- Virginia's State Corporation Commission (SCC) on Wednesday approved Dominion Energy's plan for a time-of-use (TOU) rate experiment, including a Solar Incentive Program.
- Dominion's experiment could lay the groundwork for a systemwide rollout of TOU rates, the SCC noted in its order. But environmental and solar industry stakeholders, along with the Consumer Counsel in Virginia's Office of Attorney General, first want Dominion to refile its plan with more details.
"The Commission should have sent Dominion back to the drawing board to come back with a more fully developed plan," William C. Cleveland, senior attorney with the Southern Environmental Law Center (SELC), told Utility Dive.
Environmental concerns included a need for greater detail on how Dominion plans to collect, evaluate and use data from the experiment, as well as the company's plans to educate customers about the program.
"Our concern was not with the specific rate but rather with the companion pieces of the application," said Cleveland, who represented Appalachian Voices, the environmental respondent to Dominion's application.
A solar industry analyst also had reservations about Dominion's application.
"While the rate itself does provide an actionable price signal by including a 2:1 or greater ratio between on-peak and off-peak rates, which rewards behavior change, our greatest concern with this rate was the lack of outreach and education details associated with rolling out this rate to customers," Rachel Smucker, Virginia policy and development manager with the Maryland-DC-Delaware-Virginia Solar Energy Industries Association (MDV-SEIA), told Utility Dive in an email.
Although the commission approved Dominion's application, the company must submit EM&V and customer outreach and communication plans by Nov. 1, a move welcomed by Cleveland. Dominion's plan would begin Jan. 1, 2021, and include 10,000 participants in the TOU rate schedule, with a subset of 500 participants in the Solar Incentive Program.
Current Virginia regulations enable Dominion to add a variety of surcharges to customer's bills, he noted. But the utility now must prepare marketing materials that include a full disclosure of rates and surcharges, so customers get a clear picture of the true rate in the program.
"I would hope that future applications for time-varying rates are more fully formed and put customers first," Cleveland said.
"I think as we move to decarbonize power generation, we need to empower customers to better manage their utility use," he added.
The commission's decision approving the experiment requires Dominion to file an annual report each Dec. 31 that includes specific EM&V results of the TOU rate schedule through July 31 of that year.
The TOU rate schedule's energy charges would include on-peak, off-peak and super off-peak time periods, according to Dominion's application. Any hours not categorized as on-peak or super off-peak would be categorized as off-peak.
Dominion wrote that its load peaks between 3 p.m. and 6 p.m. during the summer. In non-summer months, the company's load peaks at 8 a.m. and again in the late afternoon or evening.
In response to stakeholder feedback, the TOU rate schedule would include off-peak and super off-peak periods on the New Year's Day, Memorial Day, Independence Day, Labor Day, Thanksgiving, and Christmas holidays.
The experimental TOU rate schedule is designed to be revenue neutral — the basic customer charge under the TOU rate schedule would be $6.58 per billing month, the same as Dominion's basic customer charge under its residential rate schedule.
Dominion's now must submit its EM&V and customer outreach and communications plans.
"We look forward to working alongside the Company and other key stakeholders moving forward to develop the details of the evaluation methods, the Outreach and Communications plan, bill protection measures, and other important modifications that should be implemented to ensure a successful TOU rate and robust customer adoption," MDV-SEIA's Smucker said.