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Direct Testimony of Tim Woolf and Erin Malone Regarding Virginia Power and Electric Company's Application to Implement DSM Programs
On behalf of Sierra Club, Synapse reviewed and critiqued the DSM Programs proposed by the Virginia Electric and Power Company (Dominion). Our testimony focuses on how well the proposed DSM programs comply with statutory and regulatory requirements, the proposed DSM program spending and savings levels, DSM cost-effectiveness, and DSM program design. Virginia’s Grid Transformation and Security Act requires Dominion to spend $870 million on energy efficiency between 2018 and 2021. The Company only proposed a budget of $262 million for its 2019-2023 DSM programs, which includes lost revenues. We argue the Company should increase its budgets and remove lost revenues from that budget to meet the statutory budget requirement. Based on the Company's potential study and energy efficiency program efforts in other states, there are plenty of savings available with an increased budget. The cost-effectiveness screening practices in Virginia could also be improved, including to account for all costs and benefits in each of the tests used in the state, and to evaluate rate and bill impacts more comprehensively than relying on the Rate Impact Measure test.