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Virginia SCC Staff Generally Unopposed To Dominion Utility Renewable Tariff That Would Trigger Cessation Of Provision Allowing Retail Suppliers To Offer Service Under 100% Renewable Exception

November 1, 2019

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Copyright 2010-19
Reporting by Paul Ring •

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Staff of the Virginia State Corporation Commission filed testimony which generally did not oppose the proposed 100 percent renewable energy tariff filed by utility Dominion Energy (Virginia Electric and Power Company).

As previously reported, Virginia does not allow for retail electric choice, except under limited exceptions

One of the exceptions allows a customer of any size to take service from a competitive supplier for 100% renewable energy if the utility does not have a qualifying renewable energy tariff to provide customers with 100% renewable energy. As previously reported by, several retail suppliers have recently enrolled customers under this exception

Dominion's 100 percent renewable tariff filing, if approved by the SCC, would mean customers would no longer be able to take service, under "new contracts", from a retail supplier under the 100% renewable energy exception

Staff found that Dominion's proposal would meet the statutory standard of providing customers with 100% renewable energy, and complies with various recent Commission precedents regarding renewable energy programs

Staff testified that, "On advice of legal counsel, if the Commission approves proposed Rider TRG as a tariff for electric energy provided 100 percent from renewable energy, the Company's customers would no longer be permitted to purchase electric energy from licensed retail providers, also known as competitive service providers ('CSPs') pursuant to new contracts under § 56-577 A 5."

Under the proposed program, known as Rider TRG, Dominion (DEV or the "Company" said that customers will receive 100 percent of their energy and capacity from a portfolio of resources ("TRG Portfolio") owned or contracted for by the Company that meet the definition of renewable energy in the Code.

Customers electing to participate in Rider TRG will pay a premium over standard service that DEV states is based on the prevailing market value of retail renewable energy, using the market value of RECs as a proxy for this premium. Currently, DEV proposes a TRG Premium of 0.4210 per kWh, or $4.21 per MWh.

The Company additionally states that participating customers will also pay a 'balancing charge' that credits the generation component of base rates, fuel, and generation riders in amounts to hold nonparticipating customers harmless, including any future generation riders that may be approved.

As proposed, participating customers will still be required to continue to pay their standard tariff for all wires-related charges for transmission and distribution service.

According to the Company, customers must have a peak demand of less than five megawatts (MW) in order to be eligible to receive service under proposed Rider TRG.

In response to a Staff interrogatory, Dominion said that the eligibility limitation is to allow for broader participation among smaller customers, "who do not currently have as many options available for the procurement of renewable energy."

"Staff takes no position on this limitation, however Staff would like to note for the record that all customers, regardless of peak demand, currently have access to options for renewable energy purchased from licensed CSPs pursuant to § 56-577 A 5 of the Code," Staff said

Staff offered various recommendations concerning DEV's program, but nothing which prompted Staff to oppose the program (and some of which DEV has already agreed to).

As a general matter, Staff believes the Company should be required to seek Commission approval prior to the inclusion of additional resources in the TRG Portfolio in the future.

Staff also believes that the Company is required to seek Commission approval prior to altering the rate assessed to participating customers.

Case No. PUR-2019-00094

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