Dominion Energy RGGI Rider Request

(9Cu~H
Virginia State Corporation Commission

eFiling CASE Document Cover Sheet
Case Number (if already assigned) PUR-2020-00169
Case Name (if known) Petition of Virginia Electric and Power Company, For
approval of a rate adjustment clause, designated Rider
RGGI, under § 56-585.1 A 5 e of the Code of Virginia
Document Type £_X^£.
Document Description Summary Petition of Virginia Electric and Power Company and
Request for Limited Waivers
Total Number of Pages 100
Submission ID 20299
eFiling Date Stamp 11/9/2020 3:03:40PM

McGuircWoods LLP
Galeway Plaza
800 East Canal Street
Richmond, VA 23219-3916
Phone: 804775.1000
Fax: 804.775.1061
www.mcgulrewoods.com
Elaine S. Ryan
Direct: 804.775.1090 McGUIREWOODS erya n ® m cgu i rewoods
November 9, 2020
BY ELECTRONIC DELIVERY
Bernard Logan, Interim Clerk

State Corporation Commission
Document Control Center
Tyler Building, First Floor
1300 East Main Street
Richmond, Virginia 23219
Petition of Virginia Electric and Power Company, For approval of a rate adjustment clause,
designated Rider RGGI, under § 56-585.1 A 5 e of the Code of Virginia
Case No. PUR-2020-001.69
Dear Mr. Logan:
Please find enclosed for electronic filing in the above-captioned proceeding the Petition
of Virginia Electric and Power Company and Request for Limited Waivers.
Please do not hesitate to call if you have any questions in regard to the enclosed.
Highest regards,
/s/ Elaine S. Ryan
Elaine S. Ryan
Enclosures
cc: William H. Chambliss, Esq.

Arlen Bolstad, Esq.
C. Meade Browder, Jr., Esq.
Paul E. Pfeffer, Esq.
David J. DePippo, Esq.
Joseph K. Reid, U.l, Esq.
Sarah R. Bennett, Esq.
Dan Bumpus, Esq.
Atlanta | Austin | Baltimore | Brussels j Charlotte | Charlottesville | Chicago | Dallas | Houston | Jacksonville | London | Los Angeles - Century City
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m
Dominion
Energy9
Petition of
Virginia Electric and Power
Company
Before the State Corporation
Commission ofVirginia
For approval of a rate adjustment

clause, designated Rider RGGI, under
§ 56-585.1 A 5 e of the Code of
Virginia
Volume 1 of 1
Case No. PUR-2020-00169
Filed: November 9,2020

Petition of Virginia Electric and Power Company
For approval of a rate adjustment clause, designated Rider RGGI,
under § 56-585.1 A 5 e of the Code of Virginia
Case No. PUR-2020-00169
TABLE OF CONTENTS
Petition
Direct Testimony of C. Eric McMillan
Direct Testimony of Shane T. Compton

Company Exhibit No., STC, Schedule 1 -CO2 Volume Forecast
Direct Testimony of John C. Ingram

Company Exhibit No., JCI, Schedule 1 - Rider RGGJ Revenue Requirement
Direct Testimony of Paul B. Haynes

Company Exhibit No., PBH, Schedule J - Allocation Factors
Company Exhibit No. , PBH, Schedule 2 - Rate Design
Company Exhibit No. , PBH, Schedule 3 - Rider RGGI Tariff Sheet
Company Exhibit No., PBH, Schedule 4-Typical Bills
Company Exhibit No., PBH, Schedule 5 - Typical Residential Bill
Filing Schedule 46A Sponsored by Company Witnesses C. Eric McMillan and

Shane T. Compton
Statement 1 Projected Costs by Type of Cost

Statement 2 Documentation Supporting Projected Costs
Filing Schedule 46B Sponsored by Company Witness John C. Ingram
Statement I Rider RGGI Revenue Requirement

Statement 2 Accounting Procedures and Internal Controls
Filing Schedule 46C Sponsored by Company Witness Paul B. Haynes
Statement 1 Methodology of Allocation of the Revenue Requirement and Rate

Design
COMMONWEALTH OF VIRGINIA
STATE CORPORATION COMMISSION
PETITION OF )
)
VIRGINIA ELECTRIC ANDPOWER COMPANY )
) Case No. PUR-2020-00169
For approval of a rate adjustment clause, )
designated Rider RGGI, under § 56-585.1 A 5 e )
of the Code of Virginia )
PETITION OF VIRGINIAELECTRIC AND POWER COMPANY

AND REQUEST FOR LIMITED WAIVERS
Virginia Electric and Power Company (“Dominion Energy Virginia” or the “Company”),
by counsel, hereby files with the State Corporation Commission of Virginia (“Commission”) its
petition for approval of a rate adjustment clause (“RAC”), designated Rider RGGI, under § 56-
585.1 A 5 e of the Code of Virginia (“Va. Code”) to recover projected and actual costs related to
the purchase of allowances through the Regional Greenhouse Gas Initiative (“RGGI”) market-
based trading program for carbon dioxide (“CO2”) emissions, a program in which the Company
is required to participate. The Company further requests limited waivers of certain Rules
Governing Utility Rate Applications and Annual Informational Filings (the “Rate Case Rules”).
In support of its petitions and request for limited waivers (collectively, the “Petition”), the
Company respectfully shows as follows:
GENERAL INFORMATION
I. Dominion Energy Virginia is a public service corporation organized under the
laws of the Commonwealth of Virginia furnishing electric service to the public within its
certificated service territory. The Company also supplies electric service to non-jurisdictional
customers in Virginia and to the public in portions of North Carolina. The Company is engaged
in the business of generating, transmitting, distributing, and selling electric power and energy to
the public for compensation. The Company is also a public utility under the Federal Power Act,
and certain of its operations are subject to the jurisdiction of the Federal Energy Regulatory
Commission. The Company is an operating subsidiary of Dominion Energy, Inc.
2. The Company’s address is:
Virginia Electric and Power Company

120 Tredegar Street
3. The names, addresses, and telephone numbers of the attorneys for the Company
are:
Paul E. Pfeffer
David J. DePippo
Dominion Energy Services, Inc.
120 Tredegar Street
(804) 787-6033 (PEP)
(804) 819-2411 (DJD)
Joseph K. Reid, Ifl

