In early May, Dominion Virginia Power filed its annual Integrated Resource Plan (IRP) with the State Corporation Commission (SCC). An IRP is a long-term plan laying out how a utility will meet the electric demand of its customers in the coming years. The SCC is the Virginia’s regulatory body charged with overseeing utility electricity providers. Utilities like Dominion are required to file IRPs annually to describe what new electricity generation facilities will be brought online, what existing facilities will be retired, and where. Traditionally, Dominion’s IRPs (and generation portfolio on the whole) have demonstrated the utility’s heavy reliance on fossil-fuel sources: roughly one-third of its electricity generating fleet is powered by coal, and another third powered by natural gas. But this year, something changed.
More so than in any previous IRP, Dominion’s 2017 IRP features a strong focus on solar. Whereas previous years’ IRP filings gave very little mention to renewable energy, solar in particular, this one provides some pretty compelling numbers. In it, Dominion commits to building out 3,200 MW (or 3,200,000 kW) of solar generating capacity by 2032, fifteen years from now. Dominion also indicates that it could build a total of 5,200 MW (5,200,000 kW) of solar by 2042. Considering Virginia has only ~300 MW of solar installed at present, Dominion’s solar numbers seem quite impressive.
Beyond its numbers and figures, Dominion’s IRP press release praises solar. “For the first time, the costs of utility-scale universal solar power are expected to be low enough to make it a component [of our generation portfolio],” announced Paul Koonce, CEO of Dominion Generation Group. We believe this balance of solar [with our other generation sources] hits the sweet spot in terms of cost, environmental performance and reliability for our customers.” In perhaps its most solar-centric statement to date, Dominion offers “[we] must now prepare for a future in which solar PV generation can become a major contributor to the Company’s overall energy mix.”
Where is customer-owned solar?
VA SUN and its growing constituency of solar supporters is pleased to see Dominion- Virginia’s largest electric utility incorporating more solar into its generation portfolio. But, we want to see Dominion fulfill its obligation to remove barriers to customer-owned solar. Dominion blocks the right of its customers to benefit from the energy freedom, job creation and grid resilience that only customer-owned ‘rooftop’ solar enables.
While the aggregate solar projections filed in the IRP seem impressive, the numbers are far less exciting when broken down by year. As Ivy Main pointed out in a recent article, 3,200 MW of solar by 2032 translates to roughly 240 MW of new solar generating capacity per year. That’s about equal to what individual Virginia homeowners, small businesses, non-profits installed, combined with the utility-owned, centralized solar from a few large-scale developers in 2016 alone. Given Dominion’s wealth, resources, and available infrastructure, we should expect more.
In fact, why doesn’t Dominion commit to building more solar facilities in the state? Company executives contend that installing more solar than what’s included in their IRP projections will threaten power reliability and burden Virginia’s ratepayers with extreme costs- A claim which they have no data to substantiate. However, as came to light after their 2016 IRP filing, Dominion’s own utility modeling software found that they could build out a total 15,000 MW of solar over the next 15 years and still save ratepayers money. A lot of money – upwards of $1.5 billion, even after construction and grid upgrade costs are factored in. The revelation was made public after a team of lawyers from the Southern Environmental Law Center discovered that Dominion deliberately removed these “high-solar” projections from their IRP filing, essentially hiding them from public view. What Dominion’s own “high-solar” modeling figures suggest is clear: they can integrate much more solar into the electric grid than the meager 3,200 MW they include in their 2017 IRP, the cost of doing so is not prohibitive, and more solar would, in fact, mean more savings for ratepayers.
The most notable feature of Dominion’s 2017 IRP is the discord between its own plans to build more solar and its continued efforts to undermine the ability of Virginians to do the same. Dominion actively impedes third-party ownership models for solar (also called PPAs, or power purchase agreements) in the state, significantly restricting the residential solar market. It continues to support and defend an arbitrary 1% cap on net metering, limiting the amount of distributed solar that they will financially compensate through net metering to a mere 1% of their previous year’s peak load forecast. Additionally, Dominion charges excessive stand-by charges for customers who install mid-sized solar arrays on their roofs, and prohibits customers from installing solar systems that produce electricity in excess of their previous year’s consumption. Taken together, these practices are a significant barrier to going solar for regular people. Should Virginians accept such treatment from a company that touts solar so vigorously in its planning and public relations materials?
In light of Dominion’s recently-filed 2017 IRP, we can certainly celebrate its emerging solar plans. But, we must also continue to protect the rights of all Virginians to go solar and ensure that Dominion’s build-out of solar facilities works for all state ratepayers.