Dive Brief:

• Dominion has filed its Integrated Resource Plan with Virginia regulators, outlining how it intends to supply power to millions of customers, but the company highlighted the uncertain environment it faces in anticipation of the federal government's final Clean Power Plan regulations.
• The plan, filed with both Virginia and as an update in North Carolina, predicts annual increases in future peak and energy requirements of 1.5% and 1.3%, respectively.
• The utility proposes four different compliance plans, utilizing a mixture of proven resources as well as technologies Dominion considers to still require wide-scale testing like solar energy.

Dive Insight:

Dominion has submitted an integrated resource plan that outlines four different ways the company could supply power while complying with the federal government's plan to reduce greenhouse gas emissions. Interestingly, it still defines solar power as a resource in need of testing. And the utility repeatedly refers to the "uncertainty" caused by the Clean Power Plan, using the word 10 times in its proposal.

"Although proven as a stand alone technology, large quantities of solar in a given electric generation, transmission and distribution portfolio could induce operational challenges because it is non-dispatchable hour-to-hour intermittent generation," the company told regulators.

"More study is necessary," Dominion said of the resource, although each of its plans do include increases in utility-scale solar generation.

The proposal went on to praise coal fired generation for its ability to provide consistent baseload generation and store ample fuel on site. The utility indicated that its primary plans do not anticipate the retirement in the coming years of any coal fired power plants, and noted that SB 1349, a bill it sheparded through the Virginia legislature earlier this year, encourages Dominion to keep "coal as a significant part of the Company’s generation portfolio for as long as possible, recognizing the regulatory threat to existing coal units posed by the [Clean Power Plan]."  

In one plan, Dominion calls for large amounts of solar generation. A second plan utilizes coal generation with 25% natural gas combined with solar resources. A third plan calls for nuclear generation, and the fourth banks on both on- and off-shore wind facilities.

But Dominion also put together a plan to demonstrate that the Clean Power Plan would raise its costs: "The Least Cost Non‐Compliant Plan would not represent a viable alternative because it does not meet the EPA’s proposed CPP requirements and is presented in this document for comparison purposes only," Dominion officials wrote.

All of the plans call for at least 400 MW of nameplate solar generation. The utility's proposal, which anticipates utilizing a mix of the plans, also calls for demand side management programs potentially reaching 600 MW by 2030.