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Virginia State Corporation Commission eFiling CASE Document Cover Sheet ……Document Description Summary Direct Testimony & Exhibits of D. Scott Norwood, filed on behalf of the Office of the Attorney General’s Division of Consumer Counsel

DIRECT TESTIMONY OF SCOTT NORWOOD ON BEHALF OF OFFICE OF THE ATTORNEY GENERAL DIVISION OF CONSUMER COUNSEL SEPTEMBER 15, 2015

The purpose of my testimony is to present my evaluation and recommendations regarding Dominion Virginia Power’s (“DVP” or “Company”) 2015 IRP filing. The focus of my testimony is on the Company’s proposed resource plans that include the continued development of the North Anna Unit 3 nuclear generating facility (“NA3”), in view of the requirement in § 56-599 that the Commission shall make a determination as to whether an IRP is reasonable and in the public interest.

 Dominion has not estimated the average annual retail rate impacts that would result from construction of NA3. However, assuming that the NA3 project is completed without further cost increases, I estimate that the first year revenue requirement for the project (including related replacement fuel cost savings) would be almost $2.4 billion. This would result in an average rate increase of approximately 25.7% over current Virginia retail residential rates.

The analysis presented in DVP’s 2015 IRP Report does not demonstrate that the Company’s plan to continue development of NA3 is reasonable in consideration of the increasing costs ofNA3 relative to other resource options identified in DVP’s IRP analyses. In fact, theNA3 project is more costly than the Least Cost Plan (“LCP”) in all 19 scenarios evaluated by DVP in the 2015 IRP, and is not the lowest cost option for complying with the EPA’s Clean Power Plan. DVP has not completed analysis of other issues of concern regarding the NA3 project that were ordered by the Commission in the Company’s 2013 IRP proceeding; however, the analyses that have been completed generally indicate that there are much lower cost alternatives to NA3. Moreover, the forecasted capital cost of NA3 is far higher than the ElA’s current generic cost estimate for nuclear generating units. For all of these reasons, DVP’s 2015 IRP strategy to continue development of NA3 does not appear to be reasonable. …… http://www.scc.virginia.gov/docketsearch/DOCS/34bx01!.PDF