RD216 - Virginia Electric and Power Company’s d/b/a Dominion Energy Virginia 2020 Integrated Resource Plan
Throughout its history, the Company has been dedicated to the delivery of safe, reliable, and affordable energy to its customers. This dedication has included a strong movement towards a clean environment. For example, over the last two decades, by changing its generation mix and employing best practices, the Company’s power generation fleet has reduced certain air emissions, including nitrogen oxide, sulfur dioxide, and mercury, by as much as 99%. The Company has also reduced its greenhouse gas emissions, lowering its carbon intensity by approximately 47% since 2000. Further, by adopting the latest technology and applying creative design, the Company is using less water in its operations through the use of air-cooled condensers.
The Company has now entered a new phase in its overall efforts to preserve the environment. On February 11, 2020, the Company’s parent company—Dominion Energy—announced a significant expansion of its greenhouse gas emissions reduction goals, establishing a new company-wide commitment to achieve net zero carbon dioxide (“CO2") and methane emissions by 2050. Net zero does not mean eliminating all emissions, but instead means that any remaining emissions are balanced by removing an equivalent amount from the atmosphere. For example, this can occur through carbon capture, reforestation, or negative-emissions technologies such as renewable natural gas. This strengthened commitment to net zero CO2 and methane emissions builds on Dominion Energy’s strong history of environmental stewardship, while acknowledging the need to further reduce emissions consistent with the findings of the United Nations’ Intergovernmental Panel on Climate Change. The commitment is also a recognition of the increased expectations and interest among customers, policy makers, and employees in building a clean energy future.
This net zero CO2 and methane emissions commitment from Dominion Energy parallels the commitments made to clean energy in both Virginia and North Carolina. In Virginia, the Virginia Clean Economy Act (the “VCEA") will become law effective July 1, 2020. The VCEA establishes a mandatory renewable portfolio standard (“RPS") aimed at 100% clean energy from the Company’s generation fleet by 2045. In furtherance of this mandatory RPS, the VCEA requires the development of significant energy efficiency, solar, wind, and energy storage resources; it also mandates the retirement of all generation units that emit CO2 as a byproduct of combustion by 2045, unless the retirement of a particular unit would threaten grid reliability and security. Based on other new legislation, the Company expects that Virginia will soon become a full participant in the Regional Greenhouse Gas Initiative (“RGGI")—a regional effort to cap and reduce CO2 emissions from the power sector. In North Carolina, the Clean Energy Plan, a compilation of policy and action recommendations developed through a public stakeholder process, sets a statewide carbon neutrality goal by 2050.
This 2020 Plan focuses on presenting alternative plans that set the Company on a trajectory to achieve these clean energy targets. Indeed, the Company has already begun to transition its generation fleet, as well as its transmission and distribution systems, to achieve a cleaner future. Examples of this ongoing transition include:
• The retirement of over 2,200 MW of coal-fired and inflexible, higher cost oil- and natural gas-fired generation over the past ten years;
• The construction of approximately 198 MW of solar generation over the past ten years, with an additional 198 MW of solar generation currently under construction;
• The procurement of approximately 874 MW of solar NUGs over the past ten years;
• The continued work to extend the licenses of the Company’s nuclear units at Surry and North Anna;
• The construction of the Coastal Virginia Offshore Wind (“CVOW") demonstration project, along with the development of a larger build-out of offshore wind generation off the coast of Virginia;
• The continued transformation of the Company’s distribution grid to provide an enhanced platform for distributed energy resources (“DERs") and targeted DSM programs; more secure and reliable service, leading to the increased availability of DERs; and more ways for customers to save energy and money through DSM programs and other rate offerings; and
• The continued work associated with energy storage technology, including the development of a new pumped storage hydroelectric facility in Virginia and the deployment of three battery energy storage system (“BESS") pilot projects.
Over the long term, however, achieving the clean energy goals of Virginia, North Carolina, and the Company will require supportive legislative and regulatory policies, technological advancements, grid modernization, and broader investments across the economy. This includes support for the testing and deployment of technologies such as large-scale energy storage, hydrogen, advanced nuclear, and carbon capture and sequestration, all of which have the potential to significantly reduce greenhouse gas emissions.
In this 2020 Plan, the Company presents four alternative plans (the “Alternative Plans"). Except for Alternative Plan A, all Alternative Plans assume that Virginia is a full RGGI participant.
• Plan A – This Alternative Plan presents a least-cost plan that estimates future generation expansion where there are no new constraints, including no new regulations or restrictions on CO2 emissions. Plan A is presented for cost comparison purposes only in compliance with SCC orders. Given the legislation that will take effect in Virginia on July 1, 2020, this Alternative Plan does not represent a realistic state of relevant law and regulation.
