore wind.)

The plan also supports removing barriers to customer purchases of solar energy, including shared solar and a greater ability for renewable energy suppliers to compete with utilities for retail sales. This is all phrased as a consumer choice issue rather than an endorsement of greater utility investments in solar; regardless, these would be welcome moves.

It’s also good to see the governor’s endorsement of rate reform. Republicans have been at least as much to blame as Democrats for Dominion Energy’s success in getting laws passed that let it bilk ratepayers. It will be interesting to see if Youngkin actually pursues the reforms he touts.

Less encouraging are Youngkin’s desires to jump into hydrogen (I’m guessing not the green kind, since we hardly have an excess of renewable energy) and, worse, to deploy “the nation’s first” commercial small modular nuclear reactor (SMR) in Southwest Virginia within 10 years.

You know what will happen there, right? Ratepayers will foot the bill, and it will be very expensive.

But unlike offshore wind, SMRs aren’t proven technology; they remain firmly in the research phase. The U.S. Department of Energy is hoping for a demonstration project “this decade.” If successful, the industry believes SMRs will eventually be able to produce electricity at a price that’s only two or three times that of solar and wind energy. Which begs an obvious question: Is there a reason to build SMRs?

Nor has anyone figured out the nagging problem of what to do with the radioactive waste, including the waste piling up at today’s nuclear plants because it’s too dangerous to move and there’s no place to put it. So Youngkin’s plan also “calls for developing spent nuclear fuel recycling technologies that offer the promise of a zero-carbon emission energy system with minimal waste and a closed-loop supply chain.” Great idea! But how about focusing on that first, Governor?

That’s not where Younkin is putting his focus, though. Last week, he proposed spending $10 million on a Virginia Power Innovation Fund, with half of that earmarked for SMR research and development. The announcement said nothing about waste.

Look, I happen to know some earnest climate advocates who believe SMRs are the silver bullet we’ve been waiting for. I follow the research with an open mind while also noting the astonishing advances in renewable energy technology announced almost daily. But the climate crisis is here and now. We can’t afford to press pause on known carbon-free technologies for 10 years in the hope that something even better will pan out.

Investing in research and development of new technologies is an important role for government, but kicking the climate can down the road isn’t an option. Rather than attacking our energy transition, Youngkin would have done more for Virginia by using his plan to build on it.

This article appeared first in the Virginia Mercury on October 18, 2022.

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Power for the People VA

Virginia energy policy made interesting

Tag Archives: Dominion Energy

If Dominion’s plan is so bad, is there a better one? (Spoiler alert: yes, there is.)

It’s all about the data centers

Garbage in, garbage out

Clean energy, vindicated

Why are Dominion Energy’s customers footing the bill for Virginia’s data center buildout?

Law? What law? Pandering to the governor, Dominion’s new plan ignores Virginia’s climate law

It’s time for Virginia to plan its next offshore wind farm

Will the cost of energy come down?

It’s a great time for workers entering the industry — if you can find them

Halting steps towards Virginia’s next project

Is your electricity bill keeping you in the dark?

A dog, a food fight and other highlights from the 2023 General Assembly session

Republican attacks on the energy transition failed

Raids on the VCEA produced mixed results

Utility reform consumed most of the session (again)

Elsewhere, consumers did poorly

Offshore wind remains on track

The gas ban ban fails again

And this year’s big winner is … Amazon!

Attacks on Virginia’s climate laws are front and center at the General Assembly

Republicans are not down with the energy transition

Raiding the store for polluter interests

SMRs and hydrogen

Utility reform

Retail choice

Goosing investments in solar and efficiency

Shared solar

Offshore wind

Residential PACE

Data centers

Return of the gas ban ban

Dominion Energy says solar will dominate by 2040

Shared solar launches in Virginia but still faces an uphill battle

Interconnection woes: delays, high costs and ‘dark fiber’

Multifamily shared solar scores a win, regardless of income level

You call that an energy plan?

It’s all about the data centers

Garbage in, garbage out

Clean energy, vindicated

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Will the cost of energy come down?

It’s a great time for workers entering the industry — if you can find them

Halting steps towards Virginia’s next project

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Republican attacks on the energy transition failed

Raids on the VCEA produced mixed results

Utility reform consumed most of the session (again)

Elsewhere, consumers did poorly

Offshore wind remains on track

The gas ban ban fails again

And this year’s big winner is … Amazon!

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Republicans are not down with the energy transition

Raiding the store for polluter interests

SMRs and hydrogen

Utility reform

Retail choice

Goosing investments in solar and efficiency

Shared solar

Offshore wind

Residential PACE

Data centers

Return of the gas ban ban

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Interconnection woes: delays, high costs and ‘dark fiber’

Multifamily shared solar scores a win, regardless of income level

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