by Steve Haner

The staff of the State Corporation Commission (SCC) has concluded that Dominion Energy Virginia cannot meet the energy demands of our data- center based digital economy with renewable energy projects alone, and “does not oppose” adding natural gas.

“It is unlikely, in Staff’s opinion, that renewable energy development alone will suffice to serve the Company’s forthcoming energy and capacity needs caused by data center demand,” wrote Public Utility Division manager Andrew T. Boehnlein in testimony filed back on August 19. Boehnlein in part focuses on the unreliability of offshore wind.

The testimony is part of the utility’s pending application to build a new natural gas plant in Chesterfield County, subject to a full SCC hearing starting September 23. The staff analysis concluded “there is reasonable support for the claim that the Company is currently resource deficient, and that the Company will be significantly more resource deficient if the projected data center load growth materializes in whole or in part.”

That testimony came from Steven E. Smith, a Public Utilities Division analyst, but in both cases it is clear they were signing off on consensus opinions. Smith reported they were “not opposed” to the application but noted that the company’s application had not really proven that the proposed 944-megawatt peaker plant, only slated to run on high demand days, was the best choice to address the coming energy shortage.

In similar testimony in another case, this one dealing with Dominion’s application for a rate increase, the SCC staff chose to highlight the deficiency of utility-scale solar projects when reliable energy is in short supply. As previously reported, it noted all of Dominion’s big solar projects were failing to meet promised output. All of them.

In a similar vein, this case turns the spotlight on the inadequacy of the massive Coastal Virginia Offshore Wind project, more than halfway to completion 27 miles off the coast of Virginia Beach. Boehnlein’s testimony zeroes in on Dominion’s own data from a computer model it used to prove it would need the gas plant in a future bitter cold snap. It is worth quoting Boehnlein at length: 

“…the largest single in-state resource, renewable or otherwise, ever constructed, which is Dominion’s offshore wind facility, will be coming online at the end of 2026 with a nameplate capacity of approximately 2,600 MW. According to the Company, this resource, despite its size, will not alone be able to adequately support the Company’s energy and capacity needs. Indeed, as Company witness Crabtree’s Cold Snap Analysis demonstrates, when the Company needs energy the most, the Company expects that the production from the offshore wind facility, which the Commission found has a price tag of over $21 billion, will collapse.”

(Author’s note:  The $21 billion is the all-in “revenue requirement” for the project, including the $11 billion plus construction cost, decades of maintenance, annual profit and interest expenses, and the pot of money saved for the day it must be removed. It is the amount demanded from customers over the years.) 

“At the peak of the Cold Snap Analysis event, when the Company has 2,242 MW of unserved customer demand, the offshore wind farm is projected to contribute approximately 414 MW of energy, relative to its 2,600 MW nameplate rating. In its worst performing hour over the three-day event, the Company forecasts that the offshore wind facility is predicted to contribute just 153 MW, or approximately six percent of its nameplate capacity. In that same hour, the Company forecasts 1,337 MW of unserved customer load.

“According to the Company, ‘[t]he CVOW output is based entirely on the dispatch of the 2-turbine pilot during the Cold Snap hours, scaled to the installed capacity of the project. To the Company’s knowledge, the reduction in the CVOW pilot output was due to the drop in wind speed.’ Given that the offshore wind farm is non-dispatchable, the Company will necessarily have to build more resources, and likely natural gas-fired resources, to make up for the offshore wind farm’s performance characteristics, particularly in the overnight hours in the dead of winter.

“According to the Company, ‘these changes in capacity factor and output serve to illustrate the nature of weather-dependent intermittent resources and underscore the need for dispatchable generation.’”

To model that future long stretch of bitter cold, Dominion merely looked at the last similar energy crunch this past January and how the existing two 6-megawatt turbines performed. To use Boehnlein’s word, they collapsed to almost no output in crucial nighttime hours when solar will also be unavailable. See his attachment ATB-2 to track Dominion’s projection of the hourly output and it often is far below the possible 2,600 megawatts. As bad as the wind is, check out the zero or tiny solar output most hours of that three-day event.  

There is the problem with the Virginia Clean Economy Act in a nutshell, in one exhibit from Dominion’s own sworn data testimony. Yet the political fight to prevent construction of this proposed gas plant or any such future plant continues to rage. At a hearing before the Department of Environmental Quality Monday night, opponents packed the room and presented a new letter of opposition signed by 20 Democratic members of the General Assembly, many of them on the November ballot.Virginia Mercury reproduces it.

Some of Boehnlein’s most pointed testimony shows up in a footnote, where he describes the transmission issues that might prevent Dominion from injecting all the electricity from the turbines into the regional grid, even when it is running full tilt. A failure to do that doesn’t just mean less energy when needed, it will impose a financial penalty on ratepayers, also because of the Virginia Clean Economy Act.   

“If the offshore wind facility cannot put energy onto the grid, it cannot produce RECs,” Boehnlein writes, referring to renewable energy certificates. “If the Company cannot acquire sufficient RECs, customers will have to pay a deficiency payment. For the capital and financing costs of the offshore wind farm, the Company could have built approximately 6 CERCs.” 

That deserves a repeat. For the cost of the offshore wind project, Dominion could instead have built six (6!) of the 944-megawatt natural gas peaker plants. And as other testimony makes clear, those peaker plants are not the most cost-efficient hydrocarbon choice at all. Yet for the same money, Dominion would have almost 6,000 megawatts capable of running on demand, when you need it most, rather than 2,600 megawatts that “collapse” when needed most.

We’ve been warned, Virginia.