• Plan B – This Alternative Plan sets the Company on a trajectory toward dramatically reducing greenhouse gas emissions, taking into consideration future challenges and uncertainties. Plan B includes the significant development of solar, wind, and energy storage resources envisioned by the VCEA. Plan B preserves approximately 9,700 MW of natural gas-fired generation to address future system reliability, stability, and energy independence issues. While Plan B—and indeed all Alternative Plans—incorporate only known, proven technologies, the Company fully expects that new technologies could take the place of today’s technologies over the Study Period. Overall, Plan B is the lowest cost of Alternative Plans B, C, and D, decreases the reliance on outside markets to meet customer demand and produces similar regional CO2 emissions as Plans C and D. Over the Study Period (i.e., 2021 to 2045), this Alternative Plan includes the development of approximately 31 gigawatts (“GW") of solar capacity, approximately 5 GW of offshore wind capacity, and approximately 5 GW of new energy storage.
• Plan C – This Alternative Plan uses similar assumptions as Plan B, but retires all Company-owned carbon-emitting generation in 2045, resulting in close to zero CO2 emissions from the Company’s fleet in 2045. To reach zero CO2 emissions from the Company’s fleet in 2045, Plan C significantly increases the amount of energy storage resources and the level of imported power. Specifically, in the last ten years of the Study Period, Plan C requires the addition of approximately 1 GW of incremental solar capacity and approximately 4.8 GW of incremental energy storage as compared to Plan B. In addition, beginning in Year 16 of Plan C, the Company’s transmission import capacity would need to double to approximately 10.4 GW total in order to support the Company’s winter import needs, as well as spring and fall export needs. This imported power from PJM would come in part from CO2-emitting generation, meaning that while CO2 emissions from the Company’s fleet would be near zero, regional CO2 emissions would remain at similar levels as Plan B.
• Plan D – This Alternative Plan uses similar assumptions as Plan C but changes the capacity factor assumption for future solar resources from 25% to 19%. As a result, Plan D significantly increases the amount of solar resources needed to reach zero CO2 emissions in 2045. Specifically, over the Study Period, this Plan includes approximately 9.2 GW of incremental solar capacity and approximately 4.8 GW of incremental energy storage as compared to Plan B, which is approximately 8.1 GW more solar capacity than Plan C. Like Plan C, beginning in Year 16 of Plan D, the Company’s transmission import capacity would need to be doubled to approximately 10.4 GW total in order to support the Company’s winter import needs, as well as spring and fall export needs. Accordingly, also like Plan C, regional CO2 emissions would remain at similar levels as Plan B based on the increased dependence on imported power. Notably, the lower 19% capacity factor is based on the historical performance of the Company’s solar generation resources as required by an SCC order; in the Company’s view, this 19% capacity factor does not represent a reasonable estimate of solar generation’s expected potential.
As can be seen in the table on numbered page 5 of the report, Alternative Plans B through D are very similar over the first 15 years. This general alignment over the Planning Period sets a common pathway for the Company to pursue now while allowing new technologies to mature. All Alternative Plans include 970 MW of natural gas-fired combustion turbines (“CTs") as a placeholder to address probable system reliability issues resulting from the addition of significant renewable energy resources and the retirement of coal-fired facilities. While all Alternative Plans in this 2020 Plan incorporate only known, proven technologies, the Company fully expects that new technologies could take the place of today’s technologies over the Study Period. The Company intends to explore all new and promising technologies that support a cleaner future and that will enable the Company to achieve its environmental goals, as well as the goals of Virginia and North Carolina. The Company will provide information on these developments in future Plans and update filings.
Based on the current state of technology and the need for technological advances to truly achieve a cleaner future, Alternative Plans B through D as presented in this 2020 Plan all pose challenges over the long term.
Alternative Plans B through D factor in the implementation of energy efficiency programs and measures to achieve both 5% total annual energy savings by 2025, as targeted by the VCEA, and $870 million in proposed spending by 2028, as required by the Grid Transformation and Security Act of 2018 (the “GTSA"). The Company has modeled these objectives by supplementing the Company’s approved and pending DSM programs with a generic level of energy efficiency at a fixed price. This approach is a theoretical assumption used for planning purposes only. In reality, the level of energy efficiency savings included in this 2020 Plan may not materialize in the same manner as modeled due to many outside factors. These factors include the ability of future vendors to deliver program savings at the assumed fixed price, the desire of customers to participate in the program at that price, and the effectiveness of the program to be administered at that price. The modeled costs and level of savings attributable to generic energy efficiency are thus placeholders as future phases of actual energy efficiency programs are developed and implemented.
From a permitting perspective, all Alternative Plans include large quantities of solar capacity located in Virginia. In fact, to meet customers’ demand, Alternative Plans B through D require between 31,400 MW and 40,640 MW of new solar capacity by 2045. Given current technology, 31,400 MW of solar generating capacity in the Commonwealth would require the land use of 490 square miles. This land mass is nearly 25% larger than Fairfax County, Virginia, or the equivalent of nearly 237,000 football fields. Utilization of such a large land mass area for energy generation will likely encounter local and environmental permitting issues.
