Dominion Energy Virginia plans to add nearly 24,000 MW of renewables and storage to its generation mix over the next 15 years to prepare for a cleaner energy future, but legislators behind a landmark Virginia law believe the utility needs to do more.

"Other utilities have risen to the challenge such as [Xcel Energy Inc.] in Minnesota, [Consumers Energy Co.] in Michigan, and [Eversource Energy] in Massachusetts, and Dominion should follow suit and further expand its investment in clean energy deployment and energy efficiency," Sen. Jennifer McClellan and Del. Rip Sullivan said in a May 9 joint statement.

The Dominion Energy Inc. subsidiary, known legally as Virginia Electric and Power Co., in its 2020 integrated resource plan, or IRP, laid out plans to add about 5,100 MW of offshore wind, nearly 16,000 MW of solar and about 2,700 MW of energy storage to its portfolio through the end of 2035.

The 2020 IRP, filed May 1 with the Virginia State Corporation Commission, is largely designed to align with the Virginia Clean Economy Act while preserving certain baseload generation units.

"We have an obligation to serve our customers with safe, reliable energy. We are conducting an analysis to determine how we meet that obligation while expanding renewable energy to lower carbon," Dominion spokesman Rayhan Daudani said in a May 13 email.

Daudani added that Dominion is "on a trajectory" to achieve net-zero carbon dioxide and methane emissions by 2050 for both its power generation and natural gas operations, as well as meet the state's clean energy goals.

On the company's first-quarter 2020 earnings call, Dominion executives said they see about $9.9 billion in investment potential through 2024 tied to the new state law, which takes effect July 1. Management outlined about $19 billion in potential investments in primarily solar generation along with onshore wind through 2035.

Dominion Energy Virginia's updated capital plan includes spending $3.5 billion on offshore wind through 2024 with a total potential investment of $8 billion to $17 billion from 2020 through 2035.

In September 2019, Dominion Energy Virginia announced plans to build the "largest offshore wind project" in the U.S. off the coast of Virginia Beach in three phases of 880 MW each. If approved, the first phase of the $8 billion Virginia Beach Offshore Wind Project would be completed in 2024, with the final phases expected to come online in 2025 and 2026.

Dominion forecasts a second, large-scale offshore wind project will come online by 2035.

The lawmakers who crafted the Virginia Clean Economy Act, however, say the utility's resource plan falls short.

"The VCEA requires Virginia utilities to step up to the plate and be active leaders in carbon reduction. Dominion Energy's IRP is tantamount to quitting the game before the first pitch is thrown," McClellan and Sullivan wrote. "The law sets clear benchmarks for Virginia to reach 100[%] clean energy by 2045, not for utilities to plan to import carbon-polluting energy from West Virginia or Kentucky."

The legislation requires Dominion Energy Virginia to procure 100% of its electricity from renewable resources by 2045, while American Electric Power Co. Inc. utility Appalachian Power Co. must hit that benchmark by 2050.

The law requires the utilities to have retired all electric generating units in Virginia that emit carbon by Dec. 31, 2045.

Dominion Energy Virginia and Appalachian Power must retire all oil plants with a capacity of more than 500 MW and "all coal-fired electric generating units operating in the Commonwealth" by Dec. 31, 2024. The bill provides an exception for coal plants co-owned with a cooperative utility and for Dominion Energy Virginia's 624-MW Virginia City Hybrid Energy Center, which co-fires with biomass.

Dominion's IRP models the retirement of its 1,032-MW Chesterfield coal plant and 792-MW Yorktown oil unit by 2024, along with the retirement of three biomass plants by 2028.

The company, however, has said its "most likely plan" will preserve 9,700 MW of natural gas-fired generation with "placeholders" for two 485-MW natural gas plants.

"We see the potential development of 970 [MW] of natural gas peaking generation to address probable system reliability issues resulting from the addition of significant renewable energy resources and the retirement of coal-fired facilities," Daudani said. "Additionally, based on limitations, such as existing battery storage technology and the variable nature of renewables, natural-gas fired generation will continue to play a critical, low emission role in our system for decades to come."

Dominion also forecasts importing capacity to meet demand.

"In addition to challenges related to winter capacity, development of significant volumes of solar generation also present challenges related to energy," Dominion Energy Virginia wrote in its IRP. "Specifically, the company would likely need to import a significant amount of energy during the winter, but would need to export significant amounts of energy during the spring and fall."

A new energy efficiency standard in the Virginia Clean Economy Act sets a 5% energy savings target for Dominion and a 2% target for Appalachian Power by 2025, both from 2019 levels.

Dominion also is tied to $870 million in proposed energy efficiency spending by 2028 as required by the Grid Transformation and Security Act of 2018.

McClellan and Sullivan say Dominion's plan "underutilizes energy efficiency" and overestimates costs to Virginia ratepayers.

"Virginians need Dominion to respect and adhere to the intent of this landmark legislation to grow clean energy jobs and stop the worst impacts of climate change from further harming Virginia's economy," the lawmakers wrote.

In its IRP, Dominion includes a residential bill analysis that shows the bill for a typical residential customer in Virginia using 1,000 kWh of electricity per month was $122.66 at the end of 2019. The utility's analysis projects the typical residential bill will increase by about 2.9% "on a compound annual basis," for a total bill increase of $45.92, by the end of 2030.

"[A]bout 40% of the projected bill increase from 2020 to 2030 is associated with investments incentivized or mandated by the VCEA and other legislation from the 2020 Regular Session of the Virginia General Assembly," the utility wrote.

Daudani noted that the resource plan "is a snapshot in time based on existing technology, costs and policies."

"Beyond the 15-year planning period, the company presents several alternatives to reduce carbon and provide safe, reliable and increasingly clean energy to its customers. Achieving these goals will require supportive legislative and regulatory policies, technological advancements, grid modernization, and broader investments across the economy," Daudani said.

Dominion contends there needs to be support and improvement in the "testing and deployment" of carbon capture and sequestration, utility-scale energy storage, hydrogen and advanced nuclear technology, which all "have the potential to significantly reduce greenhouse gas emissions."