Dominion Virginia 2023 Integrated Resource Plan Docket

Sierra Club
Project completed.

Synapse supported Sierra Club’s engagement in Dominion Virginia’s 2023 Integrated Resource Plan (IRP) docket before the Virginia State Corporation Commission. Synapse conducted capacity expansion and production cost modeling of Dominion Virginia’s electric system with a focus on evaluating the least-cost way for Dominion to meet its dramatic projection of future data center load growth while complying with Virginia’s Clean Economy Act (VCEA). We reviewed the economics of Dominion’s proposal to extend the life of its aging coal units at the Virginia City Hybrid Energy Center (VCHEC), Clover Power Station and Mt. Storm Generating Station – some of which previously had near-term retirement dates – beyond 2045. We discussed how the Company’s baseline proposal falls short of meeting the VCEA requirements to retire all carbon-emitting resources by 2045 and will saddle ratepayers with renewable portfolio standard (RPS) costs, large ongoing capital investments in the aging plants, and even stranded asset costs.

We performed independent modeling to evaluate an optimized portfolio, with optimized resource additions and retirement, as well as a scenario that relaxed build limits and retired all existing coal plants by 2035 to comply with the proposed greenhouse gas rules under section 111 of the clean air act. We found that Dominion’s decision to delay the retirement of its existing coal plants is not in the best interest of ratepayers. If Dominion retires its coal plants and builds incremental solar and BESS, it will reduce CO2 emissions and save ratepayers $1.8 – $7.7 billion over the 25-year study period.

We recommended that the Commission require Dominion to revise its 2023 IRP by (1) lifting or easing the build limits it has placed on solar PV and battery storage, and justifying the limit it chooses; (2) modeling the impact of the proposed 111(b) and (d) rule on its existing and proposed new fossil resources; and (3) testing a lower cost sensitivity for solar PV and battery storage resources to reflect the market trend in falling renewable energy costs. Dominion should then rerun its model with these updated assumptions and allow the model to choose from among the clean energy resources available.