Consumer Group: Halt Spending on North Anna 3

Source: Dominion Virginia Power 2016 Integrated Resource Plan

Dominion Virginia Power capacity projections under Clean Power Plan E. Source: 2016 Integrated Resource Plan (Click for more legible image.)

by James A. Bacon

A Virginia consumer advocacy group has petitioned the State Corporation Commission to forbid Dominion Virginia Power from spending more money on its proposed $19 billion North Anna 3 nuclear unit without obtaining formal approval from the SCC.

Dominion has spent $600 million on the project, mainly for engineering and regulatory expenses, but also $58.6 million on site preparation, administrative buildings, and “craft and other service support buildings,” maintains the Virginia Citizens Consumer Council (VCCC) in the SCC filing. “As Dominion spends more money on North Anna 3, it may become more difficult for the expenditures to be disallowed without causing financial harm to the utility.”

The SCC has allowed Dominion to recover $310 million of the money spent so far, but the company has stated in its Integrated Resource Plan that it will not seek cost recovery for the rest until it receives a federal Combined Operating License (COL). The COL, the company says, will provide “an option to build a nuclear unit at the North Anna site at some point in the future,”which is “of great value given the uncertainty of the [Clean Power Plan] and the uncertainty of any other federal or state law or regulation that the Company and its customers may face in the future.”

While Dominion contends that ongoing construction costs are incurred solely at the risk of the company’s stockholders, says the VCCC filing, “the Company has made it clear that at some point in the future, it intends to seek recovery of those expenditures, whether or not the project is ever completed. … The Company is treating all ongoing expenditures as ‘recoverable’ for accounting purposes.”

Consumer and environmental groups have long contended that the proposed North Anna 3 plant would be far more expensive than non-nuclear alternatives such as energy conservation, electricity purchases from wholesale markets, and green energy sources such as wind and solar, backed by energy storage technologies such as batteries. Building North Anna 3, according to the Virginia attorney general, could boost electric rates by 26% in Dominion’s service territory.

In its Integrated Resource Plan (IRP), Dominion has described a third unit at the North Anna nuclear power station as its ace in the hole should Virginia adopt the most stringent alternative available to the states under the Clean Power Plan, which limits CO2 emissions from the nation’s power plants. The so-called Plan E, or “Mass-Based Emissions Cap” applying to both old and new generating units, would force Dominion to retire some of its fossil fuel generating plants and would leave nuclear and renewables as the only viable non-CO2 emitting alternatives for replacing that capacity and meeting increasing demand as the economy grows. In Virginia, environmentalist groups are urging the McAuliffe administration to adopt the strictest Mass-based option should the Clean Power Plan pass U.S. Supreme Court muster next year.

Dominion has characterized wind and solar as intermittent, thus “nondispatchable,” meaning that they generate power when the wind blows and the sun shines, not necessarily when people are consuming electricity. The electric grid can handle a significant amount of variable production, but at some point the system becomes unstable. In a Plan E regulatory environment, Dominion argues, building nuclear would be the only way to add stable base-line capacity. In essence, Dominion regards North Anna 3 as insurance, albeit very expensive insurance, should Virginia adopt the strictest approach to controlling carbon emissions.

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40 responses to “Consumer Group: Halt Spending on North Anna 3

  1. Scientists May Have Found Reason Behind Unusual Earthquakes in Southeastern U.S.

    Until now, the exact cause of the earthquake perplexed geologists. But a new study published in the Journal of Geophysical Research – Solid Earth has an explanation for this event and others in the region.

    Rather than originating from plate boundaries, as earthquakes in more active regions do, they key to these quakes is beneath the plates and in the Earth’s mantle, researchers found. Their theory is that pieces of the mantle are breaking off, weakening the plate above. And they found that the 2011 earthquake is one of many that are likely to come.

    https://weather.com/safety/earthquake/news/earthquake-southeast-us-north-american-plate

    at some point – the NRC should put the kibosh on this even if DVP is lacking in judgement.

  2. Procedurally, this is what should happen. Interest groups should participate in VSCC proceedings to advance their views. Of course, the Commission must recognize that these are interest groups that may or may not represent the public interest. But, in any event, it is good to see more participation in energy proceedings.

  3. There are a fair number of such groups. The VCCC, which filed this petition, was very active itself back in the 1990s. The Southern Environmental Law Center is active in many dockets and various homeowner associations in transmission line cases.

