Dominion needs batteries, not gas 

CHARLOTTESVILLE, Va.—On Friday, the Southern Environmental Law Center, on behalf of Appalachian Voices, filed the testimony of three experts in Dominion’s Integrated Resource Plan, or IRP, before the Virginia State Corporation Commission.  

At its core, Dominion’s long-term plan projects how much electricity the utility will need and then uses modeling software to determine the most economical way to meet those needs given applicable policies. This modeling provides a foundation to further evaluate anticipated impacts. 

To understand the limitations of Dominion’s IRP, SELC engaged multiple experts. 

James F. Wilson focused on forecasting of electricity needs; Nicholas D. Laws, Ph.D., and Joshua D. Rhodes, Ph.D., of IdeaSmiths LLC analyzed Dominion’s model and created their own suite of scenarios; and Michael Goggin of Grid Strategies LLC, focused on several issues including battery capabilities and other modeling assumptions.  

Key findings include: 

The need to better assess electricity demands in the face of vast uncertainty. Dominion projects massive increases in electricity needs due almost entirely to data center growth. Wilson’s testimony highlights the extreme uncertainty associated with Dominion’s data center forecasts, which may be significantly overestimating the degree to which long-term load will increase. To address this issue, Wilson recommends a number of improvements, including (a) requiring the utility to hire a qualified, independent forecaster to develop a wide range of scenarios to better reflect the significant market uncertainty and (b) requiring data centers to enter into long-term contracts to ensure non-data center customers are not left holding the bag for investments to serve data centers that might never come to fruition. 

The importance of modeling policy compliance. Dominion presents several modeling scenarios, all of which fail to account for the legal requirement that its fleet be carbon free by 2045. As a result, all of Dominion’s scenarios build approximately 6 gigawatts of new gas generation at a time when the law requires the utility to transition to zero-carbon power sources.  

As set forth in Laws’ testimony, a team of experts at IdeaSmiths analyzed Dominion’s modeling and determined that the utility’s plans that only extend through 2039 are of limited value to the Commission. The IdeaSmiths team then created an alternative model to provide additional information to the Commission. Even accepting Dominion’s highly uncertain load forecast, the IdeaSmiths’ report demonstrates that when the model can “see” the 2045 zero-carbon requirement, it chooses a very different path forward than Dominion’s short-horizon model. Most notably, and contrary to Dominion’s assertions, the IdeaSmiths team determined there are ways to meet future energy needs and continue to comply with the law, including the 2045 zero-carbon requirement. Instead of building gas, Dominion should build batteries faster and at larger scale. While additional nuclear will likely be needed in the future, investing in batteries now will free up valuable time—about a decade—for the Commission to assess actual energy needs and how best to meet those needs, whether through new nuclear projects or other developing technologies. Dominion did not model many of these developing technologies that could reduce the amount of new nuclear needed, such as solar plus storage, long-duration energy storage, and virtual power plants.  

The benefits of batteries. The IdeaSmiths report offers a “no regrets” pathway for customers, maximizing cost-effective batteries that provide numerous grid benefits while avoiding new gas, which remains a very risky proposition for customers. Separately, Goggin recommends several improvements to Dominion’s modeling assumptions, including removing arbitrary and unsupported limits on solar and battery projects. He also describes the numerous benefits of batteries, which are highly modular and flexible, can be connected to the grid faster than other resources, and can obviate or reduce the need for transmission upgrades. Moreover, as set forth by Goggin, batteries match or exceed the reliability benefits associated with gas plants. 

The toll of air pollution on environmental justice communities. While Dominion’s plan provides no analysis of health effects, the IdeaSmiths team analyzed the health effects of Dominion’s gas-heavy plans. Based on this analysis, IdeaSmiths estimates that the utility’s plans impose between $7.4 billion and $13.9 billion in detrimental health effects, including by using county-specific data to estimate impacts from existing power plants that have already burdened fence line communities for years and will continue to do so under Dominion’s plans. IdeaSmiths also showed that Dominion’s plans do not actually reduce emissions long-term; by 2036 or 2037, annual emissions will be virtually the same as emissions in 2024. Under IdeaSmiths’ compliant pathways, however, emissions would reach zero in 2045. 

The fuel savings clean energy technologies provide. Fuel costs represent a major and often volatile component of customers’ bills. IdeaSmiths extended Dominion’s 2039 plans to 2045 and then compared the fuel costs in 2045 between Dominion’s plans and IdeaSmiths’ compliant plans. This analysis shows that following a compliant pathway like IdeaSmiths’ plans could yield huge annual fuel savings for customers—likely several billion dollars a year. 

The State Corporation Commission will hold a hearing beginning April 15, 2025, where the parties will present their evidence.  

“We look forward to presenting our case,” said Senior Attorney Nate Benforado. “We believe the evidence will show that Dominion can comply with the law and do so in a way that is good for customers—creating a reliable, carbon-free system that is significantly cheaper to operate. To do that, Dominion needs to ramp up batteries, not gas.” 

The hearing is open to the public and will likely continue for multiple days. Members of the public are also invited to submit written comments by April 8, 2025, on the Commission’s website or submit oral comments by telephone. Members of the public who wish to provide telephonic comments must register in advance by April 8, 2025.