The staff of the Virginia State Corporation Commission recommends that regulators reject Dominion Energy Virginia's request to build and operate a 100-MW solar plant in Greensville County, Va.
The Dominion Energy Inc. subsidiary, known legally as Virginia Electric and Power Co., filed a petition July 23 for a certificate of public convenience and necessity, or CPCN, for the planned Sadler Solar Project. The utility also seeks expedited approval of cost recovery through a rate adjustment clause to be known as Rider US-4.
The staff wrote in testimony filed Oct. 22 with the SCC that it "does not recommend approval" of the requested certificate of public convenience and necessity for the project as filed. The staff said third-party power purchase agreements are "lower cost and lower risk" than the planned solar plant.
"[T]he company could have executed two solar PPAs totaling 100 MWs and received the exact same constellation of benefits as the proposed US-4 Solar Project," staff wrote. "Importantly, these benefits could have been attained at a much lower cost through these third-party solar PPAs rather than the company-build rate-based Sadler Solar."
Dominion has proposed a performance guarantee for the US-4 solar project that is based on the performance guarantee that the commission approved in a prior request.
The SCC issued an order in January giving conditional approval to the construction and operation of the 142-MW Colonial Trail West Solar Facility and the 98-MW Spring Grove 1 Solar Facility, together known as the US-3 solar projects, contingent on the utility accepting a 20-year performance guarantee.
"Should the commission determine to approve a CPCN for the US-4 Solar Project, staff recommends changes to the company's performance guarantee as filed in this case to more adequately address the performance risks associated with this project," staff wrote in its testimony.
The staff said Dominion's proposed performance guarantee "does not adequately address" energy production risk or the company's new capacity bidding strategy.
Dominion said in its application that its integrated resource plans have shown the need for solar generation resources to meet its forecast load growth. In addition, Virginia's Grid Transformation and Security Act supports the integration of 5,500 MW of new solar and wind generation by 2028.
(SCC docket PUR-2019-00105)