Elaine S. Ryan
Sarah R. Bennett
Dan Bumpus
McGuireWoods LLP
Gateway Plaza
Richmond, Virginia 23219-3916
(804) 775-1198 (JKR)
(804) 775-1090 (ESR)
(804) 775-4730 (SRB)
(804) 775-1199 (DRB)
BACKGROUND
4. Initiated in 2009, RGG1 is the first mandatory market-based program in the
United States to reduce greenhouse gas emissions. RGGI is a collaborative effort among the
states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Plampshire, New York,
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Rhode Island, Vermont, and New Jersey to cap and reduce CO2 emissions from the power sector. W
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CO2 allowances are obtained by RGGI participants through quarterly, regional auctions. p
5. In May 2019, the Virginia Department of Environmental Quality (“DEQ”) issued
a final rule establishing a state carbon regulation program linked to RGGI (the “DEQ Carbon
Rule” or “Rule”). Although the DEQ Carbon Rule was finalized in 2019, language in the state
budget bill prohibited DEQ from continued work on the Rule. During the 2020 Regular Session,
the General Assembly passed the Clean Energy and Community Flood and Preparedness Act,
Senate Bill No. 1027 and House Bill No. 981, which authorized Virginia to become a full
participant of RGGI and authorized DEQ to implement the DEQ Carbon Rule. The legislation
became effective July 1,2020. With the passage of this legislation, DEQ revised the DEQ
Carbon Rule to clarify that the Commonwealth will join RGGI in 2021. The revised Rule was
signed by the DEQ on June 25, 2020, and became effective on July 10, 2020. DEQ held a
meeting to inform stakeholders about the Rule revisions, including any near-term compliance
submittals required of companies subject to the Rule, on August 12, 2020.
6. The DEQ Carbon Rule will cap CO2 emissions for Virginia at 27.1 million short
tons for calendar year 2021, and decrease the emissions cap annually by approximately 3% to
achieve a 30% reduction from 2020 levels to a level of 19.6 million short tons in 2030. Emission
sources subject to the Rule will be required to obtain and surrender a CO2 emission allowance for
every short ton of CO2 emitted during a control period through participation in the RGGI
allowance auction program.
7. The Company owns regulated emissions sources, so must comply with RGGI.
8. Va. Code § 56-585.1 A 5 e permits cost recovery related to compliance with
RGGI and establishes the applicable standard of review:
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A utility may at any time, after the expiration or termination of m
capped rates, but not more than once in any 12-month period, ©
petition the Commission for approval of one or more rate adjustment 10
clauses for the timely and current recovery from customers of. . .
[projected and actual costs of projects that the Commission finds to
be necessary ... to comply with state or federal environmental laws
or regulations applicable to generation facilities used to serve the
utility’s native load obligations, including the costs of allowances
purchased through a market-based trading program for carbon
dioxide emissions. The Commission shall approve such a petition
if it finds that such costs are necessary to comply with such
environmental laws or regulations.
RIDER RGGI
9. The Company estimates it will initially require approximately 19,000,000 CO2
allowances per year to cover CO2 emissions from its Virginia-based generation fleet.
Accordingly, by July 31, 2022, the Company expects to need approximately 29,000,000 CO2
allowances.
10. Generally, to meet its obligations under RGGI, the Company intends to follow a
programmatic approach by purchasing most of the required allowances in the RGGI quarterly
auctions and using the secondary market to fill any auction deficiencies. More specifically,
Dominion Energy Virginia plans to acquire approximately 25% of the forecasted annual
allowance requirement in each of the quarterly auctions. If the Company fails to secure
approximately 25% in an auction, the Company will look to purchase allowances in the
secondary market. Also, Dominion Energy Virginia will seek to maintain a bank of allowances
equal to approximately 10% to 20% of the annual requirement. The purpose of the bank is to
protect customers from short-term allowance price volatility. The Company’s compliance
strategy is not based on any price outlook. Instead, the Company intends to follow a
programmatic, auction-based approach to compliance. The Company may adjust its compliance
strategy as needed to adapt to changes in the structure of the RGGI program.
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11. The Company has assumed a weighted average price of $6.84 per allowance.
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This assumption is based on the actual clearing pricing in RGGI Auction 49 and actual
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transactions in the secondary market, combined with the ICF forward price curve.
12. The Company’s RAC revenue requirement in this proceeding includes the
Projected Cost Recovery Factor. Beginning with the next RAC filing expected to be made in
2021, the revenue requirement will also include the Actual Cost True-Up Factor. The Projected
Cost Recovery Factor calculation results in the operating income necessary for recovery of
amortization expense for CO2 allowances as well as projected financing costs on the unamortized
purchased CO2 allowance balances. In addition, the Projected Cost Recovery Factor includes the
amortization of deferred costs, including financing costs, incurred prior to this initial Rate Year.
No Actual Cost True-Up Factor is included in this initial proceeding because this filing
represents the initial request for cost recovery. It is anticipated that any true-up for calendar year
2020 will be included in a 2021 update filing for implementation during an August I , 2022 to
July 31,2023 rate year. At that time, and for years beyond, the Actual Cost True-Up Factor will
recover from, or credit to, customers any under- or over-recovery of costs from the most recently
completed calendar year. Actual revenues recovered during the test year are compared to actual
costs incurred during the test year. Any difference in these amounts becomes the Actual Cost
True-Up Factor credited to, or recovered from, customers through the total revenue requirement
requested for recovery during the rate year.
13. The total revenue requirement requested for recovery in this initial Rider RGGI
Petition for the Rate Year beginning August 1,2021, is $168,260,000.
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14. The Company proposes to use an energy allocation factor to allocate costs to the
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Virginia jurisdiction and that the costs be recovered through a uniform charge per kilowatt-hour \F*
(“kWh”) from all bundled service customers in the Virginia jurisdiction.
15. The implementation of the proposed Rider RGG1 on August 1,2021, will increase
the residential customer’s monthly bill, based on 1,000 kWh per month, by $2.39.
SUPPORTING TESTIMONY, FILING SCHEDULE 46, AND REQUEST FOR LIMITED

WAIVERS OF RATE CASE RULES FILING REQUIREMENTS
16. The Company’s Petition is supported by the pre-filed direct testimonies of
Company Witnesses C. Eric McMillan, Shane T. Compton, John C. Ingram, and Paul B. Haynes.
17. Section Rule 60 of the Rate Case Rules provides that an application filed pursuant
to Subsection A 5 “shall include Schedules 45 and 46 as identified and described in 20 VAC 5-
201-90, and which shall be submitted with the utility’s direct testimony.” The Company is filing
with this Petition, Filing Schedule 46, as follows:
a. Company Witnesses McMillan and Compton co-sponsor Schedule 46A,

consisting of Statements I and 2. Schedule 46A, Statement I, provides projected
costs associated with Rider RGGI, while Schedule 46A, Statement 2, provides
documentation supporting the projected costs.
b. Company Witness Ingram sponsors Schedule 46B, consisting of Statements 1 and

2. These statements provide revenue requirement information for the proposed
RAC and describe all significant accounting procedures and internal controls to
identify costs related to RGGI allowances.
c. Company Witness Haynes sponsors Schedule 46C, consisting of Statement 1,

which provides details of the Company’s methodology for allocating the Rider
RGGI revenue requirement.
18. The Company, for good cause shown and pursuant to 20 VAC 5-201 -10 E of the
Rate Case Rules, respectfully requests that the Commission waive, in part, the requirements
under Rules 60 and 90 of the Rate Case Rules with respect to Filing Schedule 45 (Return on
Equity Peer Group Benchmark). Pursuant to the provisions of Va. Code §§ 56-585.1 and 56-
6
585.1 :l, and consistent with recent Commission orders granting similar limited waivers,1 a
return on equity determination is not to be made in this proceeding. Therefore, good cause
exists, as required by Rule 10 E, for the Commission to waive in part the requirements of Rules
60 and 90 of the Rate Case Rules with respect to Filing Schedule 45.
19. The Company, for good cause shown and pursuant to 20 VAC 5-201 -10 E,
additionally respectfully requests that the Commission waive, in part, the requirement under
Rules 60 and 90 of the Rate Case Rules to “[p]rovide the annual revenue requirement over the
duration of the proposed rate adjustment clause by year and by class.” Specifically, the
Company requests waiver of two portions of this requirement. First, the Company seeks waiver
of this requirement related to information for the “duration of the proposed rate adjustment
clause.” By statute, RGG1 will continue indefinitely; Rider RGGI thus differs from other
Company RACs approved by the Commission for assets that have a specific lifetime. Second,
the Company seeks waiver of this requirement related to providing information on the revenue
requirement “by class.” As explained by Company Witness Haynes, the Company has
developed a uniform charge per kilowatt-hour applicable to all bundled service customers in the
Virginia jurisdiction. Accordingly, the revenue requirement is not available “by class.” For
these reasons, good cause exists, as required by Rule 10 E, for the Commission to waive in part
the requirements of Rules 60 and 90 of the Rate Case Rules with respect to this limited portion of
Schedule 46.
1 See, e.g., Petition of Virginia Electric and Power Company, For approval and certification of
the proposed US-4 Solar Project pursuant to §§ 56-580 D and 56-46. P of the Code of Virginia,
andfor approval of a rate adjustment clause, designated Rider US-4, under § 56-585.1 A 6 of the
Code of Virginia, Case No. PUR-2019-00105, Order for Notice and Hearing at 21, Ordering
Paragraph (21) (Jul. 31,2019).
7
COMPLIANCE WITH RULE 10 OF THE RATE CASE RULES
20. The Company’s Petition for approval of Rider RGGI complies with the
requirements contained in Rule 10 of the Rate Case Rules. In accordance with Rule 10 A, the
Company filed with the Commission on September 8, 2020, the Company’s notice of intent to
file this Petition under Va. Code § 56-585.1 A 5.2 Copies of the public version of this Petition,
to the extent required by Rule 10 J, along with the additional information required by Rule 10 J,
have been served upon the persons addressed in that Rule. A complete copy of the public
version of this Petition has been served upon the Office of the Attorney General’s Division of
Consumer Counsel in conformity with Rule 10 J. Also included with and following this Petition,
pursuant to Rule 10, is a table of contents of this filing, including testimony and schedules.
21. Beyond the initial Petition, Rate Case Rule 10 J requires the Company to serve
copies of certain information related to Dominion Energy Virginia’s rate proceedings upon local
officials via first class mail or personal delivery. The Company has obtained a continuing waiver
of Rule 10 J from the Commission to permit electronic delivery of rate application information to
the localities in lieu of first class mail delivery upon request from the locality.3 Accordingly, the
Company requests that any procedural order issued in this proceeding allow for electronic
service of materials going forward on localities that request such service in writing.
2 This notice dated September 8, 2020, indicated the Company’s intent to file this Petition on or
after October 5, 2020. On that same day, the Company filed a motion for limited waiver of the
60-day notice requirement of Rule 10 A. On September 23, 2020, the Commission denied the
motion. Based on that order, on September 25, 2020, the Company filed an amended notice of
intent to file this Petition under Va. Code § 56-585.1 A 5 on or after November 9, 2020.
3 Petition of Virginia Electric and Power Company, For a continuing waiver of 20 VAC 5-201-
10 J of the Rules Governing Utility Rate Applications and Annual Informational Filings to
permit electronic service to local officials upon request. Case No. PUE-2016-00039, Pinal Order
at 2-3 (Apr. 19, 2016).
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CONCLUSION
WHEREFORE, Dominion Energy Virginia respectfully requests that the Commission
(i) approve the proposed revenue requirement for service rendered on and after August 1, 2021,
to recover projected and actual costs related to the purchase of CO2 allowances to comply with
RGG.I; (ii) approve the Company’s proposed Rider RGGI, effective for usage on and after
August I, 2021; (iii) grant the Company’s requested limited waivers outlined in the Petition; and
(iv) grant such other relief as deemed appropriate and necessary.
Respectfully submitted,
VIRGINIA ELECTRIC AND POWER COMPANY
By: /s/Elaine S. Rvan

