Dominion Virginia’s 2020 Integrated Resource Plan falls short in leveraging lower cost energy efficiency resources in its proposal to meet the Commonwealth’s projected energy needs.
This is the position of Virginia Advanced Energy Economy, which submitted comments to the State Corporation Commission on the Dominion IRP on Tuesday.
According to VAEE, Dominion’s IRP fails to incorporate energy efficiency efforts similar to those of comparable utilities and does not achieve the intent of the Virginia Clean Economy Act, resulting in $1 billion in higher electricity costs for Virginia customers.
“Our review of Dominion’s IRP shows that it fails to adequately consider energy efficiency as a resource, presenting a plan that is unnecessarily costly and attributes excessively high costs to meeting requirements of the VCEA,” VAEE Executive Director Harrison Godfrey said. “Dominion considers only those energy efficiency programs that are already approved or required, rather than all cost-effective energy efficiency efforts that could save money for Virginia families.”
“Our independent third-party review found that implementing robust energy efficiency programs would virtually eliminate any incremental costs of electricity bills that Dominion Virginia attributes to the VCEA,” said Godfrey. “For this reason, in our comments we urge the Commission to send Dominion back to the drawing board. The utility needs to present a plan that fully utilizes affordable, clean resources — like energy efficiency — to implement the VCEA in a least-cost manner. To date, it has not.”
“This is particularly disappointing given that the benefits of utility energy efficiency programs are well-documented across the nation,” said Godfrey. “Our analysis, based on EIA data, shows that Dominion significantly lags the vast majority of comparable utilities across the nation when it comes to residential and commercial efficiency, and at the same time overestimates the cost of efficiency programs.”
Based on U.S. Energy Information Administration data, Dominion ranks 69th out of 88 utilities nationally in terms of savings from residential energy efficiency programs.
Virginia AEE’s analysis shows that if Dominion Virginia were to accelerate energy efficiency programming to a pace of 1.5-2.0 percent Annual Incremental Savings at costs similar to the average investor-owned utility, it could substantially reduce the need for new generation resources, meeting the Commonwealth’s clean energy goals, and saving its customers substantial costs.
Currently, according to VAEE, Dominion’s residential programs achieve just 0.25 percent Annual Incremental Savings. A 2.0 percent Annual Incremental Savings would put Dominion Virginia on a level comparable with peers like PECO in Pennsylvania, DTE in Michigan, MidAmerican in Illinois, Southern Indiana Gas & Electric (Vectren South) in Indiana.
When taking into account both the cumulative avoided costs to the grid that result from additional efficiency, and reduced household consumption, Virginia AEE’s analysis indicates such efficiency programming would reduce the average monthly residential bill in 2030 by an estimated $16.76 below what it would otherwise be.
“Customer cost savings from energy efficiency programs like those offered by other utilities could exceed $1 billion over the 15 years covered by Dominion Virginia’s resource plan,” Godfrey said. “We urge the Commission, and the utility, not to leave those savings on the table.”
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Chris Graham
