Dominion Energy Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Dominion Energy demonstrates a strong governance process for lobbying, particularly in the context of climate-related activities. The company has published a "Climate-Related Lobbying and Trade Associations report" that outlines its approach to policy engagement, climate-related lobbying activities, and associated governance and oversight practices, which indicates a commitment to transparency. The Board of Directors, through its Sustainability and Corporate Responsibility (SCR) Committee, oversees the company's environmental sustainability and climate policies, while the CEO and senior leadership team manage strategy and execution. Additionally, the company has established a Climate Council, Climate Working Group, and Net Zero Team to support its climate governance and ensure alignment with its sustainability goals. Dominion Energy also regularly assesses the positions of its trade associations to ensure alignment with its core values and engages constructively to address misalignments, with the option to sever ties if necessary. The company's Lobbying and Political Contributions Policy requires express authorization for lobbying activities and mandates regular updates to the CEO or operating unit presidents, as well as annual reporting to the Board's Audit Committee on lobbying activities, expenditures, and governing policies. However, while the governance framework is robust and includes oversight of both direct and indirect lobbying, there is no explicit mention of a third-party review or audit of lobbying alignment, which would further enhance the comprehensiveness of its governance process. View Sources	B

Overall Assessment

Analysis

Score

Strong

Dominion Energy demonstrates a strong governance process for lobbying, particularly in the context of climate-related activities. The company has published a "Climate-Related Lobbying and Trade Associations report" that outlines its approach to policy engagement, climate-related lobbying activities, and associated governance and oversight practices, which indicates a commitment to transparency. The Board of Directors, through its Sustainability and Corporate Responsibility (SCR) Committee, oversees the company's environmental sustainability and climate policies, while the CEO and senior leadership team manage strategy and execution. Additionally, the company has established a Climate Council, Climate Working Group, and Net Zero Team to support its climate governance and ensure alignment with its sustainability goals. Dominion Energy also regularly assesses the positions of its trade associations to ensure alignment with its core values and engages constructively to address misalignments, with the option to sever ties if necessary. The company's Lobbying and Political Contributions Policy requires express authorization for lobbying activities and mandates regular updates to the CEO or operating unit presidents, as well as annual reporting to the Board's Audit Committee on lobbying activities, expenditures, and governing policies. However, while the governance framework is robust and includes oversight of both direct and indirect lobbying, there is no explicit mention of a third-party review or audit of lobbying alignment, which would further enhance the comprehensiveness of its governance process.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Dominion Energy provides an unusually expansive picture of its climate-policy advocacy. It names a wide range of specific measures it has engaged on, including federal rules such as “40 CFR 98” and “40 CFR 60 Subparts OOOOa, OOOOb and OOOOc,” the “proposed SEC rules on climate-related disclosures,” the “Inflation Reduction Act of 2022,” and state-level bills and regulations such as Virginia House Bills 2197, 2311, 894, 1797, 2333 and HB 73, HB 118, HB 839, Senate Bill 761, Connecticut Senate Bill 10, NC House Bill 329, HB 951, Colorado rules 5-CCR 1001-5/9/26, and the Virginia Clean Economy Act, among others. The company also describes in detail how and with whom it lobbies. It cites submitting written comments to the EPA and the SEC, “meeting with Congressional offices to encourage continued funding of the Methane Challenge and Natural Gas Star programs,” filing comments with the Virginia Department of Environmental Quality, working “with industry groups: EEI and AGA to respond to the SEC’s request for comments,” participating in stakeholder processes before the Colorado Air Pollution Control Division and the North Carolina Utilities Commission, and supporting or opposing specific bills in the Virginia General Assembly. These disclosures identify both the mechanisms (meetings, formal comment letters, stakeholder working groups, coalition activity) and the precise targets (EPA, SEC, Virginia GA, Colorado APCD, NCDEQ, U.S. Congress) of its lobbying. Dominion Energy is equally explicit about the results it seeks. It supports “direct federal methane regulation of the oil and gas industry,” seeks to “expand the definition of renewable energy” in Virginia to cover advanced nuclear and hydrogen, aims to have “the first small modular nuclear reactor operating by the end of 2032,” backed the IRA’s “robust clean-energy tax package,” and opposed legislation that would impose a “capacity-factor-based performance guarantee” it says could jeopardize the Coastal Virginia Offshore Wind project. The company also discloses its push to repeal Virginia’s participation in RGGI, explaining that the program “increases electricity costs … and is not necessary to realize carbon reductions.” By naming numerous concrete policies, detailing the methods and venues of engagement, and spelling out the specific legislative or regulatory changes it supports or opposes, Dominion Energy demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	A