Counsel
Paul E. Pfeffer
David J. DePippo
Dominion Energy Services, Inc.
120 Tredegar Street
(804) 787-6033 (PEP)
(804)819-2411 (DID)
paul. e.pfeffer@dominiomnergy>. com
davidj.depippo@dominionenergy.com
Joseph K. Reid, III

Elaine S. Ryan
Sarah R. Bennett
Dan Bumpus
McGuireWoods LLP
Gateway Plaza
Richmond, Virginia 23219-3916
(804) 775-1198 (JKR)
(804) 775-1090 (ESR)
(804) 775-4730 (SRB)
(804) 775-1199 (DRB)
jre id@mcguirewoods, com
9
erycm@mcguirewoods, com
sbennetl@mcguirewoods. com
dbumpi<s@mcguirewoods. com
Counsel for Virginia Electric and Power Company
■November 9, 2020
Witness Direct Testimony Summary
Witness: C. Eric McMillan
Title: Manager, Power Contracts and Origination
Summary:
Company Witness C. Eric McMillan provides a general overview of the Regional Greenhouse
Gas Initiative (“RGGI”) and describes the mechanics of the RGGI auctions. Mr. McMillan also
explains how the Company plans to meet its obligations under RGGI, and will describe the
Company’s participation in these markets to date.
Mr. McMillan explains that RGGI is the first mandatory market-based program in the United
States to reduce greenhouse gas emissions. CO2 allowances are obtained by RGGI participants
through quarterly, regional auctions or through secondary markets. In 2020, the Virginia
General Assembly passed the Clean Energy and Community Flood and Preparedness Act, which
authorized Virginia to become a full participant of RGGI and authorized the Virginia
Department of Environmental Quality (“D.EQ”) to implement its DEQ Carbon Rule. The DEQ
Carbon Rule caps CO2 emissions for Virginia at 27.1 million short tons for calendar year 2021,
and decreases the emissions cap annually by approximately 3% to achieve a 30% reduction from
2020 levels to a level of 19.6 million short tons in 2030. The Company owns regulated
emissions sources, so must comply with RGGI.
Regulated emissions sources must acquire CO2 allowances equal to their CO2 emissions over
each three-year RGGI control period. Each allowance represents a limited authorization to emit
one short ton of CO2 from a regulated source. RGGI has had four three-year control periods
since it began in 2009. The fifth control period starts on January 1,2021 and ends December 31,
2023. In addition to the three-year control period requirements, RGGI has interim control
periods that require regulated sources to hold a minimum of 50% of their allowances by the end
of each of the first two calendar years of the control period. Regulated sources demonstrate
compliance by holding sufficient allowances in each source compliance account.
To meet its obligations under RGGI, the Company intends to follow a programmatic approach
by purchasing most of the required allowances in the quarterly auctions and using the secondary
market to fill any auction deficiencies. More specifically, Dominion Energy Virginia plans to
acquire approximately 25% of the forecasted annual allowance requirement in each of the
quarterly auctions. If the Company fails to secure approximately 25% in an auction, the
Company will look to purchase allowances in the secondary market. Also, Dominion Energy
Virginia will seek to maintain a bank of allowances equal to approximately 10% to 20% of the
annual requirement. The purpose of the bank is to protect customers from short-term allowance
price volatility.
Mr. McMillan supports the weighted average price assumption of $6.84 per CO2 allowance.
This assumption is based on the actual clearing pricing in RGGI Auction 49 and actual
transactions in the secondary market, combined with the IGF forward price curve.
DIRECT TESTIMONY
OF
C. ERIC MCMILLAN
ON BEHALF OF
BEFORE THE
STATE CORPORATION COMMISSION OF VIRGINIA
CASE NO. PUR-2020-00169
1 Q. Please state your name, business address, and position with Virginia Electric and
2 Power Company (“Dominion Energy Virginia” or the “Company”).
3 A. My name is C. Eric McMillan, and I am a Manager of Power Contracts and Origination
4 for the Company. My business address is 600 East Canal Street, Richmond, Virginia
5 23219. A statement of my background and qualifications is attached as Appendix A.
6 Q. Please describe your areas of responsibility with the Company.
7 A. In my current position, I lead a team that is responsible for managing the Company’s
8 compliance with the Regional Greenhouse Gas Initiative (“RGGI”) and the mandatory
9 renewable energy portfolio standard program from a market procurement perspective. I
10 also am responsible for the negotiation, origination, and day-to-day administration of the
1 I Company’s non-utility generation power contracts.
12 Q. What is the purpose of your testimony in this proceeding?
13 A. I am testifying in support of the Company’s petition for approval of a rate adjustment
14 clause (“RAC”), designated Rider RGGI, under § 56-585.1 A 5 e of the Code of Virginia
15 (“Va. Code”) to recover projected and actual costs related to the purchase of allowances
16 through the RGGI market-based trading program for carbon dioxide (“CO2”) emissions, a
17 program in which the Company is required to participate. I will provide a general
18 overview of RGGI and describe the mechanics of the RGGI auctions. I will also explain
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1 how the Company plans to meet its obligations under R.GGI, and will describe the
2 Company’s participation in these markets to date.
3 Q. Are you sponsoring an exhibit in this proceeding?
4 A. Yes. Although there are no schedules attached to my testimony, I am co-sponsoring
5 Filing Schedule 46A, Statements 1 and 2, with Company Witness Shane T. Compton,
6 which provide information required by Rules 60 and 90 of the Commission’s Rules
7 Governing Utility Rate Applications and Annual Informational Filings. Schedule 46A,
8 Statement 1, provides projected costs associated with Rider RGGI, while Schedule 46A,
9 Statement 2, provides documentation supporting the projected costs. These statements
10 were prepared under my direction and supervision and are accurate and complete to the
11 best of my knowledge and belief.
12 Q. What is RGGI?
13 A. Initiated in 2009, RGGI is the first mandatory market-based program in the United States
14 to reduce greenhouse gas emissions. RGGI is a collaborative effort among the states of
15 Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York,
16 Rhode Island, Vermont, and New Jersey to cap andreduce CO2 emissions from the
17 power sector. CO2 allowances are obtained by RGGIparticipants through quarterly,
18 regional auctions. In most RGGI states, auction revenue is returned to state coffers. In
19 addition to Virginia joining RGGI in 2021, Pennsylvania is expected to join RGGI in
20 2022.
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1 Q. Please provide an overview of the Commonwealth’s participation in RGGI.
2 A. In May 2019, the Virginia Department of Environmental Quality (“DEQ”) issued a final
3 rule establishing a state carbon regulation program linked to RGGI (the “DEQ Carbon
4 Rule” or “Rule”). Although the DEQ Carbon Rule was finalized in 2019, language in the
5 state budget bill prohibited the DEQ from continued work on the Rule. During the 2020
6 Regular Session, the General Assembly passed the Clean Energy and Community Flood
7 and Preparedness Act, Senate Bill No. 1027 and House Bill No. 981, which authorized
8 Virginia to become a full participant of RGGI and authorized the DEQ to implement the
9 DEQ Carbon Rule. The legislation became effective July 1,2020.
10 With the passage of this legislation, the DEQ revised the DEQ Carbon Rule to clarify that
11 the Commonwealth will join RGGI in 2021. The revised Rule was signed by the DEQ on
12 June 25, 2020, and became effective on July 10, 2020. The DEQ held a meeting to
13 inform stakeholders about the Rule revisions, including any near-term compliance
14 submittals required of companies subject to the Rule, on August 12, 2020.
15 Q. What does the DEQ Carbon Rule require in terms of reduced emissions?
16 A. The DEQ Carbon Rule will cap CO2 emissions for Virginia at 27.1 million short tons for
17 calendar year 2021, and decrease the emissions cap annually by approximately 3% to
18 achieve a 30% reduction from 2020 levels to a level of 19.6 million short tons in 2030.
19 Emission sources subject to the Rule will be required to obtain and surrender a CO2
20 emission allowance for every short ton of CO2 emitted during a control period through
21 participation in the RGGI allowance auction program.
3
