Utility program deep dive · Virginia

Dominion Energy Virginia C&I demand response and battery economics

Why data centers make Dominion’s territory a prototype for VPPs at scale, what curtailment pays against PJM capacity, and how a business battery pencils out on Schedule GS-2.

VPP Economics has no affiliation with, sponsorship from, or endorsement by any utility, aggregator, platform, or device maker named here.

The short answer

  • The business programs are classic demand response. Non-Residential Curtailment pays $36 per kW-year for cutting at least 100 kW on 10–20 event days, and the Distributed Generation program pays $8.25 per kW-month to run backup generators. The 2027 VPP pilot adds a bring-your-own-device aggregator pilot that opens the door to third parties.
  • The biggest flexible load in Virginia may be the data center. Dominion is already curtailing large new loads that accept non-firm service: more than 500 hours of curtailment in 2026 under its CAPFLEX pilot, one event lasting about 194 hours.
  • Utility pay sits far below the market. PJM capacity clears at its cap, about $119 per kW-year, more than three times Dominion’s curtailment rate. A business must choose: Dominion’s program cannot be combined with PJM demand response.
  • A business battery is a long payback today. On Schedule GS-2 demand charges, a hypothetical 100 kW / 400 kWh battery pays back in about 24.5 yr with curtailment pay, or about 16.2 yr if a provider passed through 60% of PJM capacity value.
$36per kW-year, Non-Residential Curtailment
$119per kW-year, PJM capacity at the cap
508hours of CAPFLEX curtailment in 2026
178local load relief warnings in 2026

Dominion, Virginia and PJM: who does what

Dominion Energy Virginia is vertically integrated, but it operates inside PJM, so a business in its territory has two ways to sell flexibility: to Dominion through its demand-side programs, or to PJM through a curtailment service provider. That is the key structural difference from Duke Energy Carolinas, where Duke’s own programs are the only buyer.

Three tracks

Where the money comes from, who sets the rules, and what reaches a business.

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Money comes fromRules set byWhat customers getDominionEnergy Virginia:generation, wires,meterBase rates and riders; the VPP pilotadds about 20¢ a month to a typicalbillPlans resources in its IRP;dispatches through the ConcertoDERMS, live since 2025Non-Residential Curtailment, thebackup generator program and theBYOD Aggregator Access PilotVirginiaSCC and GeneralAssemblyLaw sets the pilot at up to 450 MW,with at least 15 MW of homebatteriesThe SCC approved the pilot on August3, 2026, and reviews the IRP andratesCost caps, an income- andage-qualifying battery pilot and a2028 reportPJM and aggregatorsregional marketCapacity auctions clearing at thecap, about $119–$122 per kW-yearFERC-approved rules; Order 2222aggregations from February 2028Curtailment service providers forbusinesses; third-party DERs in theBYOD pilot
Simplified. Sources below.

Programs by asset

Dominion Energy Virginia and PJM business flexibility options.

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Existing loadBatteryGeneratorPayStatusNon-Residential Curtailment100 kW or morecurtailmentif load drops—$36/kW-yropenDistributed Generationbackup generators 200 kW+——up to 120 hrs$8.25/kW-moopenSmall business HVACunder 400 kW, VPP pilotthermostats——$75 + $40/yrfrom 2027BYOD Aggregator Pilotthird parties, under 5 MWvia aggregatorvia aggregatorno fossilpay for performancefrom 2027PJM demand responsecurtailment service providersvia providervia providervia providerPJM capacityopenOfferedPartly or unclearThrough another companyNot offered
Dominion program terms from Dominion; pilot terms from Dominion’s filing. Non-Residential Curtailment cannot be combined with PJM demand response. The Distributed Generation program is run by PowerSecure and is not part of the VPP, which excludes fossil generation. Sources below.

What makes Dominion different: the data center as the flexible load

Every deep dive on this site has one feature that changes how its economics read. For Dominion C&I it is scale. Most business VPP programs we cover are built around office HVAC, cold storage or a 100 kW battery. In Dominion’s territory the customer class that matters most for flexibility is data centers, which can each draw hundreds of megawatts.

Load growth from the 2026 IRP

DOM Zone annual energy, 2026–2046, in gigawatt-hours.

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Stacked bar chart of DOM Zone annual energy from 2026 to 2046, rising from about 150,000 GWh to about 405,000 GWh, a 5.2% compound annual growth rate
Chart from Dominion Energy’s 2026 Integrated Resource Plan update. Blue: PJM-derived DOM load-serving entity (LSE) energy; green hatched: residual DOM Zone energy. Total rises from about 150,000 GWh in 2026 to about 405,000 GWh in 2046, a 5.2% compound annual growth rate.

