Category Archives: Energy

Dominion Files to Extend Surry Nukes

Surry Nuclear Power Station

Dominion Energy has filed an application with the Nuclear Regulatory Commission to renew operating licenses for its Surry Power Station for an additional 20 years, the company announced today.

Like all nuclear units, the three-loop Westinghouse pressurized water reactors, capable of generating 1,676 megawatts each, were originally licensed to operate 40 years. Under its current licenses, the two nuclear units are allowed to generate electricity through 2032 and 2033. A second re-licensing would extend their lives through 2052 and 2053. The units account for about 15% of the electricity consumed by Dominion customers.

Dominion also has applied to re-license its two units at the South Anna power station. Between the four units, the utility estimates that it could spend as much as $4 billion on the re-licensing program.

Critics are certain to attack the proposal on the grounds that the power company should not make a long-term commitment to an expensive electric generating source even as the cost of solar power, wind power, and battery-powered backup continue to decline. Dominion argues that the nuclear units will provide a reliable, CO2-free source of base-load electric power. In essence, the critics are advocating a zero-nuclear, renewables-intensive energy policy similar to Germany’s energiewende, which has resulted in high electricity rates and burns CO2-intensive coal to replace the lost nuclear power.

It will make a fascinating debate.

When and Why Can the SCC Say No?

When the General Assembly and Governor pass a law that states a source of electricity – or even a specific power project – is in “the public interest,” what is the State Corporation Commission left to do?  Does that mean the SCC must approve the project even if it turns out to be unreasonable, imprudent or not needed?

Since 2007 the Assembly has designated several aspects of generation and transmission “in the public interest,” this year adding to the list up to 5,000 megawatts of renewable generation and a small and expensive demonstration project for off-shore wind for Dominion Energy Virginia.  Before going further on that wind project, Dominion filed a petition seeking a declaratory judgement on the question of prudence.  Just because one parent said yes, best to check with the other one.

The two SCC commissioners then turned the tables and asked all participants in the matter to give their legal opinion on seven specific questions.  Lawyers for the two major electricity providers, for environmental groups and for the Office of the Attorney General all took a crack at questions such as this one:

“6. Do the statutorily-mandated public interest findings under either Subsections A or E override a factual finding that the project’s: (a) capacity or energy are not needed for the utility to serve its customers; and/or (b) costs to customers are unreasonable or excessive in relation to capacity or energy available from other sources, including but not limited to sources of a type similar to the proposed project?”

Before Dominion dictated a new regulatory approach in 2007,and before Virginia legislators developed a taste for micromanaging the state’s energy economy, such questions never came up.  The SCC had unlimited authority to decide what was needed, prudent or reasonable, subject to appeal.

The briefs are all buried in this pile of documents and they were supplemented with oral arguments on Thursday, drawing a packed house.  There was agreement that a finding of public interest is distinct and does not override questions of prudence or reasonable cost, and the SCC can reject a project for those reasons.  But picking up a phrase used before, Joseph Reid III of McGuireWoods said Dominion views the legislative blessing as “a thumb on the scale” and that phrase in the law “strongly encourages a result.”

The petition dealing with the wind project is filed under a new process for testing prudency. “It would be illogical for the General Assembly to first declare solar or wind generation facilities to be in the public interest and provide for a prudency determination if the General Assembly meant for the terms to be treated synonymously. There would be no need for a prudency determination if such was the case,” wrote Assistant Attorney General Mitch Burton of the Consumer Counsel’s staff.

Burton also pointed to the part of the new bill dealing with putting residential power lines underground.  The General Assembly years ago deemed that underground program in the public interest, and directed the SCC to interpret the law liberally, yet the SCC scaled back the project based on cost.  This year the Assembly added a hard mandate that those costs had to be deemed reasonable,  but that implies SCC discretion remains in other areas.

At times the argument focused on the general issues, but at other times it focused on the project at hand – the 12 megawatt, two-turbine wind project planned for 27 miles off Virginia Beach and projected to cost $300 million.  Supporters of the project argued that the SCC should not reject it just because the tiny energy output is not needed.  Given this has been billed all along as a small demonstration project, not a major source of electricity, the question of need may not apply in its case.

But need will be a question in other cases, and projected demand growth is a major dispute in the pending Dominion integrated resource plan.  The rapid move to renewable sources may be accompanied by the early (and costly) retirement of existing fossil fuel generation. This part of the discussion produced the strongest disagreement among the parties.  They had different answers to part (a) of the question set out above.

Continue reading

How Will the SCC Approach Energy-Efficiency Investments?