1 Q. Is the Company required to comply with the DEQ Carbon Rule?
2 A. Yes. The Company owns regulated emissions sources, so must comply with RGGL
3 Q. How is compliance demonstrated under RGGI?
4 A. Regulated emissions sources must acquire CO2allowances equal to their CO2emissions
5 over each three-year RGGI control period. Each allowance represents a limited
6 authorization to emit one short ton of CO2 from a regulated source. These regulated
7 sources can use CO2 allowances issued by any participating RGGI state during the
8 current year, or any future year.
9 RGGI has had four three-year control periods since it began in 2009. The fifth control
10 period starts on January 1,2021 and ends December 31,2023. In addition to the three-
II year control period requirements, RGGI has interim control periods that require regulated
12 sources to hold a minimum of 50% of their allowances by the end of each of the first two
13 calendar years of the control period. Regulated sources demonstrate compliance by
14 holding sufficient allowances in each source compliance account.
15 Q. How do regulated sources acquire CO2 allowances?
16 A. Regulated sources acquire CO2 allowances by purchasing them at quarterly auctions or
17 through secondary markets. CO2 allowances purchased by the winning bidders in the
18 quarterly auctions and CO2 allowances traded in the secondary market are tracked and
19 recorded in the RGGI CO2 Allowance Tracking System (“COATS”). RGGI allowances
20 currently do not have any limitations on banking. Potomac Economics serves as the
21 independent market monitor for RGGI. The market monitor covers both the auctions and
4
1 the secondary market, and publishes quarterly reports analyzing each R.GGI auction and
2 activity in the CO2 allowance secondary market.
3 Q. Please explain how the RGGI quarterly auctions work.
4 A. The RGGI member states use an online platform to offer and sell CO2 allowances in
5 quarterly auctions. The RGGI member states are the only market participants permitted
6 to offer allowances in these auctions. The auctions are conducted in accordance with
7 the statutory and/or regulatory authority of each state offering CO2 allowances for sale in
8 the auctions.
9 The quarterly auctions are open to any interested bidder that meets the financial
10 qualifications. Auction bidders must provide sufficient collateral to fully cover all their
11 bidding activity. The auction clearing prices are determined by ordering the bids by
12 dollar value highest to lowest, and then allocating allowances to the bids in descending
13 dollar value until all the allowances have been allocated. The marginal bid—or the
14 lowest bid to receive allowances—then becomes the auction clearing price. All winning
15 bidders pay the auction clearing price for every CO2 allowance allocated to them.
16 Q. Please describe the secondary market for RGGI CO2 allowances.
17 A. The secondary market allows market participants to buy and sell physical allowances
18 outside of the quarterly auctions, facilitates price discovery in between quarterly auctions,
19 and provides tools to manage price risk and volatility. The secondarymarket includes the
20 trading of physical allowances and financial products.
5
1 A physical CO2 allowance trade occurs when a buyer and seller agree to specific
2 commercial terms such as price, volume, and vintage, and then register the transfer of
3 allowance ownership in RGGI COATS.
4 Financial products include any contracts whereby the buyer and seller agree to exchange
5 funds and/or allowances at some future date under specific conditions. Many financial
6 products are designed to, and eventually result in, the transfer of physical CO2 allowances
7 in RGGI COATS. Depending on the product and the agreed-to commercial terms, this
8 transfer may occur months or even years after the financial transaction was executed by
9 the buyer and seller. The most commonly traded financial products are forward contracts
10 and futures contracts. In forwardcontracts, which typicallyare traded in the over the
11 counter (“OTC”) market,parties agree toexchange allowances at a setprice and quantity
12 at some future date. Forwards are non-standard contracts transacted outside of an
13 exchange. Futures contracts are standardized, exchange-traded contracts. One futures
14 contract equals 1,000 CO2 allowances. All allowances, regardless of product, must be
15 transferred from seller to buyer in the COATS registry.
16 Q. Please describe the historical pricing and volumes that have cleared in the RGGI
17 auctions since 2015.
18 A. Figure I shows the RGGI quarterly auction volume that has cleared through September
19 2020, as well as projections of auction volume in the next two auctions. Note that the
20 March 2021 auction shows the introduction of Virginia volumes into the quarterly
21 auction for the first time.
6
TEfi0ET£TC£!)E
Figure 1: RGGI Quarterly Auction Volume (Mar. 2015 to Mar. 2021)
VA 1st
Auction 23.0001100
NJ 1st
Auction
20,0001)00 2
(A
15.000D00 2J
c
(O
■g "g io.ooodoo _o
1 1 <
£ -£ sfloaooo
1 Figure 2 shows the historical prices of RGGI allowances that have cleared through the
2 quarterly auctions as well as the secondary markets. Allowance prices have ranged from
3 $2.53/short ton to $7.50/short ton in the RGGI auctions during this timeframe.
Figure 2: RGGI Quarterly Auction Clearing Price (Mar. 2015 to Sept. 2020)
S8.00
7
1 Q. How many CO2 allowances does the Company expect to need once Virginia joins
2 RGGI?
3 A. As supported by Company Witness Compton, the Company estimates it will initially
4 require approximately J 9,000,000 CO2 allowances per year to cover CO2 emissions from
5 its generation fleet in Virginia during the fifth control period. Based on the projected
6 CO2 emissions requirements, the Company would need to hold at least 9,500,000
7 allowances by December 31,2021, and at least 19,000,000 allowances by December 31,
8 2022.
9 Q. Generally, how does the Company plan to meet its obligations under RGGI?
10 A. In general, the Company intends to follow a programmatic approach by purchasing most
II of the required allowances in the quarterly auctions and using the secondary market to fill
12 any auction deficiencies. More specifically, Dominion Energy Virginia plans to acquire
13 approximately 25% of the forecasted annual allowance requirement in each of the
14 quarterly auctions. If the Company fails to secure approximately 25% in an auction, the
15 Company will look to purchase allowances in the secondary market. Also, Dominion
16 Energy Virginia will seek to maintain a bankof allowances equal to approximately 10%
17 to 20% of the annual requirement. The purpose of the bank is to protect customers from
18 short-term allowance price volatility.
19 The Company’s compliance strategy is not based on any price outlook. Instead, the
20 Company intends to follow a programmatic, auction-based approach to compliance. The
21 Company may adjust its compliance strategy as needed to adapt to changes in the
22 structure of the RGGI program.
8
1 Q. Has the Company started to procure CO2 allowances to meet its obligations?
2 A. R.GGI Auction 49 occurred in September 2020 with a clearing price of $6.82 per
3 allowance. Dominion Energy Virginia started purchasing small volumes of
4 CO2 allowances in this auction, purchasing 750,000 allowances. In the secondary market,
5 the Company purchased 250,000 vintage 2020 allowances at $6.73 for September 2020
6 delivery. While the Company intends to bid on additional allowances in RCGI Auction
7 50 scheduled for December 2020 and may purchase allowances in the secondary market,
8 the Company does not intend to purchase significant volumes of allowances until the
9 Commonwealth begins selling allowances in the March 2021 auction.
10 Q. What price for CO2 allowances has the Company used to calculate the revenue
11 requirement in this proceeding?
12 A. The Company has assumed a weighted average price of $6.84 per allowance. This
13 assumption is based on the actual clearing pricing in RGG.I Auction 49 and actual
14 transactions in the secondary market, combined with the ICF forward price curve as
15 supported by Company Witness Compton. As discussed further by Company Witness
16 John C. Ingram, the revenue requirement will be trued up in future Rider RGGI
17 proceedings based on actual prices paid for CO2 allowances.
18 Q. Does this conclude your pre-fded direct testimony?
19 A. Yes, it does.
9
APPENDIX A
BACKGROUND AND QUALIFICATIONS

