Dominion Energy’s new choices are really about limiting choices

Trees clearcut.

Dominion’s renewable energy products contain copious amounts of biomass, also known as burning trees. Photo by Calibas, Creative Commons.

An annual survey conducted by Yale and George Mason universities shows concern about climate change is surging. Seventy-three percent of Americans think climate change is happening, and 69% are at least somewhat worried about it, the highest percentages since the surveys began in 2011.

Another Yale survey found that “a large majority of registered voters (85%) – including 95% of Democrats and 71% of Republicans – support requiring utilities in their state to produce 100% of their electricity from clean, renewable sources by 2050. Nearly two in three conservative Republicans (64%) support this policy.”

Yet here in Virginia, Dominion Energy expects to reduce carbon emissions less in the future than in the past, and it has no plan to produce 100% of its electricity from clean, renewable sources by 2050. For all the talk here of solar, Virginia still had one-seventh the amount of solar installed as North Carolina at the end of 2018 and no wind energy.

Dominion has developed a few solar projects and new tariffs to serve tech companies and other large customers, but ordinary residents still lack meaningful choices. So this spring, Dominion decided to do something about that.

The wrong thing, of course.

Dominion has asked the State Corporation Commission for permission to market two quasi-environmentally-responsible products. One is for people who are willing to pay a premium for renewable energy, and don’t read labels, and the other is for people who want a bargain on renewable energy, and don’t read labels.

There may be plenty of both kinds of customers out there, but that doesn’t mean the SCC should approve either product. Indeed, while the purpose of the bargain product is to offer a choice nobody wants, the purpose of the premium product is to close off better choices.

Let’s look first at the product for bargain-hunters, a super-cheap version of the utility’s Green Power Program. Dominion is calling it “Rider REC.” A better name for it would be the “You Call This Green? Power Program.”

Rider REC consists of the dregs of the renewable energy category, the stuff that isn’t good enough for the Green Power Program. That’s a low bar already, because the Green Power Program doesn’t sell green power. It sells renewable energy certificates (RECs), the “renewable attributes” of electrons from facilities labeled renewable.

Customers who pay extra for RECs still use whatever mix of energy their utility provides. For Dominion customers, that’s fracked gas, nuclear and coal, plus a tiny percentage of oil, biomass, hydro and solar.

Buying RECs lets good-hearted people feel better about using dirty power by donating money to owners of renewable energy facilities somewhere else. The facilities might be in Virginia, or they might be clear across the country.

For example, say a utility out west builds a wind farm because wind is the cheapest way to generate power. If the state doesn’t have a renewable portfolio standard that requires the utility to use the RECs for compliance (most windy states don’t), the RECs can be sold to buyers in liberal East Coast states, lowering energy prices for the utility’s own customers.

RECs don’t even have to represent clean sources like wind. Some RECs subsidize industries that burn trees (aka biomass), black liquor (a particularly dirty waste product of paper mills) and trash.

Dominion’s Green Power Program uses RECs that meet the standards of a national certification program called Green-e. Green-e requires that facilities be no more than 15 years old and meet minimum environmental standards, such as requirements that woody biomass be sustainably grown and that generators don’t violate state and federal pollution limits.

But Virginia’s definition of renewable energy is, shall we say, more forgiving than Green-e’s. Our law does not discriminate against decades-old facilities like hydroelectric dams, or energy from trees that have been clear-cut. (Nor does it recognize that burning trees produces even more lung-damaging, asthma-inducing pollution than coal, and more climate-warming CO2 as well.) Virginia’s definition of renewable energy even includes a vague category of “thermal” energy that may be another way paper mills profit from the REC racket.

This loose definition of “renewable” creates a business opportunity for anyone unscrupulous enough to seize it. Dominion proposes to package up these otherwise unmarketable RECs from sketchy sources across the continental United States and pawn them off on unsuspecting consumers here in Virginia.

There is always money to be made by suckering well-meaning folks, but that’s not a good enough reason for the SCC to let Dominion do it. The case is PUR-2019-00081. Public comments are due by Aug. 15.

So what about the more expensive quasi-environmentally responsible product? “Rider TRG” consists of real, straight-from-the-facility electricity on the power grid serving Virginia, not RECs from out west. And while it is not dirt-cheap like Rider REC, Rider TRG would cost residential customers a premium of only about $50 per year.

Unfortunately, Virginia’s kitchen-sink definition of renewable energy means the sources still don’t have to be new or carbon-free or sustainable. It appears most of them won’t be.