    The problem is that the subject matter is very technical and getting a general legal practitioner up to speed in order to provide effective representation can be very daunting, not to mention expensive. The attorney who filed this particular petition formerly worked at the Attorney General’s office in its consumer protection division and is very well regarded. He’s likely doing this pro bono.

  4. I am growing more and more skeptical about the cost-benefit result on North Anna 3, which is a shame because I think nuclear power needs to remain part of the mixture. The regulatory requirements and legal battles just add so much to the cost, and the country continues to fail to make rational decisions on dealing with the used fuel.

    That said, Dominion can take all the risk it wants with the stockholder’s money but can expect a battle if it tries to recover the funds beyond what it is already authorized to recover. And I wouldn’t be surprised it that is the message the SCC chooses to send.

  5. I have three problems. First – we’re still using technology that allows disastrous meltdown if some bad happens….

    then – DVP apparently (along with others here, I presume) does not think putting that technology on a demonstrably active earthquake fault is a deal killer.

    then these things are giant terrorist targets –

    I’m just flabbergasted that this thing is still alive given the confluence of those first two issues at this site

    Find a new place or find a new technology.

    I am NOT opposed to nuclear power. I do not understand if we can size them for ships why we cannot do that for land-based which at the least would limit the amount of damage if they did go bad.

    we just have what feels like an almost ideological allegiance to a BAD design …that has a proven track record of making a large area uninhabitable if it goes bad That’s just not acceptable.

    We’ve had 60 years at the drawing board and all we have is what we started with? No way!

    At this point – we need to start thinking about the age of these plants – and what we’re going to transition to – that’s not a 60 year old meltdown design.

    I consider continuing reliance on such a risky design to be just flat unacceptable – irresponsible.

    The public opposition is not because of some fraidy-cat foolishness. They don’t want to use uber risky technology – they want a better technology. I think folks in the industry are fooling themselves if they think they can gradually bring the public back to trust – it’s not going to happen. People inherently know it’s not a good design. They KNOW the damage that can result.

    You’d have no trouble what-so-ever with a design that shuts down passively – on it’s own when trouble happens and goes into a dormant state OR one in which the “disaster” has a radius of a mile or two not 50-100 miles.

    Nuke industry folks are living in LA LA land… build a better design.

    • It would take more space than I have, and I’m not the right person, but Larry — The most recent designs are significantly different and safer than previous designs, the technology is greatly advanced. That is partly why they are costing more. Fascinating that a power plant proposed for Virginia causes panic but 60 years of a nuclear Navy built and based in Virginia causes pride.

    • I cannot speak for natural disasters. But it is my understanding that the NRC (Nuclear Regulatory Commission) has practical requirements for nuclear plant security that are comparable to that at sensitive government facilities.

  6. The real driving force here is the GA’s indecision on the Clean Power Plan. NA3 is a very legitimate response to Plan E, IF that is the choice of the GA. Indecision, postponement, procrastination has a price . This key part of DVP’s IRP is, very simply, DVP’s way of saying, the price of keeping the possibility of Plan E open is to keep the possibility of NA3 open — at ratepayer expense, because the cost of this latter possibility is “prudently incurred.”

    In short, DVP is saying to the SCC, “if you tell us NOT to keep the NA3 option open but then the State goes with CPP Plan E, we will have to play an expensive catchup game and the fingers will be pointed at you. It’s your call, SCC!” This is, pure and simple, “regulatory chicken.”

    • Acbar, I’m curious, why do you pin the indecision on the General Assembly?My understanding, possibly wrong, is that the DEQ picks which course to take. And it’s hard for DEQ to make a ruling until the Supreme Court decides whether the Clean Power Plan is constitutional. Am I missing something?

      • Seriously? Are you missing something? Actually, you are missing everything. The Imperial Clown Show in Richmond exercises dictatorial power in this state. The one term governor can’t touch them, the judiciary (appointed by the Clown Show) can’t touch them, the SCC (also appointed by the Clown Show) can’t touch them and the DEQ can’t touch them. Off year elections, endless illegal gerrymandering and impossible ballot eligibility rules means the electorate can’t effectively touch them either. I know that you and your friends in the Richmond elite are just fine with this distributed dictatorship. After all, so long as the goodies keep flowing toward the Imperial City of Richmond, why would you complain? Unfortunately, the rest of us have to pick up the pieces of this anti-democratic governance structure. Why is the Clown Show to blame? Because they totally control the state. The better question is why you pretend not to understand this.