OF
C. ERIC MCMILLAN
C. Eric McMillan joined the Company in 2008 as an Associate Financial Analyst in the
Generation Financial Services Department. Since then he has held various financial, business
development, and renewable operations roles within the power generation business segment of
the Company. In 2015, Mr. McMillan was promoted to Manager of Renewable Energy
Operations. In October 2019, he assumed his current position of Manager of Power Contracts
and Origination. In his current role, Mr. McMillan is responsible for the negotiation, origination,
and day-to-day administration of the Company’s NUG power contracts.
Mr. McMillan graduated from the Longwood University in 2006 with a Bachelor of
Science degree in Business Administration with concentrations in Finance. In 2013, Mr.
McMillan obtained a Masters of Science in Finance degree from Virginia Commonwealth
University.
Witness: Shane T. Compton
Title: Manager, Integrated Strategic Planning
Summary:
Company Witness Shane T. Compton provides the forecast of CO2 emissions from the
Company’s generation facilities used to determine the projected volume of CO2 allowances
needed to meet the Company’s obligations under RGG1. Mr. Compton states that the Company
used PLEXOS modeling software to simulate the economic dispatch of the Company’s
generating units to meet projected load requirements. The projected CO2 emission production
was then pulled for each Company-owned CCh-emitting resource located in Virginia. Mr.
Compton estimates that the Company will initially require approximately 19,000,000 CO2
allowances per year to cover CO2 emissions from its Virginia-based generation fleet.
Accordingly, by July 31,2022, the Company expects to need approximately 29,000,000 CO2
allowances.
DIRECT TESTIMONY
OF
SHANE T. COMPTON
ON BEHALF OF
BEFORE THE
CASE NO. PUR-2020-00169
3 A. My name is Shane T. Compton and I am Manager of Integrated Strategic Planning. M.y
4 business address is 600 East Canal Street, Richmond, Virginia 23219. A statement of my
5 background and qualifications is attached as Appendix A.
6 Q. Mr. Compton, what is the purpose of your testimony in this proceeding?
8 clause (“RAC”), designated Rider RGG.I, under § 56-585.1 A 5 e of the Code of Virginia
9 (“Va. Code”) to recover projected and actual costs related to the purchase of allowances
10 through the Regional Greenhouse Gas Initiative (“RGG.I”) market-based trading program
11 for carbon dioxide (“CO2”) emissions. I will support the forecast of CO2 emissions from
12 the Company’s generation facilities.
13 Q. During the course of your testimony, will you introduce an exhibit?
14 A. Yes. Company Exhibit No., STC, consisting of Schedule I, was prepared under my
15 supervision and direction, and is accurate and complete to the best of my knowledge and
16 belief. J am also co-sponsoring Filing Schedule 46A, Statements 1 and 2, with Company
17 Witness C. Eric McMillan, which provide information required by Rules 60 and 90 of the
18 Commission’s Rules Governing Utility Rate Applications and Annual Informational

1 Filings. Schedule 46A, Statement 1, provides projected costs associated with RJder
2 RGGI, while Schedule 46A, Statement 2, provides documentation supporting the
3 projected costs.
4 Q. How did the Company determine the projected volume of CCh allowances needed to
5 meet its obligation under RGGI?
6 A. PLEXOS modeling software was used to simulate the economic dispatch of the
7 Company’s generating units to meet projected load requirements. The projected CO2
8 emission production was then pulled for each Company-owned CCh-emitting resource
9 located in Virginia. The Company did not include CO2 emissions from its units in West
10 Virginia {i.e., Mt. Storm) or North Carolina (i.e., Rosemary). As explained by Company
11 Witness C. Eric McMillan, the Company must obtain and surrender a CO2 allowance for
12 every short ton of CO2 emitted from regulated sources.
13 Q. What is the projected volume of CO2 allowances that the Company expects to
14 require through the end of the rate year in this proceeding—July 31, 2022?
15 A. The Company estimates it will initially require approximately 19,000,000 CO2
16 allowances per year to cover CO2 emissions from its Virginia-based generation fleet.
17 Accordingly, by July 31,2022, the Company expects to need approximately 29,000,000
18 CO2 allowances. My Schedule 1 shows the projected CO2 emissions by month for 2021
19 and 2022.
20 Q. Will Virginia joining RGGI affect the dispatch of the Company’s generation units?
21 A. Yes, it will. Regulated sources {i.e., the Company’s carbon-emitting generating units that
22 are subject to RGGI) must purchase a CO2 allowance for every CO2 short ton emitted
2
C E (D O E'S
1 during a specific compliance period. All else equal, adding the cost of CO2 allowances to
2 carbon-emitting generating units that are subject to RGGl will likely result in those units
3 dispatching less. In modeling space, PLEXOS takes this into account by adding a
4 forecasted cost of CO2 allowances to its generating units in Virginia subject to RGGl.
5 My Schedule 1 shows the projected CO2 allowance prices used in PLEXOS. As the
6 carbon-emitting generating units dispatch less, PLEXOS replaces the lost generation with
7 market purchases.
8 Q. Does this conclude your pre-filed direct testimony?
9 A. Yes, it does.
3
APPENDIX A
©
It*
BACKGROUND AND QUALIFICATIONS &
OF <&
m
SHANE T. COMPTON
Shane Compton joined the Company in 2007 as an Hourly Trader in the Energy
Marketing group. Since then he has held various financial and planning roles within the power
generation and corporate strategic planning segments of the Company. In 2015, Mr. Compton
was promoted to Manager of Financial & Business Services. In September 2019, he assumed his
current position of Manager of Generation System Planning. In his current role, Mr. Compton is
responsible for developing generation portfolio plans to serve the Company’s long-term
customer capacity and energy needs.
Mr. Compton graduated from Virginia Tech in 2004 with a Bachelor of Science degree in
Business Administration with a concentration in Finance. In 2014, Mr. Compton obtained a
Master of Business Administration degree from Virginia Commonwealth University.

