RD740 - Chapter 591 - Shared Solar Workgroup Report to General Assembly – November 30, 2022
Executive Summary: During its 2022 General Session, the Virginia General Assembly enrolled, and the Governor signed Chapter 591 of the 2022 Virginia Acts of Assembly, directing the State Corporation Commission (SCC) to convene a stakeholder workgroup to evaluate shared solar programs for Appalachian Power Company (APCo) and Kentucky Utilities Company d/b/a Old Dominion Power Company (ODP). For this task, the SCC hired Sustainable Energy Advantage (SEA) to facilitate the stakeholder workgroup and prepare this report. SEA conducted four day-long stakeholder meetings, which in total consisted of seven different sessions. At each session, SEA solicited comment on various aspects of a potential shared solar program from 22 separate stakeholder organizations that included APCo and ODP, state agencies required by the enabling legislation, solar development interests, environmental advocates, and consumer advocates. The list of stakeholders that participated in the workgroup can be found in Table 1 of the body of this report. The topics covered by the seven sessions are listed below: 1. Discussion/Stakeholder Ranking of Overall Goals for the Process; In each session, SEA first presented on the regulations governing the existing Dominion Shared Solar program, to create a common understanding of a potential Virginia-specific shared solar program model for APCo and ODP. SEA then presented potential alternative program models from various shared solar offerings in other jurisdictions for stakeholders to comment on. Stakeholders were then offered the opportunity to ask clarifying questions on the presentation content prior to providing formal feedback. Opportunities were also provided for stakeholders to offer and discuss any program alternatives not contemplated by SEA in its review of shared solar potential alternatives. The process was not designed specifically to build consensus around a specific program design, but instead was intended to determine the areas upon which consensus exists on many of the technical and conceptual elements of shared solar programs. The formal feedback from the stakeholder groups (which have been anonymized to ensure maximum candor) is extensive in nature, and is therefore not herein summarized. Instead, that feedback, and the associated levels of consensus, can be found in the section of this report titled "Review of Stakeholder Discussion Sessions and Stakeholder Comments Regarding Potential Shared Solar Program Elements." Overall, there was a general agreement that any program for APCo and ODP must minimize costs, institute strong consumer protections, and leverage existing funding (including funding and/or tax credits available from the Inflation Reduction Act of 2022). There was also consensus that APCo and ODP’s customer bases differ significantly from Dominion’s, further enhancing the need for consumer protections, and that there should be further investigation of some mechanism to incentivize shared solar project siting on previously disturbed parcels of land. Most stakeholders were open to discussing a shared solar program further in settings beyond the confines of the stakeholder group process, since significant differences of opinion still remained regarding key structural aspects of a potential shared solar program. The participating stakeholders also identified other issues for further consideration and/or next steps, including, but not limited to: • Consideration of ways to incentivize siting shared solar on disturbed parcels of land; • How to measure the potential value of distributed energy resources in APCo and ODP service territories (though this was not explicitly endorsed by APCo or ODP); • Stakeholder coordination on how to best leverage funding from the Inflation Reduction Act of 2022; • Establishing a working group on how to develop an approach to “net crediting" that may apply to programs in APCo and ODP service territories; • Ensuring that the costs and benefits of any programs established within APCo or ODP service territories (and the degree to which consumers are protected within such programs) are evaluated several years after deployment, were such programs to be established by law. |