The large quantities of solar capacity in Alternative Plans B through D also pose challenges from a technical perspective. A key component included in the traditional design of the North American electric power grid is the inertia from many existing traditional turbines to create a reservoir of kinetic energy. This kinetic energy automatically provides grid support by balancing the myriad of instantaneous discrepancies between generation and load at any moment in time. Inverter-based generation such as intermittent solar and wind resources do not provide such a reservoir of kinetic energy. Therefore, the retirement of traditional generation units coupled with the addition of large quantities of intermittent renewable generation will adversely affect both electric system reliability and the Company’s ability to restore the system in the event of a largescale blackout. Transmission planning work has begun, but more planning analysis is necessary to model the grid under different conditions to assure system reliability, stability, and security with the retirement of traditional generation. Although Plans B through D show significantly reduced carbon emissions by 2045 associated with these projected retirements, additional transmission and distribution projects potentially needed to address system reliability and security have not been fully assessed and evaluated in this 2020 Plan. The Company will provide the results of these additional analyses in future Plans and update filings.
In the long term, based on current technology, other challenges will arise from the significant development of intermittent solar resources in all Alternative Plans. For example, based on the nature of solar resources, the Company will have excess capacity in the summer, but not enough capacity in the winter. Based on current technology, the Company would need to meet this winter deficit by either building additional energy storage resources or by buying capacity from the market. In addition, the Company would likely need to import a significant amount of energy during the winter, but would need to export or store significant amounts of energy during the spring and fall.
In Alternative Plan B, the Company preserved approximately 9,700 MW of efficient natural gasfired generation units to address these future system reliability, stability, and energy independence issues. In future Plans, these units could be replaced by new types of generation such as small modular reactors. These units could also be transformed into low-carbon or carbon-free generation by installing new technologies such as carbon capture sequestration or refueling these units with hydrogen or renewable natural gas. For example, the Company could use excess energy from renewable facilities during periods of lower demand (i.e., spring and fall) to create and store hydrogen fuel that could subsequently be used in these gas-fired generators. When hydrogen fuel is used in gas-fired generators, the byproduct is water rather than CO2. The Company will continue to study these types of innovative alternatives and will, when and if feasible, reflect those alternatives in future Plans.
Unlike Alternative Plan B, Alternative Plans C and D model the retirement of all Companyowned carbon-emitting generation by 2045. If the Company retires all carbon-emitting generation units by 2045 as modeled in Alternative Plans C and D, given current energy storage and solar technology—and even with approximately 10,000 MW of new incremental storage—customers’ winter peak load demand could not be met unless grid transmission import capacity is approximately doubled. Doubling transmission import capacity is a significant task that requires additional study, and would require significant capital expenditures and permitting challenges. Even if this import capacity could be doubled from a technical perspective, Virginia would become dependent on other jurisdictions to meet its winter peak needs, which, in the Company’s view, presents an unacceptable risk. This risk increases as neighboring states elect to pursue the development of significant solar resources similar to Virginia and face similar challenges meeting winter peak load demand. Doubling transmission import capacity as modeled in Plans C and D would also result in similar regional CO2 emissions as Alternative Plan B because the imported power from PJM would come in part from CO2-emitting generation.
Separate from the proposed build plans and related system upgrades, Alternative Plans B through D include foundational investments to transform the Company’s electric distribution grid to facilitate the integration of DERs, to enhance reliability and security, and to improve the customer experience (the “Grid Transformation Plan"). The Grid Transformation Plan will prepare the Company’s distribution grid to support the cleaner future envisioned by Virginia, North Carolina, and the Company. For example, with advanced metering infrastructure (“AMI") and a new customer information platform, the Company can offer advanced rate options to all customers across its system targeted at energy efficiency and demand reduction. A transformed grid will also support electric vehicle (“EV") adoption while minimizing the effect of EV charging on the distribution grid, thus maximizing the benefits of electrification. Foundational components of the Grid Transformation Plan, such as AMI, deployment of intelligent grid devices, advanced control systems, and a robust and secure telecommunications network, are necessary to integrated distribution planning that can produce inputs into future Plans.
The Company fully supports the transition towards clean energy without compromising reliability, and stands ready to meet the challenges discussed with continued study, technological advancement, and innovation. Importantly, as noted above, the first 15 years of Alternative Plans B through D present very similar paths forward; the dramatic differences between the Alternative Plans occur during the last ten years of the 25-year Study Period. This alignment between Alternative Plans B through D over the 15-year Planning Period creates a common pathway for the Company to pursue now while allowing new technologies to emerge and mature, and allowing analysis and study to continue. Accordingly, for this 2020 Plan, the Company recommends a path forward that substantially aligns with the first 15 years of Alternative Plans B through D. Over the longer-term, however, based on current technology and this “snapshot in time," the Company recommends Alternative Plan B.
Going forward, long-term integrated resource plans will evolve and will continue to support the cleaner future envisioned by public policy, by lawmakers, and by the Company. As noted, this future, while achievable, will require supportive legislative and regulatory policies, technological advancements, and broader investments across the economy. It will also require further study and analyses of necessary investments in the transmission and distribution systems to ensure the reliable electric service that customers expect and deserve. Overall, the Company’s deliberate transitional approach to a cleaner future has, and will continue, to provide customers a path to clean energy that meets public policy objectives while maintaining the standard of reliability necessary to power Virginia’s and North Carolina’s modern economies.