The data center pipeline

Contracted data center capacity by contract stage, and the actual metered peak.

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0 GW10 GW20 GW30 GW40 GW50 GW60 GWJuly 2023contracted data center capacity16.5 GWJuly 2026ESA + CLOA + ELOA53.8 GWAugust 2026data center billing peak, actual4.8 GWElectric service agreementsConstruction lettersEngineering lettersMetered peak
Contract stages from Dominion’s Q2 2026 results; billing peak from PJM. Contracted capacity is not load. Sources below.

Dominion reports about 4 GW of data centers in Loudoun County, more than 20 GW of new data center load expected by 2031 and about 10 large-load requests a month (Dominion Energy). Where the transmission grid cannot yet serve them firmly, some customers accept non-firm service under its CAPFLEX pilot: 29 curtailment events and about 508 hours so far in 2026, the longest lasting about 194 hours. Dominion also counts 178 post-contingency local load relief warnings so far in 2026 (Dominion Energy).

Two lessons follow for smaller businesses. First, the value of flexibility in Northern Virginia is partly locational: a kilowatt reduced in a constrained load pocket is worth more than the same kilowatt elsewhere, and no current Dominion business program pays a locational premium. Second, data center backup generators are a large untapped resource, but Dominion’s VPP excludes fossil generation, so they stay in the separate Distributed Generation program.

What a flexible kilowatt is worth

Utility pay against the market

PJM capacity prices and Dominion’s per-kW business program pay.

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$0/kW-yr$50/kW-yr$100/kW-yr$150/kW-yr$200/kW-yrPJM capacity, uncapped2028/29 auction without the cap$202/kW-yrPJM capacity at the cap2028/29, $325 per MW-day$119/kW-yrBackup generator program$8.25 per kW-month, fossil$99/kW-yrBattery Storage Pilotabout $50 per average kW$50/kW-yrNon-Residential Curtailment$36 per kW-year$36/kW-yr
PJM prices from PJM and Utility Dive, converted from $ per MW-day. Program rates from Dominion. PJM accredits demand response at less than nameplate and providers keep a share, so a site would see less than the PJM bar. Sources below.

Non-Residential Curtailment averages about $26,250 a year per participant (Dominion filing), which at $36 per kW implies sites of roughly 700 kW. Those sites could also sell through a PJM provider, where capacity at the cap is worth about $119 per kW-year before the provider’s share. Dominion’s program offers simpler terms and fewer events; PJM offers more money and more risk.

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Non-Residential Curtailment

Building controls

$36 per kW-year, paid monthly; 10–20 events a year.

Small business HVAC

Rooftop HVAC

$75 to enroll and $40 a year under 400 kW, from 2027.

Rate + program

Battery

Schedule GS-2 demand savings plus curtailment or PJM capacity, not both.

Distributed Generation

Backup generators

$8.25 per kW-month for up to 120 hours a year; outside the VPP.

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BYOD Aggregator Pilot

Solar with a battery

Pay for performance through an aggregator, under 5 MW, no double enrollment.

Stacking needs care, depending on M&V methodology. Dominion’s curtailment program and PJM demand response measure the same kilowatts, which is why they cannot be combined.

If the business adds a battery

Schedule GS-2, for sites of 30–500 kW, bills demand on the highest 30-minute interval of the month: $4.963 per kW for distribution, $1.971 for transmission and $1.803 for generation in summer, $0.588 in winter (Schedule GS-2). That is about $95 per kW-year before riders. Energy is not time-of-use priced, so a battery earns little from shifting.

Capital stack

Ten years of credit, savings and program pay as a share of cost plus ten years of maintenance.

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0%25%50%75%100%125%150%GS-2, bill onlydemand savings47%GS-2 + Non-Res Curtailment$36 per kW-year, assumed eligible61%GS-2 + PJM through a providerwhat-if, 60% of the cap to the site75%Covers full costFederal creditDemand savingsDominion curtailmentPJM capacity
100 kW / 400 kWh at $600 per kWh plus $15 per kW-year maintenance; 30% federal credit, subject to construction-start rules (Solar Cost Data); 50 kW off monthly peak demand. Demand riders that apply above a 50% load factor are excluded (Rider GEN). Whether a battery qualifies for Non-Residential Curtailment is not confirmed. Sources below.

Payback

Simple payback in years after the federal credit.

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0 yr10 yr20 yr30 yr40 yrGS-2, bill onlydemand savings40 yractual 51.6 yrGS-2 + Non-Res Curtailmentassumed eligible24.5 yrGS-2 + PJM through a providerwhat-if16.2 yr
Undiscounted, before taxes on savings. Sources below.

Own, borrow or buy a battery service

The GS-2 case with Non-Residential Curtailment. Money in and out of the site, then cumulative cash over 10 years.