        As an aside, here’s your DEQ in action:

        http://www.styleweekly.com/richmond/chief-of-virginia-deq-attended-masters-tournament-on-dominions-dime/Content?oid=2300365

        P.S. – You really should make it a point to read more of Peter’s writing. He has somehow managed to live in the Richmond area without becoming a state government zombie.

        • Don, do you have a shred of evidence to suggest that the General Assembly, not the DEQ, will decide which of the Clean Power Plan options to adopt?

          • Evidence? How about proof. On party line votes for two session running the Assembly has passed bills requiring that it make the final decision on CPP compliance. This governor has vetoed them and is trying to maintain control over the decision but the final decision may not come until the next governor’s term, so this will be a 2017 issue. So the evidence is a series of bills which have passed but been vetoed. The Assembly is certainly trying to grab onto the power to decide.

            With all due respect to them, based on years of close monitoring of these issues, my preference would be a decision made by the SCC after major input from DEQ and all stakeholders. Yes, the SCC judges are elected by the Assembly, but I don’t share Don’s ultra-cynical view that they are controlled by the Assembly.

          • Yeah, sure, the SCC probably would be the better independent decision-maker — as opposed to the SCC as the GA’s handmaiden. But, given who elects the members of the SCC, and who rejected DVP’s efforts to spin off its generation and vertically “de-integrate” and then bought off on DVP’s change of direction to abandon retail access, and who has passed DVP’s current micro-legislated ratemaking process, and who remains poised to pounce on whatever the SCC does with the IRP process — I will view whatever comes out of the SCC this December upon review of Dominion’s buck-passing IRP as (1) addressed to the GA, and (2) entirely conditioned upon what the GA does on the CPP. And it appears DEQ is waiting for the SCC to sort through and address the economic alternatives. And since DEQ has not spoken, and the SCC has remained silent till now, and the GA has not ratified or reversed anything they have said or spoken for itself, except the usual posturing and pontificating — I believe the SCC will punt in December and approve a continuation of the caution on renewables and keep alive the NA3 hedge until, so to speak, “such time as the clouds clear and we can see the horizon.” Which is another way of saying, as to the CPP, until the GA has decided the course, nobody that matters is steering this ship.

          • Here you go –

            http://lis.virginia.gov/cgi-bin/legp604.exe?161+ful+HJ120ER

            29 Whereas’s followed by a recommendation that JLARC do DEQ’s job, presumably because the Imperial Clown Show in Richmond didn’t like the answers they were getting from DEQ.

            Why doesn’t the General Assembly pay any ongoing attention to Virginia’s public colleges and universities? Because there is no way to extract money from those colleges and universities for the personal benefit of the the members of the general assembly.

            Why does the General Assembly regulate one fish and only one fish – menhaden (the remainder are regulated by the Virginia Marine Resources Commission)? Because Omega Protein fishes for menhaden and is willing to stuff money into legislators’ pockets.

            If I throw a baseball up in the air I know it will come down. Why? Because of the law of gravity.

            If there is money involved I know the Imperial Clown Show in Richmond has their hand in the cookie jar. Why? Because of the law of greed.

          • Thanks for refreshing my memory. The General Assembly tried but failed to take control of the process. Under the Virginia constitution, the governor’s veto settles the matter.

            I’ve been critical in the past of McAuliffe exceeding his executive authority. In this case, he prevented the General Assembly from exceeding its authority.

          • Re: CPP – My feeling is that the GA does not currently have CPP input, as that power resides in the Gov. This session, GA learned the power of VA Gov executive action, in a state where we thought we had usurped all power from the Governor position.

            Next session we will probably (if Repubs are in charge) we will go from one term Gov to zero term Gov, or equivalently give GA more power over CPP and other matters.

            That said, as far as NA3, believe next Gov may play key role in recommending a direction. Can you spell E-A-R-T-H-Q-U-A-K-E?

        • Fairfax County has only itself to blame. For example, its Senators and Delegates gave then Governor Mark Warner the votes to pass his tax and spending increases that cost county taxpayers $107 M the first year and gave Fairfax County Schools about $7 M in return. Yet, it’s still easy to go to a public forum and hear multi-degreed morons get up and say they’d gladly pay higher state taxes in exchange for more money for the Schools.

