The State Corporation Commission has judged Dominion Energy Virginia’s latest integrated resource plan (IRP) – the one with controversial proposals for additional use of natural gas– to be merely “legally sufficient.” In its final order issued July 15, the commission applied the term “reasonable” to only a few elements of Dominion’s 15-year roadmap on how it would meet the growing energy demands of the Commonwealth.
Leaving no room for interpretation, the order emphasized that “such acceptance does not express approval in this Final Order of the magnitude or specifics of Dominion’s future spending plans, the costs of which will significantly impact millions of residential and business customers in the monthly bills they must pay for power.”
This, at least, is a slightly better outcome than the regulatory body’s rejection of Dominion’s previous integrated resource plan, but that was before the SCC had a full panel of three members approved by the General Assembly. If Dominion was hoping it could now get agreement from the SCC that natural gas is essential for future electricity reliability, as it argued in this IRP, it came away disappointed.
The SCC will not be able to dodge that all-important reliability question in another pending Dominion application, this one to build a new natural gas plant in Chesterfield County on the site of a retired coal plant. That case is still in its early stages but is drawing a crowd of participants and will soon see filed testimony from the SCC staff and various parties. The public hearing will be held September 23 (the height of the fall political season).
While the SCC found that the most recent IRP, filed last October, satisfied the requirements in state law and its own rules, it then proceeded to order major differences in the way Dominion prepares its next such plan, probably filed in late 2026.
That plan will have to look forward 20 years, not the 15-year time window used for this plan. Critics attacked the choice of 15 years (2025-2039) as intended to avoid the deadline of 2045 for the elimination of all gas and coal generation in Virginia. That deadline is set in the Virginia Clean Economy Act (VCEA), and this IRP just ignored it.
The next plan needs to take a deeper look at integrating battery technology to back up the wind and solar elements, which is likely to do anyway. The SCC did not dispute Dominion’s claim that, as it drafted this IRP, the battery technology then available added little value, but argued that the technology is improving.
The SCC also ordered Dominion to include, among its optional generation combinations to meet demand, a plan that eliminates all hydrocarbons, as required by the VCEA. The lack of such a plan was another talking point for opponents.
A footnote in the SCC order reported that Dominion did produce such a carbon-emissions-free plan on its modeling software, but only during its stakeholder meetings before it submitted the IRP.Dominion deemed the carbon-free plan to be unrealistic and thus did not incorporate it into the SCC application.The undisclosed plan only surfaced in exhibits produced for the hearing and had no cost estimate included to compare it to the plans Dominion ultimately put forward as preferred.
How did Dominion’s modeling replace the electricity from the hydrocarbon plants in its other plans, both the existing coal and gas plants and the proposed new ones? Here is a summary from that exhibit.
“This Stakeholder Input Case includes increasing build limits as compared to the primary Portfolios included in the 2024 IRP, by:
- Doubling the amount of (added) solar to 2,040 MW annually,
- Doubling the amount of storage to 700 MW annually,
- Doubling the amount of SMRs to 2 units annually,
- Adding another 2,600 MW of offshore wind to be built, and
- Increasing the capacity purchase limit to 5,000 MW per year.
“In the Company’s view, all of these incremental increases are infeasible.
“Combining the incremental resources in this case with the like resources in the primary Portfolios, over the 15-year planning period, the Case includes 23.4 GWs of solar, 7.6 GWs of storage, 6.1 GWs of wind, almost 3 GWs of SMRs, and requires that the capacity purchase limit be increased to 5,000 MW per year to meet customer need.”
Those proposed amounts of wind and solar generation greatly exceed the mandated levels in the Virginia Clean Economy Act, which was written before the data center industry exploded all our assumptions about future demand. In the exhibit, Dominion asserted that the required level of power purchased from outside Virginia, “other people’s power”, would be impossible to achieve.
Dominion complained to the SCC that it cannot get land use approvals for the many new solar fields already demanded by the VCEA, and this scenario would almost double the required land. Dominion’s published IRP included two additional offshore wind farms beyond the one now being built, and that no-carbon scenario would require a fourth county-sized sea of Atlantic turbines.
And unmentioned during the case proceedings and certainly ignored in the SCC’s final order, many of the underlying federal energy policies have changed. Congress and President Trump have now set a cutoff date, in most cases 2027, by which any wind or solar projects must be in service to qualify for federal tax credits.
For projects after that date, the bulk of the construction demanded in all the various IRP generation mix variations, there will be no federal tax credits. What was a hidden cash subsidy from taxpayers, keeping costs down, will now become an increased monthly cash demand from ratepayers, adding probably tens of billions in cost.
That “footnote” zero carbon plan is the future for Virginia demanded by the Virginia Clean Economy Act, and by the many Virginia politicians who continue to insist VCEA is possible and reasonable. It should end this debate and force a repeal of the VCEA and hopefully, a new, reasonable, forward-looking appraisal of our energy needs. Sadly, it likely will not.
Steve Haner is a Senior Fellow for Environment and Energy Policy. He can be reached at [email protected].