PUR-2025-00049

The docket identifies several areas of growth and provides key considerations related to each:

1. Energy Sales and Load Growth:
- There are contrasting forecasts for energy sales and load growth. The company’s forecast, finalized in December 2024, is less conservative than the Enverus forecast from June 2025, which projects slower growth for both APCo Load Serving Entity (LSE) and the PJM-AEP Zone. The Enverus model is particularly restrained in its load growth outlook. This difference affects projections for resource needs and planning 1.

Key considerations:
- Timing and methodology differences in forecasting can significantly impact planning.
- More conservative load growth assumptions could delay or reduce the need for new capacity.

2. Capacity Price Growth:
- For the 2026/2027 and 2027/2028 delivery years, a “capacity price collar” sets floors and ceilings ($175/MWh floor, $325/MWh ceiling). Enverus models capacity prices clearing near the ceiling through 2030, but expects a sharp decrease if the collar is lifted, as the floor would be removed 1.

Key considerations:
- Regulatory mechanisms (like price collars) can create artificial price stability or inflation.
- Anticipated future changes to these mechanisms introduce uncertainty in long-term planning and project economics.

3. Technology and Resource Options:
- The company is planning for growth in baseload resource options, including SMR nuclear, combined cycle natural gas units (with and without carbon sequestration), and other technologies. Alternative technologies with comparable cost and performance may be substituted if market or technological conditions change 2.

Key considerations:
- Flexibility in resource selection is necessary to adapt to emerging technologies and market shifts.
- Compliance with statutory requirements (e.g., Code § 56-585.5) is a prerequisite for resource eligibility.

4. Battery Energy Storage:
- The docket discusses the Wythe BESS project, a utility-scale battery storage project being developed in Wythe County, VA, with a 52.2 MW capacity and 208.8 MWh energy storage. The project is considered an “RPS eligible source” as it is physically located within the PJM region 3.

Key considerations:
- Battery storage supports grid reliability, renewable integration, and compliance with RPS requirements.
- Environmental review and wetland impact consultation are required before siting such facilities.
- The project must adhere to operational, safety, and mitigation standards.

In summary, the key areas of growth are in energy sales/load, capacity prices, diversified generation resource options, and battery storage deployment. Each area’s considerations revolve around regulatory compliance, forecast uncertainty, technological flexibility, and environmental impact.

The timeline of key events and scheduled submissions in Appalachian Power Company's 2025 RPS Plan proceeding (Case No. PUR-2025-00049) is as follows:

- May 21, 2025: Appalachian Power Company completed the filing of its annual 2025 RPS Plan with the Virginia State Corporation Commission.
- June 6, 2025: The Commission issued its order for notice and hearing, established a procedural schedule, directed staff to investigate the filing, provided for public participation, and assigned a hearing examiner.
- June 10, 2025: Sierra Club filed a notice of participation and a motion for admission pro hac vice for Dorothy E. Jaffe, which was subsequently granted.
- June 24, 2025: Proof of publication and service of notice as required by the Commission's June 6 order was certified as complete by Appalachian Power Company 1, 2.

The procedural schedule also typically includes subsequent deadlines for contract execution, regulatory approval, and project milestones, but the above dates reflect the major filings and Commission actions so far in the docket.

The docket discusses several financial and timeline risks and concerns:

Financial Risks and Concerns:
- Uncertainty from U.S. tariffs and duties, especially on steel, aluminum, copper, turbine components, solar cells, and modules, which makes it difficult to provide a fixed price for renewable generation resources. This has led to prolonged negotiations and a need for flexibility in contract terms to balance risk between developers, the company, and customers.
- Cost sharing mechanisms have been incorporated in contracts (e.g., Wythe BESS and Livingston Wind PSAs) to manage these risks. These mechanisms allow for risk/benefit sharing before construction starts and include negotiated caps; if costs exceed these caps, parties can terminate the agreement if no new arrangement is reached.
- The company mitigates cost increase risks via a rigorous review process and includes allowances for validated increases in its contingency budget 1.
- Contracts require sufficient funding capacity to meet ongoing project needs, and sellers must maintain sources for funding to achieve substantial completion and final completion according to agreements 1.

Timeline Risks and Concerns:
- Regulatory approval is required from the Virginia State Corporation Commission and, where applicable, the Federal Energy Regulatory Commission. The effectiveness of project sale agreements (PSAs) is conditional on timely regulatory approvals, posing a risk of delay if approvals are not received as expected 1.
- The uncertainty and evolving nature of tariffs, duties, and local permitting ordinances have caused delays in negotiations and project schedules 1.
- Contract terms address timeline concerns by imposing conditions precedent and providing for contract termination if certain cost or regulatory thresholds are not met before the start of construction 1, 1.

The provided excerpts do not list all stakeholders by name or provide a comprehensive breakdown of which stakeholders are for or against specific proposals in this docket. However, the following key stakeholders are identified:

- Appalachian Power Company (APCo): The petitioner, submitting the 2025 RPS plan and associated projects for approval, including the Livingston Wind facility, Collier Solar PPA, and Wythe BESS project 1, 2, 3.
- Virginia State Corporation Commission (SCC) Staff: Reviews and analyzes APCo’s proposals, provides testimony, and offers recommendations or illustrative suggestions but does not explicitly state support or opposition to specific projects 1, 2, 4.
- Project Developers: For example, Holocene Clean Energy (developer of Collier Solar), who submit proposals in response to APCo’s RFPs. Their support is implicit in their participation, but explicit positions for or against other proposals are not stated 5.
- Local Communities: Particularly those identified in environmental justice assessments, such as low-income or fenceline communities near project sites. Their stance is not directly stated, but developers are required to address potential impacts and local economic benefits in their proposals 5, 6.
- Other Bidders: Entities participating in the RFP process, whose identities and positions are not detailed in the excerpts.

There is no specific information in the excerpts regarding which stakeholders are explicitly for or against particular proposals. The excerpts focus on the evaluation process, project descriptions, and procedural aspects rather than advocacy or opposition by named stakeholders.

Docket PUR-2025-00049 before the Virginia State Corporation Commission concerns the petition of Appalachian Power Company (APCo) for approval of its 2025 Renewable Portfolio Standard (RPS) plan pursuant to § 56-585.5 of the Code of Virginia 1. The proceeding includes the following key elements:

- The Commission has appointed a hearing examiner to oversee the case, including a telephonic hearing scheduled for August 12, 2025, for public testimony on APCo’s 2025 RPS filing 2.
- The docket features modifications to discovery procedures, such as expedited responses (within 5 calendar days) to interrogatories and production requests, and mandates electronic service of documents to promote efficiency 2, 2.
- APCo requests approval of its RPS compliance plan, which details renewable energy certificate (REC) retirements, compliance calculations, and the use of banked RECs. For 2024, APCo retired 1,376,888 RECs to meet a 10% RPS obligation, with no deficiency payments required 3.
- The docket also addresses APCo’s resource planning, including the addition of renewable and storage resources, and outlines procurement and compliance strategies through at least 2028 4.
- The matter remains active and continued for further proceedings, filings, and regulatory review 2, 2.