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OWN IT OUTRIGHTCash−$240k installedday one+$72k federal credit30% §48E+$3k a yeardemand savings, net of upkeep+$4k a yearNon-Residential Curtailment10-year net cash−$99kSite keeps every stream$BORROW THE NET COSTLoan=$0 down; incentives pay principalborrows $168k−$24k a year for 10 years8% interest+$7k a year, netsame savings and pay as cash−$77k of interestover the loan term10-year net cash−$176kCash-flow testTHIRD-PARTY OWNERShared savings=$0 capitaldeveloper owns the battery+$1k a yeara guaranteed 15% of bill savings=Developer keeps curtailment payand the federal credit=Needs about 75% lower costor a larger site, for an 8% return=15-year contractdeveloper carries upkeep and risk10-year net cash$7kPositive cash, if offeredCumulative cash to the site, years 0–10−$200k−$150k−$100k−$50k$0k$50kyr 0yr 2yr 4yr 6yr 8yr 10Shared savingsdeveloper owns the batteryCashowns the batteryLoanowns the battery$77k of loan interestCash pays $168k net on day one
Illustrative, undiscounted. Loan at 8% over 10 years on cost after the credit. The battery service assumes a guaranteed 15% share of savings over a 15-year contract, an illustrative floor; at the modeled cost the developer would earn less than 8%, so a deal like this needs a lower cost or a larger site. The first 10 years are shown. Sources below.

The developer’s side

The site’s line above is only half of the deal. The developer pays the full $240k, carries maintenance, insurance and performance risk, and prices all of it into the contract to earn a return on its capital (Morgan Lewis). Third-party storage contracts usually run 15 years or more (Peak Power), and lenders treat 15- to 20-year terms as financeable (Illinois Power Agency). The chart below values each deal from the developer’s side.

What the developer earns

Present value of what the developer receives, as a share of what it spends, by contract terms.

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0%50%100%150%25% to the site, 10 yearsa short contract57% · $147k vs $259k25% to the site, 15 yearssame split, longer term57% · $157k vs $275k25% to the site, 20 yearswith augmentation in year 1158% · $160k vs $278k15% to the site at $60k15 years; installed cost 75% lower100% · $76k vs $76kCovers full costFederal credit, soldDepreciation tax valueNon-Residential CurtailmentDeveloper share of bill savings
Illustrative. Present value at an 8% after-tax return with a 27% combined tax rate; past the dashed line the developer earns at least 8%. Federal credit sold at 92 cents per dollar; storage still qualifies (Plante Moran). First-year depreciation on cost less upfront incentives and half the credit, which needs tax appetite (Ferrius Energy). Costs include maintenance plus 1% of installed cost a year for insurance and asset management. Savings held flat, with rate increases offsetting battery fade; the 20-year case adds a 10% augmentation in year 11.

With 25% of savings left to the site, a 15-year deal covers about 57% of the developer’s cost on our model, or about 65% if the battery earned 60% of PJM capacity value instead. At the modeled cost, a developer cannot earn 8% and still leave the site a share of bill savings. Battery-service offers are not priced the other way around, as a fee on top of handing over the savings: shared-savings providers promote a guaranteed share from day one (Gridwealth Electric), and Peak Power’s projects in Westchester, New York, split bill savings and market revenue with the building owner (NYSERDA case study). A deal that cannot fund a share is usually not offered at all. A guaranteed 15% share would need an installed cost about 75% lower, near $60k, well below today’s prices, so here a deal depends more on new program pay than on cheaper batteries; larger sites help, and providers such as Peak Power focus on facilities with more than 1 MW of load (Peak Power’s overview). The battery-service line above shows that 15% share. In Dominion territory today, a locational or capacity-linked payment is what would change that.

Why Dominion is ripe for more

A VPP readiness check

Eight conditions that make a territory ready for VPPs at scale, and Dominion’s status on each.

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What a VPP-ready territory needsWhere Dominion Energy Virginia stands, October 2026Fast load growthDOM Zone annual energy grows 5.2% a year through 2046 in the 2026 IRP, ledby data centersIn placeScarce capacityThree PJM auctions in a row at the price cap; the 2028/29 auction fellabout 6.8 GW shortIn placeLocal constraints178 post-contingency local load relief warnings so far in 2026, centeredon Northern VirginiaIn placeOrchestration softwareOne DERMS, Generac’s Concerto, live since 2025 and integrated with gridoperationsIn placeA mandate and a budgetState law: up to 450 MW and at least 15 MW of home batteries by July 1,2028In placeOpen accessA BYOD aggregator pilot capped at 1,000 enrollments; PJM Order 2222 fromFebruary 2028PartlyMulti-asset rulesNet-metered solar is excluded and each device takes one programNot yetPay that tracks valueBattery pilot pays about $50 per kW-year against about $119 for PJMcapacityNot yet
VPP Economics assessment from the 2026 IRP, Utility Dive, Dominion Energy, the Code of Virginia and Dominion’s filing. Sources below.
Pilot

Launch in early 2027

Dominion expects the DSM-XIV programs, including the VPP pilot, to launch around the first quarter of 2027 and run through 2030 (Dominion filing).

