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Comments re: PUR-2024-00211

Chesapeake Climate Action Network Comments re: Direct Transfer Trip Requirements

Virginia has immense energy demands, regular clean energy procurement targets, and annual Renewable Portfolio Standard (RPS) requirements. Dominion’s imposition of direct transfer trip (DTT) requirements for mid-size solar arrays negatively impacts the state’s ability to meet all three of those statutory needs. Given that alternatives are readily available, cheaper, and in use all over the country to perform the same functions as DTT – when such functions are indeed necessary, which they are often not for these smaller projects – there is little justification for the DTT requirements in Dominion territory. Such requirements are unnecessary and proven to stifle mid-size rooftop solar development, a key ingredient in Virginia’s clean energy future.

This is not an abstract concern. Numerous school systems have testified that they have existing plans for projects that will help lower costs and free up resources for students – projects that are imperiled by onerous DTT requirements. 

For example, Albemarle County Public Schools (ACPS) successfully stood up rooftop solar arrays on nine middle, high, and elementary schools prior to the imposition of DTT requirements. With plans for nine more – including two new buildings that have expended significant resources to achieve net zero emissions, in part through the use of rooftop solar – ACPS is concerned that DTT requirements will prohibit their ability to meet legal requirements for new public buildings imposed by Virginia’s High Performance Building Act. Moreover, the requirements ultimately prevent cost-savings for public school systems, as evidenced by the over $300,000 saved by Henrico County Schools thanks to existing rooftop solar arrays.

Distributed energy resources (DERs) like these affected rooftop solar projects play an important role in the utility’s ability to meet Virginia Clean Economy Act goals, including clean energy procurement targets. The achievement of VCEA clean energy procurement targets is also necessary to facilitate RPS compliance, and significant new generation is needed to meet the state’s immense energy needs. On behalf of the undersigned CCAN members, we respectfully ask that the Commission reject Dominion’s DTT requirements and develop more reasonable grid safety standards consistent with peer utilities.

*Source: Direct Testimonies of Dr. Anthony E. Smith, Catherine L. Redson, Madison T. Irving, M.S.Ed., Karl Frisch., John L. Coles, Bryson Rupnik, and John E. Taylor on behalf of the Virginia Distributed Solar Alliance. https://www.scc.virginia.gov/docketsearch/DOCS/879h01!.PDF