Dominion’s filing indicates the program will use the energy from the Gaston hydroelectric dam built in 1963; the Roanoke Rapids hydro station built in 1955; the Altavista, Southampton and Hopewell power stations that were converted from coal to wood-burning in 2013; and several solar farms the company has already built or contracted for.

In addition, Dominion proposes to allocate to the program the portion of electricity from its Virginia City coal plant representing the percentage of wood that is burned along with the coal.

That’s right, Dominion intends for renewable energy buyers to subsidize its coal plant. The idea is cynical enough to have come from the Trump administration.

Dominion knows full well that customers who want renewable energy want new wind and solar, so why is its first product for residential customers so loaded with dirty biomass and old hydro?

The answer is that Dominion doesn’t care if no one signs up for Rider TRG. The point isn’t to give customers what they want, it’s to prevent them from shopping elsewhere for better options. Like Appalachian Power before it, Dominion wants to close off the narrow opening provided by Virginia law that allows customers to shop for 100% renewable energy from other providers only if their own utility doesn’t offer it. The SCC approved APCo’s renewable energy tariff some months ago. Dominion is following APCo’s successful strategy.

Yet APCo’s product consists of hydro, wind and solar, so it is nefarious, but not actually bad. Dominion’s is nefarious and bad.

An SCC decision in 2017 confirmed customers’ right to shop for renewable energy as long as the incumbent utility doesn’t offer it. Currently at least two other providers, Direct Energy and Calpine Energy Solutions, offer renewable energy to commercial customers in Dominion territory. Yet according to documents provided by Direct Energy, Dominion is refusing to let its customers transfer to Direct Energy and Calpine, triggering competing petitions to the SCC.

Dominion no doubt hopes to resolve the dispute permanently by terminating its customers’ right to switch providers at all.

The case is PUR-2019-00094. Comments may be submitted until Nov. 14, and a public hearing will be held on Nov. 21.

 

This article first appeared in the Virginia Mercury on July 22, 2019.

Dominion gets the nod to sell solar energy to us regular folks

alternative energy building clouds energy

Photo by Pixabay on Pexels.com

The State Corporation Commission (SCC) has approved Dominion Energy Virginia’s so-called Community Solar pilot program, under which the utility will offer its residential and commercial customers the output of solar farms to be built by independent solar developers here in Virginia.

Customers will have the option to meet either all or part of their electric demand with solar. The added cost of the program, at least initially, will be 2.01 cents per kilowatt-hour (kWh). For a customer who uses an average of 1,000 kWh monthly and wants to use only solar, that would add up to a premium of $20.10 per month.

Customers who want to meet just a portion of their total demand with solar will have the option of subscribing to “blocks” consisting of 100 kWh, up to a maximum of 5 blocks for residential customers or 10 blocks for non-residential customers.

The premium cost of the program may surprise customers who have heard that large-scale solar is now one of the cheapest sources of energy in Virginia. But according to Will Cleveland, a staff attorney at the Southern Environmental Law Center who helped to develop the program, cost was not the only consideration in choosing which solar facilities to include in the program.

Facilities were selected to be smaller and distributed around the state, in keeping with the “community” concept, which meant they sometimes came with higher prices. Program costs also include Dominion’s costs of administration and marketing. Cleveland says he consulted experts who advised him these numbers were reasonable.

In addition to selling the electrical output of the solar facilities to customers, Dominion will retire the associated renewable energy certificates (RECs). The RECs represent the legal proof that the energy comes from solar, an important factor for commercial customers that wish to represent they use renewable energy in their business. “Retiring” the RECs guarantees that Dominion isn’t also selling them elsewhere.

The program is a result of legislation passed by the General Assembly in 2017 that authorized a three-year pilot program in Dominion’s territory for up to 40 megawatts (MW) of solar capacity. The legislation also authorized Appalachian Power to develop up to 10 MW for a similar program. To date, Appalachian Power has not submitted a proposal.

Although the program is called “community solar,” customers will not own shares in the solar facilities, and the facilities do not have to be located in the same communities as the customers. Virginia law does not permit the kind of community solar in which customers share in the ownership and output of solar facilities.

Calling Dominion’s program “community solar” is bound to confuse people, and it’s hard not to believe that was a calculated move on the utility’s part. Yet Dominion’s solar offering is a major step forward for the company, and for customers who aren’t able to put solar panels on their own rooftops.

And while it is somewhat more expensive than the company’s Green Power Program, it should prove much more attractive with people who understand the difference between the programs.

