Ivy Main: “Not surprisingly, Dominion Energy and Appalachian Power are seizing this opportunity to push for changes that would undermine the economic calculus supporting customer-owned solar.”

Great stuff as always by Ivy Main; cross posted from her consistently excellent blog, Power for the People VA

Virginia’s investor-owned utilities thought 2025 would be the year they put an end to net metering – and with it, rooftop solar installers’ modest competition with their monopoly.. The 2020 Virginia Clean Economy Act (VCEA) removed many barriers that residents and businesses installing solar panels under the state’s net metering law had faced, but it also called for the State Corporation Commission to reevaluate the program, beginning right about now.

Not surprisingly, Dominion Energy and Appalachian Power are seizing this opportunity to push for changes that would undermine the economic calculus supporting customer-owned solar.

Since at least 2007, Virginia law has required that customers of Dominion and APCo who have solar panels on their property be credited for surplus electricity they supply to the grid at the same retail rate they pay for electricity. The credit is applied against the cost of the electricity the customer draws from the grid at times when the panels aren’t generating, reducing what they owe on their electric bill.

But now that they have the chance, both utilities have filed proposals to end net metering. Both essentially propose to charge new solar customers the full retail rate for the electricity they draw from the grid (with Dominion using a more complicated half-hour “netting”), but compensate them for electricity fed to the grid only at the utility’s “avoided cost,” or what it pays to buy electricity from other generators. By law, existing customers and new low-income customers with solar would be unaffected.

APCo calculates avoided cost as the wholesale cost of energy and capacity, plus transmission and ancillary services, for a total of less than 5 cents per kilowatt-hour. Thus, a homeowner with solar panels would now pay the full retail rate of about 17 cents/kWh for electricity drawn from the grid, while being credited at less than one-third that amount for electricity put back on the grid.

Dominion’s approach instead pegs avoided cost to what it pays for solar generation and associated renewable energy certificates (RECs) bought from certain small producers under power purchase agreements, an average of about 9.5 cents/kWh. Dominion’s residential rate currently averages about 14 cents/kWh, but would go up to more than 16 cents if its latest rate increase request is granted.

The VCEA gave APCo the first swing at the piñata. APCo filed its proposal in September, and the SCC will hold an evidentiary hearing on May 20. Dominion only filed its petition last week, and no hearing date has been set yet.

Not surprisingly, APCo’s proposal generated fierce opposition from advocates and solar installers. They point out that it’s hard enough to make the economics of home solar work with net metering at the retail rate; slashing the compensation for electricity returned to the grid by more than one-third, as Dominion proposes, or two-thirds, as APCo wants, would make solar a losing proposition for most homeowners. Maybe economies of scale and other factors would allow the market for commercial solar to survive under Dominion’s program, though Dominion’s insistence on confiscating customers’ RECs won’t make anyone happy.

If solar owners definitely lose under APCo’s plan, advocates say other ratepayers don’t necessarily win. A homeowner’s surplus generation travels only the short distance to the nearest neighbor, lessening the need for the utility to generate and transmit power to meet the neighbor’s demand. Since the utility charges that neighbor the regular retail rate for the electricity, without having to bring it from somewhere else, the utility saves on transmission costs. On top of that, the surplus solar comes in during the day, when demand is typically higher than at night and electricity is more costly, making solar more valuable to the utility. Plus, it is clean and renewable, and the customer bears all the cost and risk of the investment.

Utilities do not share this rosy view. By their way of thinking, solar customers use the grid as free energy storage and backup power, without paying their fair share of grid costs. Not only does this deprive the utility of revenue, but those grid costs now have to be spread out among the remaining customers. This, they say, creates a cost shift from solar owners to everyone else.

More than a decade ago, Virginia took tentative steps towards resolving the dispute, with the Department of Environmental Quality setting up a stakeholder group to work towards a “value of solar” analysis. The process was never completed — the utilities walked away from the table when it appeared the results weren’t going to be what they wanted, and the group’s work product did not include numeric values or policy recommendations.

Virginia is hardly alone in navigating these clashing narratives.

Other states and regulators have arrived at very different conclusions as to the “correct” value of distributed solar to utilities, ratepayers, and society as a whole. States like Maryland kept net metering after a value of solar analysis concluded the benefits outweighed the costs. On the other hand, California famously ended its net metering program in 2022 when solar comprised almost 20% of electricity generated in the state and created a mid-day surplus without enough storage to absorb it; at the time, 45% of that solar was distributed. That same year, however, Florida Gov. Ron DeSantis vetoed an unpopular bill that would have phased out net metering in the state.

The experience of other states, combined with an abundance of research and analysis conducted over the years, gives the SCC a lot to work with as it considers the fate of net metering for APCo’s customers this year, and later for Dominion’s.

Countering the arguments of the utility’s hired witnesses, solar industry and environmental organizations have weighed in on the APCo docket with testimony from experts with nationwide experience. The experts pointed out a range of errors and omissions in the utility’s work product. They also presented their own benefit-cost analyses demonstrating a value for distributed solar in excess of the retail price of electricity, using tests often applied to energy efficiency and demand-response programs.

Perhaps even more significantly, SCC staff also filed an analysis that found many of the same problems with APCo’s proposal, including failures to comply with statutory requirements. The staff report did not include a quantitative analysis, but it urged the importance of considering benefits that APCo had ignored. Like the intervenors, staff recommended the commission reject APCo’s plan and retain its net metering program as it is, at least for now.

Although the staff report would seem likely to carry weight with the commissioners, it’s never easy to predict what the SCC will do in any case before it. But in Virginia, unlike California, distributed solar makes up vanishingly little of total electric generation. Even taking the utilities’ arguments at face value, it seems foolish to upend this small but important market to remedy a perceived harm that is, at least for now, more theoretical than real.

This article originally appeared in the Virginia Mercury on May 8, 2025.