Dominion Energy's Application for a Bottom Ash Water Transport Project in Virginia

Sierra Club
Project Completed August 2022

Synapse provided expert witness support to the Sierra Club in the rate adjustment clause docket where Dominion sought recovery of the costs for the Bottom Ash Water Transport (BAWT) project at Mt. Storm Power Station. Our testimony and analysis focused on whether Dominion has demonstrated the prudence of moving forward with Phase 2 of the project. We based our analysis on both the contemporaneous analysis conducted by the Company in 2021, at the time it decided to move forward with Phase 2 of the project, and prior analysis it had conducted throughout and following Phase 1.

We found that during the pause between Phase 1 and Phase 2 of the project, the Company incurred costs to delay the project, but did not use the information available to adequately re-evaluate whether continuing with the project was still in the ratepayers' best interest. Specifically, the Company ignored its own projections, which it had been systemically revising down every year, and now showed the plant was marginal at best. It also ignored plant data that showed declining utilization at the plant. The company also failed to evaluate the risk of additional environmental compliance costs at the plant.

We recommend that the Commission disallow the costs associated with Phase 2 of the project. At the very least, the Commission should deny the Phase 2 costs until Dominion performs an updated economic analysis that accounts for the additional environmental compliance costs including the costs of chillers, a more stringent ELG standard, and a higher CO2 price.