Dive Brief:

• Staff of the Virginia State Corporation Commission are questioning the assumptions Dominion Energy used in estimating the full cost of developing 2.6 GW of offshore wind, according to testimony filed on Friday.
• While largely redacted, the staff testimony questions whether Dominion will have more generation than needed, cannibalizing other power generation capacity. Those costs, and others, are not currently considered in calculating the levelized cost of energy for the project, which is capped by the Virginia Clean Economy Act at $125/MWh.
• Other testimony questions the utility-owned model itself, asking state regulators to consider alternative forms including power purchase agreements and renewable energy credits. The development will be the first large-scale utility-owned U.S. offshore wind project.

Dive Insight:

Other calculations of project cost, such as an incremental LCOE, "would exceed $125/MWh in 2027 dollars in all scenarios tested by Staff," by calculating the net energy addition of offshore wind to the system and accounting for the dispatch cost savings of fossil-fueled generation that would be curtailed or idle, according to the testimony of Katya Kuleshova, a strategic planning specialist with SCC's division of public utility regulation.

On March 25, testimony on behalf of the Virginia Office of the Attorney General from energy consultant Scott Norwood, flagged concerns that Dominion was using a social cost of carbon estimated at $3.2 billion to justify the price of the project and claim a $2.5 billion cumulative benefit to customers based on the project's net present value.

SCC staff, like the AG testimony, also questioned the customer benefit. Staff calculated total customer benefits to be approximately half of the project's cost, representing a net present value for the project as a $1.6 billion loss, if using a different price forecast for renewable energy credits than what the utility proposed.

"Offshore wind’s zero fuel cost and transformational economic development and jobs benefits are needed now more than ever," Jeremy Slayton, Dominion spokesperson, said.

The utility also pointed out that the parties intervening in the docket, who can see redacted figures and estimates under a non-disclosure agreement, had not opposed approval of the project.

"We are pleased all parties to the case have focused on ways to have the best possible project and none have opposed it," Slayton said.

Others besides the AG testimony have also issued concerns about an overestimation of customer benefits.

The utility has forecast the project will have nearly $9.8 billion in capital costs, and the SCC should set clear guidance that the utility "would be at risk for the recovery of excess costs," according to testimony on behalf of Clean Virginia from Max Chang, a principal associate at Synapse Energy Economics, on March 25.

In addition, Chang's testimony highlighted the need to consider other procurement methods, such as a PPA. Others have commented similarly outside of the docket as well.

"If this was Ørsted's money and a PPA, I might be a little more comfortable," said Steve Haner, senior fellow of the Virginia-based public policy group, Thomas Jefferson Institute.

In contrast to PPAs, Dominion's customers must pay charges which recover the full cost of the project even if no energy is provided, in the event of an extended outage, or if the energy supplied is lower than what was intended in the project proposal, Norwood wrote in his testimony.

While other public policy groups on the East Coast are watching for cost shifts and price increases in large projects, the Virginia development stands out due to the cost recovery mechanism on the project. "It's just that the utility's building it like it would build any other power plant and paying for it by charging the ratepayers," Haner said.

However, in December, the Virginia Department of Energy published a report on modeling decarbonization, concluding that an expansion of commercial and residential solar would be cheaper than meeting the state's offshore wind and energy storage targets.

"Eliminating the capacity targets for expanded offshore wind and for electricity storage, and allowing deployment of these resources to be guided by investor decisions about how to meet the RPS and RGGI requirements cost-effectively will likely save money for ratepayers," the report said.

According to Virginia Department of Energy modeling, the offshore wind and energy storage targets could exceed the least-cost strategy by $250 million per year by 2035, and $450 million by 2040.

The SCC will accept public comments on the project until May 16.