The commission’s staff testified in April that without the reliability exception, “it is unclear how [Dominion’s] plans could possibly be in the customers’ best interest.”
Beyond the costs of building the plants, there’s also the price of fuel to consider, said Nate Benforado, senior attorney with the Southern Environmental Law Center in Charlottesville.
“If we build all this gas, we are risking customer dollars. We are tying Virginia to this global gas commodity,” he said. Prices are on the rise and fluctuate with world events outside the state’s control, like Russia’s invasion of Ukraine. “We’re going to have higher bills, unpredictable bills,” he said.
Skewed model undervalues clean energy, critics say
Dominion Energy did not respond to a request for comment. But advocates say the company perverts its modeling output in other ways, imposing annual limits of 350 megawatts of battery storage starting in 2028 and 1,030 megawatts of solar starting in 2029.
“All of these choices tend to skew Dominion’s model to pick gas and avoid these very cost-effective, very efficient systems,” Benforado said.
By contrast, modeling that the law center and Appalachian Voices commissioned from the Texas firm IdeaSmiths shows that a more robust build-out of solar, batteries, and virtual power plants than Dominion now plans, along with new nuclear generation, could meet ballooning energy demand that wasn’t foreseen when the Clean Economy Act first became law.
“We were genuinely curious whether we could meet the carbon-free deadlines since the advent of ChatGPT and the AI race as a main driver of increased electricity demand,” Anderson said. “This is just a totally different conversation than what people were talking about in 2020 when electricity demand was flat.”
On the horizon: Data centers and a new gas plant
Though Dominion serves the largest data center market in the world, advocates also caution that its projected 5.5% annual growth in demand may well be inflated.
“The Company relies on a speculative and highly uncertain load forecast driven almost entirely by one industry, and in large part by just a few companies,” the Southern Environmental Law Center said in its filing.
At the same time, Dominion is falling far behind the law’s requirement that it shave demand with energy-efficiency programs, says Advanced Energy United, a national clean-energy industry association. The Clean Economy Act obligates the utility to trim 5% off demand by this year, compared to 2019 levels. It hasn’t and doesn’t plan to, according to the association.
“Dominion overlooked a lot of clean energy solutions in their modeling — meaning energy efficiency, demand response, and virtual power plants,” said Shawn Kelly, regulatory director for Advanced Energy United. “That resulted in them exaggerating a need for supply-side resources” that generate electricity for the grid.
Given the track record of the State Corporation Commission, advocates have some cause for hope that it will once again reject Dominion’s plan. If it does, the decision won’t bind the utility to build a particular solar or wind farm or abandon plans for a gas facility. But it could force the company to look past 2039 and incorporate what it sees into permit applications.
Kelly doesn’t discount the importance of the long-range plan, and he and his organization, like other advocates, believe the commission should deny it. But he also pointed to the gas plant proposal on the table as an urgent concern.
“If somebody were to ask me, ‘Should I read [this whole plan]?,’” he said, “I would actually recommend somebody get more involved and focus on the [permit application] filing that Dominion made in March.”