          Ditto for most county residents who said nothing when then Governor Tim Kaine agreed to transfer the Dulles Toll Road to MWAA and allow ordinary people who driver the DTR each day to pick up the tab for Silver Line construction cost overruns. Keep in mind that the DTR tolls constitute virtually all the State’s contribution to Silver Line construction. Yet, did any Fairfax County legislator protest?

          This is not the fault of Richmonders or anyone else who lives south or west of NoVA. As Al Capp used to write “We have met the enemy and it is us.”

          • Reed Fawell 3rd

            Boy – Are you ever right about that. I am continually amazed at the passivity of the local middle class American citizen in the face of constant and unrelenting abuse by their leaders and their government. Year after year they act like lambs being led to the slaughterhouse.

          • Mark Warner hasn’t been governor in 10 years. Even when the Warner tax hike was passed it was opposed by many NoVa legislators like Scott Limganfelter …

            https://lis.virginia.gov/cgi-bin/legp604.exe?042+vot+HV1951+HB5018

            The Silver Line benefits NoVa. Why shouldn’t people driving in NoVa pay for it?

            If you are saying that NoVa’s representatives to the Imperial Clown Show are as willing to sell out their constituents as the other General Assembly members – I would agree. If you’re saying they hide behind gerrymandering, off year elections, impossible ballot restrictions and unlimited campaign contributions – I would agree.

          • Don – both the State’s Environmental Impact statement and the Tysons traffic studies show the Silver Line will not provide any net traffic congestion relief for the Dulles Toll Road. Indeed, the traffic studies show that, despite the Silver Line, a billion plus in road and non-rail transit improvements, and high-quality mixed use development, total gridlock is coming to Tysons and surrounding areas. Once development hits 84 MSF, the DTR, the Beltway, Route 7 and Route 123 will fail every evening rush period. So where is the benefit to the DTR drivers?

            The basic problem with the Silver Line is that it could not pass a cost/benefit test to qualify for federal funding and that was after being grandfathered to the older and weaker test. The feds funded Phase 1 of the Silver Line solely due to political pressure from both political parties. This is just as corrupt as anything that happens in Richmond.

            Moreover, the adopted plan capped the Phase 1 funding liability for everyone except the DTR drivers. The landowners’ share was capped at about $450 M. The feds’ funding was capped at $900 M. The rest went on the backs of ordinary people commuting to and from work. How is that fair?

            There was a letter written by then FC County Executive Tony Griffin to the Secretary of Transportation Pierce Homer (November 1, 2005) in which, Griffin committed the County would pay its fair share of Silver Line cost increases through either the general fund or a bond issue. Once Governor Kaine made the transfer of the DTR to MWAA, Fairfax County has taken the position the Griffin letter is moot. All cost overruns are on the backs of the DTR drivers.

            The economic bottom line is that the Silver Line and the resultant redevelopment of Tysons involve a huge transfer of wealth from ordinary people to Bechtel (the main contractor for Phase 1) and the Tysons landowners within 1/4 mile of the four stations. It somewhat reminds me of feudalism.

            I’m not arguing we should shutter the Silver Line or stop redevelopment at Tysons. It’s way too late. Rather, we need to recognize publically the gains for some are paid by the losses of many. It’s plain and simple highway (or, in this case, tollway) robbery. Tysons & the Silver Line would make a perfect Bernie Sanders commercial for the deck is stacked economics.

            Interestingly, I’ve asked my supervisor for the county’s projection as to when the added real estate and sales tax revenue from Tysons will allow the County to reduce real estate taxes, at least in nominal terms, across the board as has occurred in Arlington. I’m waiting for the answer.

            Over the next 40 years, Tysons will succeed in redeveloping a suburban office park to an urban area. The buildings will be very nice and very expensive. Silver Line usage will increase over time, but auto congestion will continue to grow, perhaps to the point where Tysons loses some of its attraction. We’ll never see the day where added tax revenue from Tysons reduces our property tax bills.