Deadline

15 MW of batteries by mid-2028

The SCC left budget flexibility so residential storage can reach 15 MW by July 1, 2028 (Advanced Energy United).

Market

PJM Order 2222 in 2028

Dominion’s filing plans for PJM’s distributed-resource aggregation rules to go live in February 2028 (Dominion filing).

IRP

39 GW of new resources

The 2026 IRP update adds 39,244 MW by 2046, including 3,525 MW of storage and 8,965 MW of gas (Energy News Beat).

Bills

A typical bill up 57%

The IRP projects a typical 1,000 kWh bill rising from $180.31 to $283.65 a month by 2046 (Energy News Beat).

Neighbor

Appalachian Power’s own pilot

A separate law gives Appalachian Power a 150 MW VPP pilot in southwest Virginia (Code of Virginia).

Compare: ComEd C&I for another PJM zone where capacity costs reach the customer through a peak load contribution, and Duke Energy Carolinas C&I for a vertically integrated utility without a market.

Method and caveats

An independent, hypothetical analysis for business owners, facility managers, program designers, developers and other readers in Dominion Energy Virginia territory. Terms checked October 29, 2026.

Assumptions for the hypothetical battery: 100 kW / 400 kWh at $600 per kWh; $15 per kW-year maintenance; Schedule GS-2 base demand charges with 50 kW off the monthly peak and riders excluded; Non-Residential Curtailment at $36 per kW-year on 100 kW, assuming a battery qualifies; PJM what-if at 60% of the 2028/29 capped price on 100 kW. The developer figures price a 15-year third-party agreement at an 8% after-tax return.

Figures are gross savings and program payments before taxes on savings, financing and degradation. Gross payments are not net profit. Non-Residential Curtailment, the Distributed Generation program and PJM demand response are event-based demand response, not orchestrated VPPs. Stacking needs care, depending on M&V methodology.

VPP Economics has no affiliation with, sponsorship from, or endorsement by Dominion Energy, PowerSecure, Generac or any company named here.

Sources

Load growth, data centers and PJM

  1. Dominion Energy — 2026 Integrated Resource Plan update
  2. Energy News Beat — Dominion’s plan adds 39 GW of power
  3. Southern Environmental Law Center — Response to Dominion’s IRP
  4. Yahoo Finance — Dominion Energy Q2 2026 earnings
  5. Investing.com — Dominion Q2 2026 slides
  6. Stock Analysis — Dominion Q2 2026 call transcript
  7. PJM Load Analysis Subcommittee — Dominion Energy, September 2026
  8. PJM — Dominion load forecast documentation
  9. Dominion Energy — Operational realities of large load flexibility, September 2026
  10. Clean Air Task Force — Virginia’s uncertain energy future
  11. PJM Inside Lines — 2028/29 capacity auction results
  12. Utility Dive — PJM capacity auction at the price cap
  13. PJM — 2027/28 Base Residual Auction report

Virginia VPP law and pilot

  1. Code of Virginia — § 56-585.1:16, VPP pilot
  2. Code of Virginia — § 56-585.1:19, Appalachian Power pilot
  3. Utility Dive — Virginia leads with utility-scale VPP pilot
  4. Virginia SCC — Report RD623 (2026) on the VPP pilot
  5. Dominion Energy — Virtual Power Plant
  6. Dominion Energy — VPP pilot testimony, Schedule 1
  7. Advanced Energy United — SCC VPP order
  8. Advanced Energy United — Getting the VPP pilot right
  9. WHRO — Virtual power plants will launch soon in Virginia
  10. Solar United Neighbors and CEG — Value of a Virginia VPP

Dominion business programs

  1. Dominion Energy — Targeted sector programs

Business rates

  1. Dominion Energy — Schedule GS-2
  2. Dominion Energy — Rider GEN

Costs and finance

  1. Solar Cost Data — Energy tax credits in 2026
  2. Peak Power — Financing strategies for battery storage (third-party contract terms)
  3. Illinois Power Agency — Energy Storage Procurement Report (financeable contract tenors)
  4. Morgan Lewis — Shared-savings contract structures for energy storage
  5. Plante Moran — Battery storage investment tax credit after 2025
  6. Ferrius Energy — Storage depreciation and basis reduction

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