Company Exhibit No.__
Witness: STC
Schedule 1
C02 Volume and Price Forecast Page 1 of 1
(Tons CO 2 and Allowance Prices from Oct 2020 PLEXOS Outlook)
Allowance
Tons C02 Price
Jan-21 1,337,487 $6.91
Feb-21 1,388,272 $6.91
Mar-21 1,447,889 $6.91
Apr-21 1,148,777 $6.91
May-21 1,415,430 $6.91
Jun-21 1,632,852 $6.91
Jul-21 2,093,198 $6.91
Aug-21 2,151,129 $6.91
Sep-21 1,519,562 $6.91
Oct-21 873,141 $6.91
Nov-21 1,235,813 $6.91
Dec-21 1,618,607 $6.91
Jan-22 1,625,533 $6.69
Feb-22 1,674,251 $6.69
Mar-22 1,651,361 $6.69
Apr-22 1,440,970 $6.69
May-22 1,253,849 $6.69
Jun-22 1,650,957 $6.69
Jul-22 2,288,023 $6.69
Aug-22 2,317,061 $6.69
Sep-22 1,699,243 $6.69
Oct-22 942,157 $6.69
Nov-22 1,669,331 $6.69
Dec-22 1,858,761 $6.69
Witness: John C. Ingram
Title: Director, Regulatory Accounting
Summary:
Company Witness John C. Ingram provides the calculation of the revenue requirement
associated with Rider RGGI for the rate year of August 1,2021 through July 31,2022 (“Rate
Year”). The Company is requesting a total revenue requirement of $168,260,000 for the Rate
Year.
Mr. Ingram explains that the Company’s RAC revenue requirement in this proceeding includes
the Projected Cost Recovery Factor. Beginning with the next RAC filing expected to be made in
2021, the revenue requirement will also include the Actual CostTrue-Up Factor. The Projected
Cost Recovery Factor calculation results in the operating income necessary for recovery of
amortization expense for CO2 allowances as well as projected financing costs on the unamortized
purchased CO2 allowance balances. In addition, the Projected Cost Recovery Factor includes the
amortization of deferred costs, including financing costs, incurred prior to this initial Rate Year.
No Actual CostTrue-lip Factor is included in this initial proceeding because this filing
represents the initial request for cost recovery. It is anticipated that any true-up for calendar year
2020 will be included in a 2021 update filing for implementation during an August 1,2022 to
July 31,2023 rate year. At that time, and for years beyond, the Actual Cost True-Up Factor will
recover from, or credit to, customers any under- or over-recovery of costs from the most recently
completed calendar year. Actual revenues recovered during the test year are compared to actual
costs incurred during the test year. Any difference in these amounts becomes the Actual Cost
True-Up Factor credited to, or recovered from, customers through the total revenue requirement
requested for recovery during the rate year.
DIRECT TESTIMONY
OF
JOHN C. INGRAM
ON BEHALF OF
BEFORE THE
CASE NO. PUR-2020-00169
3 A. My name is John C. Ingram, and my business address is 120 Tredegar Street, Richmond,
4 Virginia 23219. I am a Director- Regulatory Accounting and am responsible primarily
5 for overseeing regulatory accounting matters and the analysis and development of
6 revenue requirement calculations for the Company. A statement of my background and
7 qualifications is attached as Appendix A.
8 Q. What is the purpose of your testimony in this proceeding?
10 clause (“RAC”), designated Rider RGGI, under § 56-585.1 A 5 e (“Subsection A 5 e” or
11 “A 5”) of the Code of Virginia (“Va. Code”) to recover projected and actual costs related
12 to the purchase of allowances through the Regional Greenhouse Gas Initiative (“RGGI”)
13 market-based trading program for carbon dioxide (“CO2”) emissions. I will address the
14 development of the revenue requirement associated with Rider RGGI for the rate year of
15 August 1,2021 through July 31,2022 (“Rate Year”).
16 Q. During the course of your testimony, will you introduce an exhibit?
17 A. Yes. Company Exhibit No.__ , JCI, consisting of Schedule 1, was prepared under my
18 supervision and direction, and is accurate and complete to the best of my knowledge and
1 belief. Also, J am sponsoring Filing Schedule 46B, Statements 1 and 2, which provide
2 information required by the Commission’s Rules Governing Utility Rate Applications
3 and Annual Informational Filings. These statements provide revenue requirement
4 information for the proposed RAC and describe all significant accounting procedures and
5 internal controls to identify costs related to RGGT allowances.
6 Q. Before discussing the revenue requirement, will you give a brief overview of the
7 accounting treatment for RGGI allowances?
8 A. Purchased CO2 allowances will be tracked in the aggregate as an intangible asset. As
9 CO2 emissions are produced each month, this intangible asset will be amortized based on
10 the then-present weighted-average cost per allowance. Based on the timing of allowance
11 auctions and purchase dates, the Company generally expects to carry an intangible asset
12 representing aggregated purchased but unamortized RGGJ CO2 allowances.
13 Q. What rate of return on common equity (“ROE”) is the Company utilizing in this
14 proceeding?
15 A. The Company has used a ROE of 9.2% for purposes of calculating the Rider RGGI
16 revenue requirement over the Rate Year in this case, consistent with the Final Order in
17 Case No. PUR-2019-00050.
18 Q. What are the key components of the revenue requirement in this proceeding?
19 A. The Company’s RAC revenue requirement in this proceeding includes the Projected Cost
20 Recovery Factor. Beginning with the next RAC filing expected to be made in 2021, the
21 revenue requirement will also include the Actual Cost True-Up Factor.
2
1 The Projected Cost Recovery Factor calculation results in the operating income necessary
2 for recovery of amortization expense for CO2 allowances as well as projected financing
3 costs on the unamortized purchased CO2 allowance balances. In addition, the Projected
4 Cost Recovery Factor includes the amortization of deferred costs, including financing
5 costs, incurred prior to this initial Rate Year.
6 No Actual Cost True-Up Factor is included in this initial proceeding because this filing
7 represents the initial request for cost recovery. It is anticipated that any true-up for
8 calendar year 2020 will be included in a 2021 update filing for implementation during the
9 August I , 2022 to July 31,2023 rate year. At that time, and for years beyond, the Actual
10 Cost True-Up Factor will recover from, or credit to, customers any under or over
11 recovery of costs from the most recently completed calendar year. Actual revenues
12 recovered during the test year are compared to actual costs incurred during the test year.
13 Any difference in these amounts becomes the Actual Cost True-Up Factor credited to, or
14 recovered from, customers through the total revenue requirement requested for recovery
15 during the Rate Year.
16 This request utilizes the end-of-test period capital structure and cost of capital pursuant to
17 Va. Code § 56-585.1 A 10 and is consistent with the Order of the State Corporation
18 Commission of Virginia (“Commission”) on Commission Staffs Motion in Limine dated
19 July 14, 2009 in Case No. PUE-2009-00019. For purposes of setting rates during the
20 Rate Year, the end-of-test-period capital structure and cost of capital is the Company’s
21 December 31,2019 year-end capital structure and year-end cost of capital (“Cost of
22 Capital”). The calculation of the end-of-period capital structure and cost of capital
23 excludes certain adjustments to the Company’s common equity balance, in accordance
3
with the Commission’s September 4, 2020 Final Order in Case Mo. PUR.-2020-00003.
2 The Company’s Cost of Capital applied in this case is shown on page 12 of my
'3 Schedule 1.
4 Q. What deferred costs are being proposed for recovery in this filing?
5 A. The Company is deferring amortization expense for CO2 allowances and financing costs
6 on rate base calculated up to the beginning of the initial Rate Year and is proposing to
7 recover them over the Rate Year in this current filing, consistent with past practice for
8 deferred operating costs and rate base items in other Company RACs under Va. Code
9 § 56-585.1 A 5 and A 6.
10 Q. Mr. Ingram, would you please discuss the Company’s current proposal for
11 calculating the Projected Cost Recovery Factor in this fding?
12 A. Yes. The revenue requirement to be recovered from Virginia Jurisdictional customers
13 through the Projected Cost Recovery Factor is presented in my Schedule I, page I, and
14 consists of the projected amortization expense for the CO2 allowances during the Rate
15 Year, the amortization of deferred costs over the Rate Year, and projected financing costs
16 on purchased CO2 allowances for the Rate Year (including income taxes on the equity
17 component of the return). CO2 allowance purchase volumes and prices and amortization
18 volumes included in the revenue requirement calculation are supported by the direct
19 testimony of Company Witnesses C. Eric McMillan and Shane T. Compton.
20 The financing cost portion of the revenue requirement is the result of multiplying
21 thirteen-month average rate base as of July 31,2022, by the Company’s Cost of Capital.
22 As noted above, the operating cost portion of the revenue requirement consists of
4
1 projected amortization expense for CO2 allowances during the Rate Year and the
2 amortization of deferred costs as previously described in my testimony.
3 Q. For purposes of this filing, please describe the composition of the rate base as
4 presented in your Schedule 1.
5 A. Rate base is comprised of month-end unamortized purchased CO2 allowance balances,
6 cash working capital, and unrecovered deferred costs.
7 Q. Will any of the expenses requested for recovery in the instant case be requested for
8 recovery in any of the Company’s unrelated Virginia rate proceedings or filings
9 such as its base rates, fuel, sales and use tax, or other unrelated rider cases?
10 A. No. Pursuant to Subsection A 5 e, the Company will only request recovery of those costs
11 and expenses directly associated with the purchase and amortization of CO2 allowances
12 in Rider RGGT proceedings. Any indirect operating costs, such as broker fees or
13 Dominion Energy Services, Inc. (“DES”) costs, will be recovered in the Company’s base
14 rates. See Schedule 46B, Statement 2, for a more detailed description of the Company’s
15 accounting procedures and internal controls utilized to ensure the purchases and
16 amortization of the CO2 allowances are segregated for purposes of requesting recovery in
17 the instant proceeding and, conversely, not requested for recovery in other non-related
18 Company proceedings.
19 Q. What is the total revenue requirement in this filing?
20 A. As summarized on my Schedule 1, page 1, for the Rate Year beginning August 1,2021,
21 the Company is requesting recovery of a total revenue requirement of $168,260,000.
5
1 Company Witness Paul B. Haynes’s testimony addresses allocation of this revenue
2 requirement among the customer classes.
3 Q. Does this conclude your pre-filed direct testimony?
4 A. Yes, it does.
6
APPENDIX A
BACKGROUND AND QUALIFICATIONS

