The Energy Plan needs to include an independent comprehensive grid transformation study that (1) provides recommendations on legislative changes and whether relative agency authorities are sufficient and (2) more broadly defines grid transformation than Dominion and the other public utilities do. In Virginia grid modernization is largely left in the hands of these for-profit utility monopolies. Thus, hundreds of millions of consumer dollars will continue to pay for projects that primarily benefit the shareholders of the utilities rather than the customers and the public. As clear from Dominion’s first filing with the State Corporation Commission, Dominion intends to use money it previously overcharged consumers for capital projects that “harden” the existing grid, rather than for projects that provide consumers choice, produce economic efficiencies, reduce the carbon footprint or in any way, create a truly modern grid.

Additionally, the Energy Plan need to promote solar and eliminate the existing barriers to solar. The recent energy legislation, SB966, has a number of significant flaws. It failed to set a sufficiently high target for solar. It also failed to remove a variety of barriers to third-party solar generation. These barriers impact the solar industry, local government solar, as well as residential and business solar. The 2018 Energy Plan should provide a robust review of these barriers and recommend legislative remedies and other reform. Remedies and reforms are especially critical to open the market for investment in distributed solar.

Thank you.