DDominion Energy

You provide disclosure about the effects of climate change on weather and how this could impact the company. Please quantify any material weather-related damages to your property or operations.

Dominion Energy tracks the impacts of weather-related damages to its properties and operations as storm damage and service restoration costs. Historically, Dominion Energy’s electric transmission and distribution operations have incurred the majority of such costs. To the extent that there is a weather event causing significant costs and customer outages, these costs are allocated to the Corporate and Other segment as these amounts are not included in profit measures evaluated by executive management in assessing operating segment performance or allocating resources.

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As such, these amounts when significant are disclosed within Note 26, Operating Segments, in the Notes to the Consolidated Financial Statements. For example, costs associated with major storm damage and restoration were disclosed when such amounts were $70 million ($52 million after-tax) for the year ended December 31, 2018 for Dominion Energy. To the extent that there is a significant variance between periods in the total storm damage and service restoration costs, inclusive of any costs associated with major storms, such amounts would be disclosed within Item 7. Management’s Discussion and

Analysis, specifically within the Analysis of Consolidated Operations section. The decreases in such costs were not considered to be significant to the analysis of Dominion Energy’s results of operations, specifically to an understanding of other operations and maintenance expense, for either 2020 compared to 2019 or 2019 compared to 2018. Dominion Energy’s other operations and maintenance expense in its Consolidated Statements of Income were $3.7 billion, $3.8 billion and $2.8 billion for the years ended December 31, 2020, 2019 and 2018, respectively. One factor which mitigates the impacts of weather-related damages to Dominion Energy’s results of operations is that the regulatory framework applicable to its subsidiary Dominion Energy South Carolina, Inc. provides for the recovery of storm damage and restoration costs in excess of a set annual amount. These costs are deferred to a regulatory asset, which at December 31, 2020, did not represent a material balance to Dominion Energy.

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If material, disclose any weather-related impacts on the cost or availability of insurance.

Damages associated with weather related flooding, storm surge and other wind driven water damage have been a factor in the cost of insurance in recent years. However, these events have not had a material impact to the cost or availability of Dominion Energy’s overall insurance program. To the extent that there had been a significant variance in Dominion Energy’s results of operations from the cost of insurance, such amounts would have been disclosed within Item 7. Management’s Discussion and Analysis, specifically within the Analysis of Consolidated Operations section. Read in the reply ↗

Disclose any material litigation risks related to climate change and the potential impact to the company.

Dominion Energy evaluates material risks as part of its quarterly financial reporting process conducted by its SEC Reporting team, which includes employees from the accounting and legal departments, through discussion with and information provided by our litigation and risk teams. While

Dominion Energy has identified and disclosed risk factors related both to litigation and to changes in the weather, including the effects of global climate change, as disclosed in Item 1A. Risk Factors, Dominion Energy has not yet identified a material litigation risk related to climate change.

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To date, Dominion Energy is not aware of any specific and targeted global warming or climate change litigation asserted or reasonably expected to be asserted against it. To the extent that

Dominion Energy was a party to any litigation reasonably possible to result in a material impact, such litigation would have been disclosed within the Note 23, Commitments and Contingencies, in the Notes to the Consolidated Financial

Statements and Item 3. Legal Proceedings.

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You provide disclosure about the purchase of carbon credits to offset emissions. If material, provide disclosure about any material effects of this on your business, financial condition, and results of operations.

Dominion Energy’s purchases of carbon credits primarily relate to its subsidiary Virginia Electric and Power Company (Virginia Power) in connection with state regulations in Virginia. This topic has been disclosed both within Note 23, Commitments and Contingencies, under the subheading State Regulations in the Environmental Matters section as well as within Note 13, Regulatory Matters, in the Virginia Regulation section of Other Regulatory Matters, in the Notes to the Consolidated Financial Statements.

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As disclosed in Note 13 under the subheading Virginia 2020 Legislation, a component of the Virginia Clean Economy Act of 2020

(VCEA) and related legislation includes provisions directing Virginia Power to participate in a market-based carbon trading program consistent with the Regional Greenhouse Gas Initiative (RGGI) through 2050 with the associated costs recoverable through an environmental rider. As also noted within Note 13, under the subheading Riders, Virginia Power filed an application in December 2020 for the approval of Rider RGGI to recover such costs with a proposed $167 million revenue requirement for the rate year beginning August 1, 2021. As this program commenced in 2021, there were no material amounts incurred as of December 31, 2020.

As disclosed within Note 13, Regulatory Matters, in the Notes to Consolidated Financial Statements to Dominion Energy’s Form 10-Q for the quarter ended June 30, 2021, the Virginia State Corporation Commission approved Rider RGGI with a $168 million revenue requirement for the rate year beginning September 1, 2021. Costs incurred through June 30, 2021 associated with Virginia Power’s participation in the market-based carbon trading program have been included within regulatory assets on Dominion Energy’s Consolidated Balance Sheets with such amounts included within the caption deferred rider costs for Virginia electric utility within the table shown in Note 12, Regulatory Assets and Liabilities.

