Dominion prepares to file Virginia IRP without natural gas buildout
April 6, 2020

By Lulia Gheorghiu 

Dive Brief:

  • Dominion Energy asked regulators for permission on Thursday, ahead of the filing of its 2020 Integrated Resource Plan (IRP), to avoid certain requirements that will no longer apply, such as a comprehensive analysis of new natural gas or nuclear power build-outs.
  • The utility notified Virginia regulators that a natural gas build-out would not be viable in the state without “a threat to reliability or security of electric service.” Dominion signaled the change in response to the 100% clean energy mandate by 2045 established by the Virginia Clean Economy Act, but the request on Thursday is “a procedural step to remove some outdated reporting requirements,” according to a spokesperson.
  • This marks a big shift for Dominion, the Chesapeake Climate Action Network (CCAN) noted, as its previous IRPs included scenarios with up to 10 new combined-cycle or combustion turbine facilities. Other environmental groups believe the lack of need for gas infrastructure could also extend to the construction of the Atlantic Coast Pipeline.

Dive Insight:

In Virginia, IRPs are filed every two years to plan for the next 15 years, and the 2020 IRP reflected several regulatory and legislative changes, from increased clean energy state measures to looser federal power plant regulations.

Dominion wants to stop incorporating certain modeling and analysis as required under the Clean Power Plan, which the U.S. Environmental Protection Agency replaced in 2019 with the Affordable Clean Energy rule. Dominion said regulatory staff read this proposal and does not oppose its request to stop fulfilling requirements related to the Clean Power Plan.

The State Corporation Commission (SCC) also asked Dominion in 2015 to include a risk analysis of constructing new natural gas and nuclear power generation.

In the last five years, Dominion built several new gas units in the Greensville, Warren and Brunswick counties. But in 2015, clean energy advocates “were able to get the [SCC] to say, ‘Hey, you need to do more assertive and more comprehensive risk assessments of these new gas builds,'” Amanda Levin, policy analyst at the Natural Resources Defense Council (NRDC), told Utility Dive.

The utility also asked to stop modeling how competitive an addition of North Anna 3, a new nuclear unit, would be, as the company “paused material development activities” for the project, according to its request on Thursday.

“[C]oal without carbon capture sequestration technology is no longer a viable generating resource, and significant build-out of natural gas facilities is not currently viable, with the passage by the General Assembly of the Virginia Clean Economy Act of 2020,” Dominion wrote.

Some environmental groups, like the CCAN, view this declaration as a pathway to eventually abandon gas in all forms.

“Dominion should go the rest of the way and close shop on the doomed and unnecessary Atlantic Coast Pipeline boondoggle,” Harrison Wallace, director of CCAN, said in a statement.

Environmental groups have been fighting the development of the Atlantic Coast Pipeline, which has key permits under evaluation at the Supreme Court. Dominion will own 53% of the gas project, alongside Duke Energy, after buying Southern Company’s 5% stake, which is intended to bring natural gas into Virginia and North Carolina.

“Dominion Energy has argued up and down to [the Federal Energy Regulatory Commission] that the Atlantic Coast Pipeline is necessary for electricity generation in Virginia, yet now the utility is telling state regulators that new gas capacity is not viable,” Cassady Craighill, spokesperson for Clean Virginia, told Utility Dive. “If we follow Dominion’s own logic, then there is no remaining purpose for the Atlantic Coast Pipeline. It should be canceled, and Virginians should be free from shouldering the cost of Dominion’s bad investment.”

“Dominion Energy Virginia is just one of several public utility customers of the ACP, with a large portion of the capacity going to North Carolina utilities,” Jeremy Slayton, Dominion spokesperson, told Utility Dive via email.

“There are no changes to the Atlantic Coast Pipeline project, It is still urgently needed for electricity, home heating and manufacturing in Virginia and North Carolina,” he said.

The company also asked regulators not to model what various amounts of solar power purchase agreements (PPAs) at 25% and 50% would look like, as the SCC had asked in 2018, because the new bill on clean energy requires 35% solar PPAs, which Dominion would model.

COVID-19 impacts of IRP filings

IRP proceedings take a long time to prepare. Dominion’s process in Virginia is not expected to wrap up until 2021, so the current pandemic may not directly impact the process, NRDC’s Levin said.

Dominion “is continuing to evaluate the logistics for filing the 2020 [IRP] in light of the ongoing public health emergency,” the utility wrote in its recent request.

While the initial filings may not reflect substantive changes inspired by the current pandemic conditions, experts and analysts assume COVID-19 conditions will be addressed in some way by all new IRP proceedings.

“[W]e will see this come up in intervenor or staff comments or amendments by the companies,” Eric Selmon, co-head of utilities and renewable energy research at SSR LLC, told Utility Dive. SSR has been tracking COVID-19 impacts on utilities’ long-term plans.

However, COVID-19 conditions will impact the validity of demand forecasts, Selmon said, based on how customer behavior will change after the pandemic.

“I expect the risks of a future pandemic will support additional utility investment … particularly in increased automation and remote sensoring, monitoring and control technologies for the grid,” he said.