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Dominion Green Power Program improvements

Whereas: The EPA honored Dominion in 2013 with an award for its Green Power program, due to the number of customers that signed up.  There are two likely reasons for the high number of subscribers.  One is that Dominion customers have few other options for renewable energy.  The other is Dominion’s advertising of the program, which claimed “a direct impact on the growth of green energy in Virginia and throughout our region”.

Dominion’s Spring 2013 greenBEAT publication shows 482 GWh purchased in RECs through the program, or over $6M that customers voluntarily invested to support local renewable energy.  The November 2012 program flyer stated it would support local green energy: “wind, solar and biomass produced in our region”, with a map of Virginia, West Virginia, Maryland and Delaware.  In fact, 64% of the wind credits came from existing facilities in Indiana and Missouri, and none came from Virginia.  The same flyer claimed Green Power will “expand development” of renewables, when in fact no facilities were developed.  The program 2011 target was 1% solar from Virginia.  The renewable energy credits (RECs) purchased in 2011 included only 0.11% solar.  Thus, Dominion oversold the solar contribution of the program by a factor of 9, as well as only buying RECs rather than developing new renewable generation.  The remaining RECs from Virginia were 24% biomass.  Recent research shows biomass plants can emit greater quantities of CO2 and other pollutants than fossil fuel generation.  A related court ruling determined that biomass is not exempt from regulation by the EPA.

As presented in Virginia SCC case PUE-2012-00064, half of Green Power funds, or $3M, has gone to Dominion’s own advertisements administration, and education, rather than toward renewable energy or credits. Dominion has collected $6M in voluntary contributions without building a single wind or solar facility to supply the program. PUE-2012-00064 also revealed that Dominion plans to use Green Power contributions to fund more than 70% of the cost of new installations under the Solar Partnership Program, thus undervaluing the solar electricity generated, very probably over-taxing Green Power funds and decreasing the net clean energy benefit of these programs combined.

By not disclosing all the facts on this program’s implementation, Dominion faces a high reputational risk due to potential public exposure and customer and investor backlash for misrepresentation.  Examples include efforts to have the EPA rescind the award, and to distribute lawn signs and bumper stickers ridiculing Dominion’s stance on renewables.

Resolved: The shareholders request that the Dominion board appoint a committee that includes outside renewable energy experts and Green Power customers, to develop options for Green Power program changes that would develop local renewable energy, provide current and complete financial and energy generation information to all customers, and/or gives customers information on other ways to support development of renewable energy.  A report on these options, prepared at reasonable cost and omitting proprietary information, shall be available to shareholders by December 1, 2014.