OF
JOHN C. INGRAM, CPA
John C. Ingram graduated from the College of William and Mary in 1992 with a Bachelor
of Business Administration degree (concentration in Accounting) and received his Certified
Public Accountant license in ] 994. He performed audit services for a national public accounting
firm prior to joining Dominion Energy in 1999. Mr. Ingram has held various positions within
Dominion Energy’s accounting organization, including SEC reporting, accounting research, and
Generation and Gas Infrastructure operating segment support. During his tenure in Generation
accounting from 2005 through 2015, he was promoted to Manager in 2006 and Director in 2010.
His responsibilities as Director primarily included overseeing personnel responsible for the
Company’s regulated generation accounting activities. From 2015 through May 2018, Mr.
Ingram served as an accounting Director supporting Dominion Energy’s Gas Infrastructure
operating segment. In May 2018, Mr. Ingram assumed his current role as the Director of
Regulatory Accounting where he is responsible for overseeing the analysis and development of
revenue requirements for the Company’s rate case proceedings.
Mr. Ingram has previously presented testimony and testified before the State Corporation
Commission of Virginia.
Witness: JCI
Schedule 1
Page 1 of 12
Rider RGGI Revenue Requirement
For the Rate Year August 1, 2021 to July 31, 2022
EX
(000s)
Line
No,
1 Projected Cost Recovery Factor $ 168,260
2 Actual Cost True-Up Factor __________:__
3 Total Revenue Requlrment S 168,260

Witness: JCI
Schedule 1
Page 2 of 12
Rider RGGI - Projected Cost Recovery Factor
For the Rate Year August 1,2021 to July 31, 2022
(000s)
Line
No. Rider RGGI
1 Rate Base $ 53,824
2 Weighted Average Cost of Capital 6.876%
3 Net Operating Income 3,701
Less Interest Expense on Debt

4 Weighted Average Cost Of Debt 2.056%
5 Weighted Average Debt Component Of JDC Expense 0,009%
6 Total Weighted Average Cost Of Debt 2.065%
7 Rate Base 53,824

8 Revenue Requirement - Interest Expense On Debt 1,111
9 Net Income 2,589
10 Income Tax Gross-up Factor 74.4%
11 Revenue Requirement - Net Income Including Income Taxes 3,481
12 Revenue Requirement-Financing Costs 4,593
13 Revenue Requirement - Operating Expenses 163,668
14 Revenue Requirement Per Projected Cost Recovery Factor S168,260

M
Company Exhibit No.__ ©
Witness: JCI {'*EJ
Schedule 1
Page 3 of 12 ^
©
©
§ f
o>
For the Period September 2020 to December 2020
s § o
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(000s)
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ct? cn Witness: JCI
Schedule 1
Page 4 of 12
fN (N
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For the Period January 2021 to December 2021
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Witness: JCI
Schedule 1
Page 5 of 12
1
2 S
I'-' o'
d
$
rsT o'
m <n
a ~
aOO' sKDo' CT> a

For the Period January 2022 to July 2022
a cn cn
3
(000s)
o
s'
w
3 s
§
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“ £ 1
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81
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c o
a z
Rider RGGI Operating Expenses
For the Rate Year August 1, 2021 to July 31, 2022
{000s)
a
i
Schedule 1
Witness: JCI
Page 6 of 12
y
y
K*
Witness: JCI
Schedule 1
Rider RGGI Pre-RAC Cost Deferral Page 7 of 12
For the Period September 2020 to July 31, 2021
• (000s)
sep-a> oci-;o NW-20 Dec-20 Mn-21 Fet>-21 Apr-a Jun-21 Jul-21

1 Allowance Amortization • S $ 9,167 $ 9315 S 10,019 $ 7,949 5 9,79« $ 1X284 5 14,465
4 Virginlaiurbdlctlonal Allocation Factor 80.35H
m.35* s&m B0.3S14 80.35* 80.35% 8035* 8035* 80.35* 8035* 80.35*
5 Virginia JurbdlctlonalTotal 7,365 7,645 8,050 6387 7370 9,066 11,623
6 Regulatory AjmI Balance 7365 15,011 23361 29/148 37317 46384 58,006
7 Regulatory Auet Balance (Net of ADrT) 5,478 11,164 17,152 21302 27,755 34,498 43,143
8 Average Regulatory Auet Balance (Net of ADfT) 2,739 8,321 14,158 19327 24329 3X127 38321
9 Virginia lurlsdlctional Rate Bate 5,427 5,427 5,427 10,979
10 Average JurHdlctlonal Rate Bate 2,713 5,427 5,427 8,203 3314
7347
(4,131)
(309)
15380
5,724
9,193
12386
1323
5,258
20,017
10,670
24306
22312
11 Pre-Tax Weighted Cott of Capital 0.71* 0.71* 0.71* 0.71* 0.71* 0.71*
Financing C«ti on Deferred Amortization 19 59 101 139 177 221 276
Financing Costs on Rate Base 19 39 ____58 ____52 _____ 12} 41 37 76 157
14 Total Deferred Costs Including Financing Costs 19 39 58 6314
Total 59,601
Witness: JCI
Schedule 1
Page 8 of 12
Rider RGGI Cash Working Capital
September 1, 2020 to December 31, 2020
(000s)
Working
Expense Capital
Average Daily (Lead) Lag Net (Lead) (Provided)
Line No, Amount_________Amount_________Days Revenue Lag Lag Days Required
Amortization Expense
3 Allowance Amortization 39.1 39.1
A Amortization of Regulatory Assets (Deferred Costs) 39.1 39.1
5 Pre RAC Cost Deferral 39.1 39.1
6 Pre RAC Cost Deferral - Debt Interest (58) (0.48) 39.1 39.1 (19)
7 Pre RAC Cost Deferral - Equity (182) (1.49) (39.1) 39.1
8 Pre RAC Cost Deferral - JDC (1) (0.01) (39.1) 39.1
12 Interest Expense 58 0.48 (90.9) 39.1 (51.9) (25)

13 Preferred Dividends (39.1) 39.1
14 JDC Expense 1 0,01 (39.1) 39.1
15 Income Available for Common Equity 182 1.49 (39.1) 39.1
16 Totals (43)
17 Balance Sheet Items (A/P --Allowance Purchases) 13,708 37.55
18 System Cash Working Capital J43)