The 2018 Grid Transformation and Security Act requires Dominion Energy Virginia to propose at least $870 million in energy-efficiency investments over the next ten years. Yesterday Dominion submitted the first wave of proposals, eleven projects totaling $280 million.

The company estimates that it would spend $215 million on new initiatives and $46.7 million on reconstituting existing programs, reports the Richmond Times-Dispatch. The proposals must be approved by the State Corporation Commission, which in the past has applied a skeptical eye toward energy-efficiency and conservation programs. Under the 2018 legislation, however, the General Assembly declared energy-efficiency to be in the public interest, presumably lowering the bar for approval.

The proposed programs include:

Residential:
1. Recycling older fridges and freezers
2. Gaining insights into energy usage to make suggestions on how to save
3. Rebates on purchases of specific energy-efficient appliances
4. Installation of energy-saving measures following a home-energy assessment
5. Management of heat pumps and air-conditioning units using smart thermostats to reduce peak demand
6. Rebates on qualifying smart thermostats coupled with energy saving recommendations

Non-residential:
1. Implementation of more efficient lighting
2. Upgrades to or implementation of more efficient HVAC technology
3. Installation of solar reduction window film
4. Energy efficiency improvements to small manufacturing facilities
5. Energy-efficiency improvements at smaller offices

In the past, the SCC has balked on energy-efficiency proposals for at least two reasons. First, proposed programs offered a poor return on financial investment — they cost more to implement than they provided in savings to rate payers. Second, some programs benefited narrow groups while loading the cost on rate payers generally. It’s not clear yet how the three SCC judges will reconcile their previous logic with the General Assembly’s declaration that energy efficiency and conservation are in the public interest.

A third question, which I have yet to see raised, is whether electric utilities are the logical entities to implement energy-efficiency measures. The free-market environmentalist Rocky Mountain Institute (RMI) has just released an analysis concluding that zero-energy homes — homes that literally produce as much energy as they consume over the course of a year — are reaching cost parity with normal homes in many parts of the country.

While there is no one-size-fits-all solution, RMI says, “In all climates, the cost optimal solution … included 100-percent LED lighting, low-flow water fixtures, and ENERGY STAR appliances, all of which reduce load at a very minimal cost premium. In addition, heat pumps were used for both space heating and water heating.”

This raises a fundamental question: Should Virginia spend arbitrarily determined amounts of money on utility investments or should it rely upon developers and home builders driven by market forces? Or a third option: Should Dominion and Appalachian Power tailor programs to incentivize home builders to install energy-efficiency measures, making the construction of energy-efficient new homes, which, if RMI is to be believed, a no-brainer?

New Virginia Energy Plan Ramps Up Commitment to Carbon-Free Future

The Northam administration’s 2018 Virginia Energy Plan is the environmental movement’s dream come true. The administration is going “all in” for solar power, offshore wind energy, distributed energy resources, energy efficiency, and electric vehicles. Under the plan, Virginia won’t be as aggressive as California, which has set a goal of a 100% carbon-free electric grid by 2045, but it would follow the same trajectory.

The Virginia Energy Plan embraces the same carbon-reduction goals incorporated into the 2018 Grid Transformation and Security Act (SB 966) but treats them as a starting point. The plan calls for an overhaul of the regulatory process and state priorities to advance goals in five broad areas:

  • Solar and onshore wind. Of the 5,000 MW of solar and wind resources deemed in the public interest under Senate Bill 966, 3,000 MW should come from solar and onshore wind. Specific proposals include expanding corporate clean energy offerings; enhancing collaboration on the siting of large solar and wind facilities; and expanding the net metering program, the power purchase agreement program, and the community solar program. The Energy Plan recommends increasing the Commonwealth’s renewable energy procurement target to 16% by 2022.
  • Offshore wind. The Energy Plan calls for building the 12 MW offshore wind demonstration project — two test turbines to show how well novel designs can withstand hurricane conditions — and then to develop 2,000 MW of offshore wind potential by 2028.
  • Energy efficiency. The plan calls for increasing utility-funded energy-efficiency programs to $100 million per year for Dominion Energy and $15 million per hear for Appalachian Power Co., as well as expanding state-sponsored energy-efficiency programs. The Commonwealth should set a goal of reducing retail electricity consumption by 10% by 2022 (using 2006 as a baseline) and consumption in state buildings by 20%.
  • Energy storage. Recognizing that intermittent wind and solar energy sources pose threats to the stability and reliability of the electric grid, the Energy Plan discusses pumped hydroelectric storage, lithium-ion batteries, and solid-state batteries. However, the plan makes no specific recommendations on which technologies or approaches should be adopted.
  • Electric vehicles. The Energy Plan calls for promoting the deployment of electric vehicles and using their battery storage capabilities to shift electric load to times that better align with solar and wind output. The state should adopt the Advanced Clean Cars program, develop a comprehensive electric-vehicle transportation plan, and set targets for building an electric-vehicle charging infrastructure.