Subscribers to the Green Power Program don’t get electricity from renewable energy; Dominion sells them regular “brown” power, then tacks on an added charge to match the dirty energy with renewable energy certificates (RECs). Most of the RECs come from existing wind projects in other states, where wind is already the cheapest power source. By contrast, the solar program provides solar energy (and the RECs) from new Virginia solar farms, ones that would not get built otherwise.

Dominion is expected to begin signing up subscribers for its solar program later this fall, with the program getting underway once the solar projects come online next year. For those of us without the sunny roofs needed to put up our own solar panels, this promises to be—for now—the next best option.

A version of this article first appeared in the Virginia Mercury, a new (and if I do say so, quite excellent) independent online news source dedicated to covering Virginia issues that matter. 

How Virginia could build 5,000 megawatts of wind and solar, and still have no wind or solar

Pie graph showing Dominion Energy Virginia energy mix 2017

No amount of new solar would enlarge the sliver of renewables in Dominion’s energy mix if it sells the RECs. Graph is from Dominion Energy Virginia’s 2018 Integrated Resource Plan.

With the passage of SB 966 earlier this year, the Virginia General Assembly declared 5,000 megawatts (MW) of utility solar and wind energy in the public interest, spreading optimism that Virginia is beginning its slow transition to a clean energy economy. All indications are that Dominion Energy Virginia, the state’s largest utility, intends to make good on that number. Yet under Virginia law, as interpreted by the State Corporation Commission, Virginia utilities could build all that wind and solar and still not be able to claim it in the energy mix serving Virginia residents.

That peculiar result is possible if Dominion and other utilities sell the renewable energy certificates (RECs) associated with the electricity generated from the wind or solar project, transferring to their buyers the legal right to call it renewable energy. The likely buyers are utilities in other states that need RECs to meet mandates for renewable energy under the laws of those states. If the RECs get sold this way, Dominion Energy can build one solar farm after another in Virginia, without ever adding solar to our electricity mix.

That’s right: if you sell the RECs from a solar facility, you can’t say you are using electricity from solar.

This scenario is not just possible, but likely, based on earlier State Corporation Commission (SCC) rulings. The first time Dominion received permission to develop solar, based on a 2013 law enabling the utility to build up to 33 MW of distributed solar (dubbed the Solar Partnership Program), the SCC insisted that Dominion sell the RECs to reduce the cost of the program to ratepayers.

What about Virginia’s voluntary renewable portfolio standard (RPS), which requires participating utilities to get a portion of their electricity from renewable energy sources, including solar? Dominion continues to meet its annual targets, which gradually rise to 15% of non-nuclear electricity by 2025, measured against 2007 demand.

But here, too, the SCC does not want ratepayers to have to spend a dime more than necessary on meeting the RPS. It requires utilities to sell higher-value RECs and replace them with the cheapest RECs available that still meet the Virginia definition of renewable energy. This practice, known as REC “optimization” or arbitrage (selling high, buying low), is common in states with loose RPS laws, and is sometimes used in the private sector as well.

The use of REC optimization, paired with Virginia’s kitchen-sink approach to what qualifies as renewable energy, renders Virginia’s RPS meaningless. Making it mandatory wouldn’t make it meaningful.

chart showing fuel types used to show RPS compliance by Dominion Energy Virginia

Fuel types used to meet compliance with Virginia RPS. From Dominion’s Annual Report to the SCC on Renewable Energy, November 2017. (MSW=municipal solid waste incineration.)

Dominion’s 2017 Annual Report to the State Corporation Commission on Renewable Energy records the company’s progress on meeting the RPS as well as describing its other renewable energy investments. The report confirms both Dominion’s ongoing use of REC optimization for the RPS and its practice of selling RECs from solar projects to reduce ratepayer costs.

Nothing in the 2018 legislation speaks to RECs generated by the 5,000 MW of utility wind and solar that are now declared to be in the public interest. One might suppose the General Assembly intends for utilities to build those projects for ratepayers, not to sell off the legal right to claim we have wind and solar in our mix. But then again, it is entirely possible most legislators never gave the topic a moment’s thought.

If one were to raise it with them now, some might even prove quite comfortable with the idea. As long as we get the jobs and economic development associated with new energy projects, and we use the clean energy to reduce the burning of fossil fuels, they might say heck yeah, let Maryland or New Jersey buy the bragging rights for their state RPS requirements and subsidize our energy costs.

If taking advantage of the flaws in other state’s laws feels like the wrong way to make progress, there is an alternative. We could reform Virginia’s RPS to make it less like corporate welfare for producers of the least valuable forms of renewable energy, and more like a transition plan to a clean energy economy. Put that together with a plan for true grid transformation, and we will have something to brag about ourselves.