      • Jim, I share much of DonR’s opinion set out just below yours. If the CPP is strung out into the next Governor’s term and if the Governor is a member of the party controlling the “Imperial Clown Show,” then the GA may get a say. If not, you are correct that the DEQ is the lead agency and will draft the plan. As I see it, under this latter scenario, the GA’s options to amend or reject the plan drafted by the DEQ would be limited to budgetary trickery to preclude the agency from spending funds to implement the plan. In that case, assuming that a lengthy court battle would ensue, the EPA would get to step in and impose its own plan.

  7. “regulatory”? naw…. here’s a test –

    ” State Gives Go Ahead for Third Nuclear Plant at North Anna – will cost 13 billion “.

    I predict that headline would not be a “regulatory” issue but a political one.

    🙂

  8. Thanks dr. I feel unappreciated

  9. This is all such a puzzle to me; especially in the founding colony for a supposedly free nation.

    In the other states in which I have lived, energy issues were resolved by the state utility regulator. Influenced by the governor and state legislator, of course, through legislation and appointments. But never have I seen a one-term governor or off-year elections for state legislators.

    Fundamentally, this is a choice between a long-term revenue stream for a utility versus the interests of the ratepayers and the health of the state economy. A choice for nuclear must address its exorbitant cost and its bad fit in a modern energy system because of its lack of flexibility.

    The argument for nuclear is a false choice. Dominion has presented it as the only choice to meet a lower carbon emission target. If we created 1500 MW of energy efficiency it would provide 24-hour baseload capacity at 2-3 cents per kilowatt hour. Far lower than any other option in Dominion’s IRP. This would result in a rate decrease, not a 26% increase as Dominion suggests for North Anna 3. And this is a low estimate. No nuclear power plant has come in on schedule and on budget in the last 50-60 years in the U.S.

    Dominion says that solar is not “dispatchable”. Correct at the moment but solar costs are rapidly declining as is the price of storage. By 2030 dispatchable solar plus storage combinations are expected to be less than the cost of energy from combined cycle gas plants that are 1/10th the cost of nuclear plants. Both energy efficiency and renewables provide a zero carbon source of energy at a far lower cost than nuclear.

    Far cheaper sources of nuclear power (plants that are 40-50 years old) are being decommissioned because they are not cost competitive in today’s energy environment. They are very inflexible in their operation because they must run all of the time and are very slow to make adjustments in their output. We are moving to a system where demand will be altered to respond to changes in supply. Must-run nuclear plants will only contribute to a less flexible, much more expensive energy system.

    A future that is better for our utilities and for our ratepayers is available if we have the foresight and political will to create it. Unfortunately that might not be as attractive for our public servants.

    • Absolutely right! But the SCC is not independent of the GA in this State (any more than the typical utility regulator is free from the typical Governor’s interference elsewhere). And the GA is not going to push Dominion into a savings program it can’t rate-base, as opposed to new construction in many members’ home districts.

      • I agree. But every taxpayer is also a ratepayer.

        The market would be leading us to greater energy efficiency and greater share of renewables if that was the only issue. A move in that direction is being slowed by utilities’ need for revenues under current rules.

        The EPA did not ask for more natural gas or more nuclear they only asked for less emissions that contribute to climate change. Wall Street pushed for more natural gas to get their billions out of their current money-losing investments in shale plays. Utilities are pushing for more natural gas, nuclear and central station solar because that is how they currently make money. Ratepayers mostly don’t know that more energy efficiency and third-party distributed generation would lower their bills. There is no huge single corporate interest that would benefit from that move except the citizens themselves. The citizens’ voice is not often heard in our halls of government anymore.

        There would be thousands of new jobs in GA members’ home districts with a statewide policy for more energy efficiency (ala Massachusetts). Far more than would be associated with any utility project and the jobs would be spread throughout the state, not just one district. However, there is no single entity related to that to provide GA members with a special “incentive” to vote for such a proposal; even though it would benefit the state economy and lower utility bills.

        We don’t have to choose between healthy utilities and low rates and clean energy. But the way we are headed, someone else will make that choice for us.

        • Correct. The energy efficiency lobby needs to get off its morally superior, green platitudes and make exactly that case for it to legislators: the lowest electricty cost path forward AND more jobs than utility central plant generation has ever provided. I think VA’s SCC already understands this well enough but needs a receptive audience at the GA to give it the backbone to push Dominion.