The Energy Plan provides no estimate of what the sum total of these initiatives would cost nor who would pay for them. While the plan does address the challenge of matching solar and wind output with daily electric load, it does not explore how the system would hold up under rare-but-recurring extreme weather events such as hurricanes or the Polar Vortex.  The document can best be seen as a roadmap for where the Northam administration and its allies in the environmental movement would like to take the state.

This Certainly Demonstrates Something (Don’t Ask)

Under normal circumstances, building two wind turbines 27 miles off the coast of Virginia at a cost of $300 million would  be neither reasonable nor prudent.  They may produce the most expensive 12 megawatts of electricity in Virginia history. The only rational reason to go forward is to test technology which is becoming more common around the world but is still untested in hurricane territory.

On that basis the proposed Dominion Energy Virginia project now pending approval at the State Corporation Commission received a lukewarm blessing from the SCC’s staff, mainly because Dominion continues to talk about quickly following up with a far more extensive turbine project in the same location.  Before building the big project, perhaps 2,000 MW, some testing is a good idea.

But the staff commentary also noted it would make sense to give the test project (known as Coastal Virginia Offshore Wind or CVOW) time to prove itself before building a multi-billion-dollar expansion.

“Should the Company decide to move forward with a larger scale offshore wind project before the CVOW Project is in service and the demonstration is complete, or before the CVOW Project has demonstrated that it can survive a hurricane type storm, the Commission may want to consider requiring the risk of such a decision be borne or shared by shareholders,” wrote Gregory L. Abbott of the Division of Public Utility Regulation in pre-filed testimony.  He also suggested the SCC put a hard cap on the cost.

He added: “…it appears unlikely that the CVOW Project will demonstrate that large-scale offshore wind will be economic compared to either the least-cost traditional generation option or to the least-cost carbon-free renewable generation option.”

The staff filed several sets of testimony, parts which are kept confidential at the request of Dominion.  There will be two hearings, the first and perhaps most important next week dealing with questions about the SCC’s authority when the General Assembly has deemed that a project is “in the public interest” based on lobbyist assurances.

The General Assembly used that phrase in connection with CVOW.  Does that reduce or even eliminate the Commission’s authority to reject things based on outrageous cost or imprudence?  Of all the many things to win that valued legislative endorsement, this is by far the worst use of your money.

It is your money.  In effect, Dominion will pay for the project with those excess profits it is not using to pay customer refunds.  There will not be a separate (and easy to track) rate adjustment clause.  When the accounting for this project finally comes up for SCC review in 2021, assuming the General Assembly doesn’t change the rules for the umpteenth time, whatever Dominion has spent on this will reduce the amount of potential profit for refund.

SCC staff witness Carol Myers dives into that, in a document replete with redaction.  The company hotly disputes her estimate of the real cost of the project at almost $700 million over 25 years, but it will have the incentive to prove a high cost in the next review because that prevents refunds or (the thought causes them to shiver) rate reductions.

Continue reading

A Thumb On The Scale for ACP?

Weather normalized summer peaks for Dominion compared to earlier and current projections by the company. Source: Southern Environmental Law Center

A witness to whom Dominion Energy Virginia had vehemently objected, Gregory Lander of a company called Skipping Stone, had his time on the stand anyway at the State Corporation Commission Tuesday. His testimony might still be stricken, but the two commissioners and everybody else in the room heard it and then a lengthy cross-examination underlined it.

If he is correct the entire integrated resource plan filed by the giant utility, a process ordered by the General Assembly to plan the utility’s future, had a fundamental flaw. One single input in a model had a ripple effect in its choices for future generation, some of which it hopes to support with the controversial Atlantic Coast Pipeline.

The three-day hearing on the integrated resource plan, which will stand for two years, opened with SCC Chairman Mark Christie deferring a ruling on the motion to exclude some of Lander’s testimony. He said the decision on the ruling would be announced with the full decision.

Christie also repeated what has become a standard SCC disclaimer on IRP cases. It is just a planning document, any future plants will need a full commission review, “and just because you admit evidence does not mean it’s a finding of fact.”  He also added that before the ratepayers are billed for gas from the ACP the cost will need to be judged reasonable and prudent in its own case.

A little background: Dominion uses a modeling system called Plexos that uses information such as the expected new demand, generating units which might need to retire, various types of generation and their costs and environmental expectations to design its future system. As engineers say, and it was said again this week at the SCC, all models are wrong but some of them are useful.