Witness: JCI
Schedule 1
Page 9 of 12
January 1, 2021 to July 31, 2021
(000s)
Working
Expense Capital
Average Daily' (Lead) Lag Revenue Net (Lead) (Provided)
Line No. Amount Amount______ Days______ Lag Lag Days Required
Allowance Amortization
3 39.1 39.1
4 Amortization of Regulatory Assets (Deferred Costs) 39.1 39.1
6 Pre RAC Cost Deferral - Debt Interest (392) (1.84) 39.1 39.1 (72)
7 Pre RAC Cost Deferral - Equity (1,227) (5.76) (39.1) 39.1
8 Pre RAC Cost Deferral - JDC (7) (0.03) (39.1) 39.1

14 JDC Expense 7 0.03 (39.1) 39.1
15 Income Available for Common Equity 1,227 5.76 (39.1) 39.1
16 Totals (167)
17 Balance Sheet Items (A/P - Allowance Purchases) 69,100 378.63
18 System Cash Working Capital HiZ)

Witness: JCI
Schedule 1
Page 10 of 12
August 1, 2021 to December 31, 2021
(000s)
Working
Average Expense Capital
Daily (Lead) Revenue Net (Lead) (Provided)
Lag Days Lag Lag Days Required
Line No- Amount Amount
3 Allowance Amortization 51,123 336.15 39.1 39.1 13,130
4 Amortization of Regulatory Assets (Deferred Costs) 24,834 163.29 39.1 39.1 6,378
6 Pre RAC Cost Deferral - Debt Interest 39.1 39.1
7 Pre RAC Cost Deferral - Equity (39.1) 39.1
8 Pre RAC Cost Deferral - JDC (39.1) 39.1

14 JDC Expense 13 0.08 (39.1) 39.1
16 Totals 78,946 19,262
18 System Cash Working Capital 19,262

Witness: JCI
Schedule 1
Page 11 of 12
January 1, 2022 to July 31, 2022
(000s)
Working
Expense Capital
Average Daily (Lead) Revenue Net (Lead) (Provided)
Line No Amount Amount Lag Days Lag Lag Days Required
3 Allowance Amortization 78,395 368.20 39.1 39.1 14,382
4 Amortization of Regulatory Assets (Deferred Costs) 34,787 163.29 39.1 39.1 6,378
Pre RAC Cost Deferral - Debt Interest
6 39.1 39.1
7 Pre RAC Cost Deferral - Equity (39.1) 39.1
8 Pre RAC Cost Deferral-JDC (39.1) 39.1
12 Interest Expense 628 2.95 (90.9) 39.1 (51,9) (153)

14 JDC Expense 11 0.05 (39.1) 39.1
16 Totals 115,767 20,607
18 System Cash Working Capital 20,607

Company Exhibit No.__ ®
Witness: JCI ^
Schedule 1 N5
Page 12 of 12 y

Actual Cost of Capital and Capital Structure
As of December 31, 2019
K3
Line Annual Embedded Weighted

No. Description Amount Percent Cost Cost Cost
1 Total long-term debt $ 12,085.529,684 44.926% $ 538,619,437 4.457% 2.002%

2 Short-term debt (13-month average) 697.797.692 2.594% 14.591.675 zm% 0.054%
3 Total debt S 12,783,327,376 47.520% 553,211,111 4.328% 2.056%
4 Total preferred stock QJ1QQ%

Q.000% 0.000%
Common stock $ 5,737,401,834 21.328% 9.200% 1.962%

Other paid-in capital 1,112,875,284 4.137% 9.200% 0.381%
Retained earnings 7,168,179,892 26.647% 9.200% 2.452%
AOCI (29,200,805) -0.109% 9.200% -0.010%
Adjustments 17,014,963 0.063% 9.200% 0.006%

Total common equity $ 14,006,271,168 52.066% 9.200% 4.790%
Job devetopmenl tax credits

10 Allocation: debt 51,492,357 0.191% 4.457% 0.009%
11 Allocation: preferred stock 0.000% 0.000% 0.000%
12 Allocation: equity 59.675.987 0,222% 9.200% 0.020%
13 Total Job development tax credits $ 111,168,344 0.413% 7.003% 0.029%
14 Total Capital $___ 26.900.766.888 100.000% 9.8755%

Dominion Energy RGGI Rider Request

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Dominion Energy RGGI Rider Request

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(9Cu~H

Virginia State Corporation Commission

Case Number (if already assigned) PUR-2020-00169

Document Type £_X^£.

Total Number of Pages 100

eFiling Date Stamp 11/9/2020 3:03:40PM

Bernard Logan, Interim Clerk

Dear Mr. Logan:

/s/ Elaine S. Ryan

cc: William H. Chambliss, Esq.

For approval of a rate adjustment

Case No. PUR-2020-00169

Filed: November 9,2020

Direct Testimony of C. Eric McMillan

Direct Testimony of Shane T. Compton

Direct Testimony of John C. Ingram

Direct Testimony of Paul B. Haynes

Filing Schedule 46A Sponsored by Company Witnesses C. Eric McMillan and

Statement 1 Projected Costs by Type of Cost

Filing Schedule 46B Sponsored by Company Witness John C. Ingram

Statement I Rider RGGI Revenue Requirement

Filing Schedule 46C Sponsored by Company Witness Paul B. Haynes

Statement 1 Methodology of Allocation of the Revenue Requirement and Rate

STATE CORPORATION COMMISSION

PETITION OF VIRGINIAELECTRIC AND POWER COMPANY

Company respectfully shows as follows:

I. Dominion Energy Virginia is a public service corporation organized under the

Commission. The Company is an operating subsidiary of Dominion Energy, Inc.

2. The Company’s address is:

Virginia Electric and Power Company

Joseph K. Reid, Ifl

4. Initiated in 2009, RGG1 is the first mandatory market-based program in the

5. In May 2019, the Virginia Department of Environmental Quality (“DEQ”) issued

submittals required of companies subject to the Rule, on August 12, 2020.

allowance auction program.

8. Va. Code § 56-585.1 A 5 e permits cost recovery related to compliance with

RGGI and establishes the applicable standard of review:

9. The Company estimates it will initially require approximately 19,000,000 CO2

strategy as needed to adapt to changes in the structure of the RGGI program.

requested for recovery during the rate year.

Petition for the Rate Year beginning August 1,2021, is $168,260,000.

(“kWh”) from all bundled service customers in the Virginia jurisdiction.

SUPPORTING TESTIMONY, FILING SCHEDULE 46, AND REQUEST FOR LIMITED

16. The Company’s Petition is supported by the pre-filed direct testimonies of

to Subsection A 5 “shall include Schedules 45 and 46 as identified and described in 20 VAC 5-

with this Petition, Filing Schedule 46, as follows:

a. Company Witnesses McMillan and Compton co-sponsor Schedule 46A,

b. Company Witness Ingram sponsors Schedule 46B, consisting of Statements 1 and

c. Company Witness Haynes sponsors Schedule 46C, consisting of Statement 1,

WHEREFORE, Dominion Energy Virginia respectfully requests that the Commission

(iv) grant such other relief as deemed appropriate and necessary.

VIRGINIA ELECTRIC AND POWER COMPANY

By: /s/Elaine S. Rvan

Joseph K. Reid, III

Counsel for Virginia Electric and Power Company

Witness: C. Eric McMillan

Title: Manager, Power Contracts and Origination

2 Power Company (“Dominion Energy Virginia” or the “Company”).

3 A. My name is C. Eric McMillan, and I am a Manager of Power Contracts and Origination

5 23219. A statement of my background and qualifications is attached as Appendix A.

6 Q. Please describe your areas of responsibility with the Company.

9 renewable energy portfolio standard program from a market procurement perspective. I

1 I Company’s non-utility generation power contracts.

12 Q. What is the purpose of your testimony in this proceeding?

13 A. I am testifying in support of the Company’s petition for approval of a rate adjustment

17 program in which the Company is required to participate. I will provide a general