          • And the GA/SCC need to give Dominion a revised role and new business model to thrive in a 21st century energy economy. Dominion cannot continue to do it all themselves. They must open up the playing field to other participants or any move towards greater efficiency and lower utility bills will stall.

  10. Here’s a comment from an investment advisor’s newsletter:

    ” The Sunlight Foundation – a nonpartisan watchdog group that tracks lobbyist spending and influence in both parties – reported on research it undertook between 2007 and 2012, tracking 200 of America’s most politically active corporations.

    After examining 14 million records – including data on campaign contributions, lobbying expenditures, and federal budget allocations and spending – it found that, on average, the most politically active corporations in the U.S. received $760 from the government for every dollar spent on influencing politics, for a total of $4.4 trillion.

    As the figure was rounded up slightly, that translates to a 75,900% rate of return. Compare that to the 0.25% Grandmother gets on her CDs.

    Crime pays; it pays even better when you do it with the help of the government.

    And these days, it pays even better still. Thanks to the Fed, bribe money has never been so cheap.”

  11. In this case it’s not to receive money from the government’s taxpayers, but to receive permission from the government to collect the money from its own ratepayers. Otherwise they are basically right. But we can’t look solely at the State disfunction and the SCC/DEQ/GA policy triangle; the blame also lies with the EPA and Congress for creating this expensive dilemma called the CPP and handing it off to the States.

  12. re: ” … the blame also lies with the EPA and Congress for creating this expensive dilemma called the CPP and handing it off to the States.”

    isn’t that sorta like saying it’s the EPA’s fault for pointing out the pollution in the Chesapeake Bay needs to be addressed – when the State, the GA, and all the folks dumping into it – themselves have chosen to not address it and abdicated that to the EPA?

    If anyone thinks that Dominion or the SCC or DEQ or the GA would address – say mercury deposition or SOx or NOx or the 18 superfund sites in Virginia and the the EPA “interfered” with those entities to deal with the problems themselves.. welcome to Alice in Wonderland politics.. of which the GOP and Conservative types seems particularly disposed to imbibe lustily….

    When I see “real” action and effort from our own folks , I’ll reassess my view – and this is not just about pollution – it’s about schools, transportation, care of the handicapped and mentally afflicted… fair treatment of people of color … etc.. Virginia is not exactly a model of leadership… more along the lines of dragged kicking and screaming… over and over… one has to ask .. what is “leadership” in Virginia? not so much….

    • One more time, Larry. An agency does not have unlimited powers. It can only act within the parameters of its enabling statutes and laws that give it specific duties. It must also follow the Administrative Procedure Act. Just because a problem or a perceived problem exists, an agency may not necessarily have the power to act. Sometimes public problems have no solution. And despite the current phantasy among many Democrats, a refusal of a legislative body to pass a new law addressing a problem does not give an agency authority to act.

      The FCC has probably the most broad ancillary power of any agency in the federal government. Section 154(I) reads “The Commission may perform any and all acts, make such rules and regulations, and issue such orders, not inconsistent with this chapter, as may be necessary in the execution of its functions.” Yet, there are numerous cases that have voided Commission action as being beyond this broad authority.

      An agency without such a broad grant of power, such as the EPA, simply cannot “fix” everything it wants to fix. Government can fix everything it wants to fix only in a dictatorship.

      • @TMT – whether or not it can “fix” is a different question as to it’s authority to act.

        and blaming the EPA for acting when the State chooses to not act is not the same at all as to whether or not the EPA has that authority.

        In fact, the State does have the authority to act and in other State has done so… and has stricter requirements than the EPA requirements.

        but the case of the Chesapeake Bay and TMDLs is a case in point.

        If it were not for the EPA – our rivers would be the cesspools they were under Virginia’s prior feckless “regulation” that has resulted in most of the rivers in Va being polluted to the point where warnings were required for eating fish and for swimming.

        The CPP is an excuse for a failure of the State and it’s feckless “leaders” – itself to act with regard to the safety of it’s own citizens as well as the right of the citizens to not be held hostage to any private sector company with monopoly power.

  13. I wrote this “review demand” before I read all the bad government comments … The Imperial Clown Show is the place where the lack of good policy and rules clearly sits.

    To the above comment … community issues crossing state lines, like pollution, must come from the federal government. The issue with the EPA is that it gave states the ability to do their own enforcing and only steps in when things are clearly in violation. Even then politics and Clown Shows can prevent corrective action. ‘Keep it simple’, like the original Clean Water Act’s ‘fishable and swimmable’ water is a good idea.