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We note from your response to prior comment 2 that damages associated with weather related flooding, storm surge and other wind driven water damage have been a factor in the cost of insurance in recent years. Provide us with additional detail clarifying how matters related to weather were a factor in the cost of insurance and explain the statement that this has not had a material impact to the cost or availability

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of your overall insurance program.

The most significant component of Dominion

Energy’s insurance program relates to its nuclear operations, including associated property insurance programs. The insurance coverage and related premiums for its nuclear facilities are separately disclosed within Dominion Energy’s Notes to the Consolidated Financial Statements, Note 23. Commitments & Contingencies, under the heading Nuclear Operations within its Annual Report on Form 10-K for the year ended

December 31, 2020.

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As disclosed therein, Dominion Energy’s nuclear property insurance maximum retrospective premium assessment for the most recent policy period was $99 million.

The cost of non-nuclear property insurance is driven by several factors, including our claims history, location of our assets and total value of the insured assets in addition to overall external market factors. While Dominion Energy has not made any claims in the last ten years for damages associated with weather related flooding, storm surge and other wind driven water damage, we believe that claims made by other entities for such events have been a contributing factor in the cost of insurance. The value of the insured assets varies based on acquisitions and dispositions as well as construction activity.

Dominion Energy’s non-nuclear property insurance has annual premiums based on the total insured values for annual periods beginning on November 1st of the rate year. For the five most recent insurance rate years, covering the periods November 1, 2016 through November 1, 2021, the annual premiums for non-nuclear facilities ranged between

$11 million and $19 million, with corresponding total insured values ranging between $46 billion and $69 billion. While Dominion Energy’s insurance premiums have increased or decreased primarily as the result of changes in total insured values, the ratio of premiums to total insured values has increased over the past five years from approximately 2.4% for the rate year commencing November 1, 2016 to 3.0% for the rate year commencing November 1, 2020. While it is not possible for Dominion Energy to specifically quantify the amount, weather related events are considered to be a component of the increase in premiums relative to insured values. The year-over-year variance in insurance premiums has been less than $5 million during each of the last five years. As such, management has not included specific reference to these changes within the Analysis of Consolidated Operations section of Item 7. Management’s Discussion and Analysis as the changes are not considered to be significant to the analysis of Dominion Energy’s results of operations, specifically to an understanding of other operations and maintenance expense, for either 2020 compared to 2019 or 2019 compared to

2018. Dominion Energy’s other operations and maintenance expense in its Consolidated Statements of Income were $3.7 billion, $3.8 billion and $2.8 billion for the years ended December 31, 2020, 2019 and 2018, respectively.

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Your response to prior comment 3 states that you are not aware of any specific and targeted global warming or climate change litigation asserted or reasonably expected to be asserted. Please tell us how you considered providing disclosure addressing the risks associated with the possibility of climate or environmental-related litigation and its potential impact.

Dominion Energy considers the possibility of climate or environmental-related litigation and its potential impact in the preparation of Risk Factors, which includes a separate section titled Environmental Risks. The adequacy of our risk factors disclosure is reviewed regularly as a part of our disclosure controls and procedures, which are designed to include multi-tiered levels of involvement and review by multiple personnel within the disclosure process.

Dominion Energy’s SEC Reporting team, which includes employees from the accounting and legal departments, conduct several procedures to

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consider what additions, revisions or deletions are appropriate to the Risk Factors sections within Dominion Energy’s Forms 10-K and 10-Q. Members of the SEC Reporting team meet with the corporate risk group, internal counsel, including its litigation lawyers, and with outside counsel as well as surveying all Dominion Energy executives. Members of management, including the SEC Reporting team, internal counsel and the corporate risk group, stay abreast of current risk trends and uncertainties in the utility industry, including through its active involvement in Edison Electric Institute (EEI) and American Gas Association (AGA), trade associations that represent U.S. investor-owned electric and natural-gas utility companies. In addition, management routinely reviews industry publications and peer company SEC filings. Dominion Energy’s senior risk officer also provides periodic reports to the Board of Director’s Finance and Risk Oversight Committee, which oversees the implementation of the company’s risk assessment and risk management policies and objectives.

Throughout this process, we consider if additional or revised risk disclosure is appropriate, including disclosure addressing specific risks associated with potential climate or environmental-related litigation. For example, our current risk factors discuss litigation risk associated with the disposal and storage of coal ash. Dominion Energy has not experienced any litigation specific to climate change.

Additionally, management has not identified any litigation affecting peer companies which would seem reasonably possible to have a material negative impact to Dominion Energy. For example, while management observed climate related litigation affecting certain utilities in California, Dominion Energy has not experienced, and does not believe it is at risk of experiencing, similar material litigation related to wildfires or other climate change related events within its service territories. In addition to the risks identified within the Environmental Risks section, Dominion Energy has included a risk within the Operational Risks section related to the potential of Dominion Energy’s financial performance and condition to be affected by changes in the weather, including the effects of global climate change, as well as multiple risks within the Construction Risks section related to both environmental factors and litigation as they may potentially impact various development projects. Dominion Energy will continue to closely monitor climate and environmental risks, including those related to litigation, for inclusion within its risk factor disclosures.

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