    Re Dominion’s demand projections …
    Alternatives to yesterday’s idea that a third reactor on the fault at Lake Anna is … “the only way to add stable base-line capacity.“

    1. Rethink demand levels … The cheapest energy is the energy you don’t use. Projected demand for central grid electricity could be down as much as 50%. Virginia has “done little to promote energy efficiency, ranking near the bottom of all states in terms of its overall efficiency efforts (Serota 2015) and receiving the lowest possible score by the American Council for an Energy-Efficient Economy for utility and public benefits programs and policies.”

    2. Demand response – Participation in capacity markets has shown that efficiency resources can be relied upon to meet system needs. PJM accepts Demand Response savings in their capacity market. The participation of efficiency and other demand resources in capacity markets can lower market-clearing prices, with potentially large economic benefits to consumers. Is the real issue … what generation does that lower capacity price knock out?

    3. Onsite solar generation – VA regulations need to allow easy customer access to finance for both efficient buildings and on-site or community solar through On-Bill or community PACE combined with a state Green Bank. Fair compensation for excess solar sent to the grid is under discussion around the country and can be created to meet both the utility and the customer’s needs. Rules that block off-site ownership need to change.

    In Minnesota “The Conservation Improvement Program not only saves energy and reduces utility bills for Minnesota consumers and businesses. It also creates jobs, boosts our economy and protects our environment,” according to the state Commerce Commissioner. (http://www.utilitydive.com/news/report-minnesota-efficiency-program-returns-4-for-every-1-invested/408835/)

    National Grid, a Mass utility plans to save customers $3.6Billion through a variety of efficiency programs which begin with a free energy audit. The utility plans to invest nearly $850 million in electric energy efficiency and is planning to install 20 MW of community solar.

    Dominion needs to consider efficient buildings and on-site/community generation as ways to meet both demand levels and reduced Green House Gases as required by the Clean Power Plan. Both options are proving good for the customer’s budget and could remove all the demand expansion in Dominion’s chart removing the need for Anna3

    • I agree with all of the above, except I don’t think it is solely Dominion’s responsibility for all of the energy efficiency improvements. Utilities have historically been rather ineffective with their efficiency and demand side management programs. But that might be because they have not had any real incentive to make them so. I prefer that third-parties as well as utilities be encouraged to participate in energy efficiency. Especially with the best prospects, commercial and government buildings. Utilities have easier access to individual residents, but that doesn’t have as big a payoff.

      Massachusetts has a huge initiative underway in which the utilities will play a major role. We’ll see how that works. Regulators must give utilities some other method of paying their expenses and attracting investors if their revenues are significantly diminished.

  14. re: ” To the above comment … community issues crossing state lines, like pollution, must come from the federal government. The issue with the EPA is that it gave states the ability to do their own enforcing and only steps in when things are clearly in violation. Even then politics and Clown Shows can prevent corrective action. ‘Keep it simple’, like the original Clean Water Act’s ‘fishable and swimmable’ water is a good idea.”

    Indeed – the biggest complainers about the EPA – the same folks would have stood in the way of the EPA cleaning up the rivers in the country… they now benefit from the cleaner waters – and still oppose the EPA… as if the waters got cleaner on their own without the EPA… denial and hypocrisy and the twins..

  15. I think it’s pretty easy to survey the states to see who is adopting solar and renewables and who is blaming the EPA for not….

    count the Neanderthals in the CLown show.. as a “not”.

  16. Tom,
    I thought I was blaming The Clown Show for not changing the rules … guess the trouble with that has to do with Dominion’s financial power over elections.
    That said …Property Assessed Clean Energy (PACE) loans, funded by banks or bonds, can be used for efficiency and on-site generation. Pay-back is tied to the property, not the property owner, and is a great way to do private funding for energy loans. VA had a PACE law that was not functional for several years. It was changed, but the change still left the local authorities with defining loan parameters and finding the monies, as well as collecting the loans.
    In CT and TX and other states, the state did a lot of the work, leaving the local governments with just collection. In Texas they called it PACE in a Box. The locals can just call up the state and get the program package as well as create loans that can be grouped and sold on the secondary market.
    Virginia didn’t get that far.

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