The five future generation configurations included in the integrated resource plan used the model with different inputs, many of the variations dealing with future carbon regulation. According to Lander, and this was apparently confirmed in interrogatories, the cost of transporting natural gas through the ACP to Dominion generators was simply left out. SCC staff witnesses pointed to the same omission.

The commodity cost for gas was plugged in, but the cost of getting that gas to the plant was not. This omission made the choice of natural gas more cost-competitive and perhaps skewed the model in favor of gas. It put a huge thumb on the scale.

It is the transportation charge for the gas which will include the cost recovery, plus profit, for the construction of the project. Lander claims that will add up to $3 billion to ratepayer costs over 20 years. Opponents claim gas from the ACP will be more expensive than from existing pipelines. Lander was an expert witness hired by Appalachian Voices, an anti-pipeline group.

The IRP cannot be found reasonable and prudent, Lander told the judges, if an important cost like fuel logistics is set at zero. “The model is making choices that are not reflective of total costs.” He said that instead of building new gas combustion turbine units, included in the plan to complement all the intermittent solar also planned, the company should just keep some of the other fossil fuel units it plans to retire early and run them less often.

Continue reading

Dominion Objects to Testimony on Pipeline Cost

One of the first decisions the State Corporation Commission may need to make in Monday’s hearing on the Dominion Energy Integrated Resource Plan (IRP) is whether to allow and consider testimony about the cost of the Atlantic Coast Pipeline.

Dominion filed a September 7 motion asking that testimony from a witness brought by Appalachian Voices “be stricken as irrelevant and improper,” which the environmental group answered with its own brief filed Friday.  Dominion argues the cost of the pipeline is not part of the IRP and is not properly before the commission in this case.  It will seek to recover the pipeline capital costs when gas from the pipeline is subject to a future fuel cost review.

Gregory Lander of energy consulting firm Skipping Stone states in his disputed testimony that the costs are already built in.  “The Company’s 2018 IRP embeds the costs of the Atlantic Coast Pipeline into each of the generation scenarios it presents…. (but) has not properly costed-out the all-in cost of increasing, beyond its current pipeline capacity portfolio, the costs associated with the level of pipeline capacity it intends to obtain on the Atlantic Coast Pipeline.”

He claims that acceptance of the IRP by the Commission in effect accepts that up to $3 billion of the cost of building and operating it will be passed on to ratepayers over 20 years.  Those are in addition to the cost of the gas.  Opponents of the pipeline argue it is not necessary to bring natural gas via the ACP to Dominion’s generators, and if it does so it will be supplanting lower-cost alternatives.

“In reality, the Company’s goal is not to avoid scrutiny of the ACP costs in this proceeding, the Company’s goal is to avoid scrutiny of the ACP costs in every proceeding,” states the brief in support of retaining Lander’s testimony.  It noted a similar effort to keep the data out was made successfully in 2017’s IRP case and during the certificate of need case for the new natural gas generation plant in Greensville County.

This is just one of the disputes expected when the SCC takes live testimony for two days on the plan, which outlines several scenarios for meeting future demand in Dominion’s territory while meeting current and future environmental rules. The amount of demand growth over the period is itself the main point of contention, with opponents claiming the utility has inflated its needs to justify excessive new plant construction.

In rebuttal testimony Dominion pushed back on claims by the SCC staff and others that it won’t need additional generation. It says the others ignored recent winter peak demands and claimed that an economic slow period responsible for flat demand is coming to an end.  “The lack of economic growth in Virginia has been a key driver to the forecast being higher than what has actually occurred” wrote Dominion’s director of energy market analysis Robert Thomas.

One of the reasons cited for expected growth is the explosion of data centers in Virginia, but representatives of that industry filed their own written comments disputing they will cause higher demand.  The letter was signed by eBay and Adobe among others.

Continue reading

BVG Makes Case for Virginia as Offshore Wind Supply-Chain Hub

Manufacturing job-creation potential for the offshore wind industry. Source: BVG.

Virginia is very well positioned to establish a supply-chain hub for an East Coast wind-power industry, says a report written by offshore-wind consulting firm BVG Associates and underwritten by the Virginia chapter of the Sierra Club.

Although Virginia will not participate in the “first wave” of  East Coast offshore wind projects, which is ramping up now in northern coastal states, Virginia-based businesses could supply key components to those pioneering efforts if the Commonwealth acts quickly, concludes the newly published report, “Offshore Wind in Virginia: a Vision.”

The report lays out the following scenario for wind farm-driven economic development:

Virginia will derive immediate economic benefits while maturing its offshore wind supply chain, ensure development of its own 2 GW [gigawatt] offshore wind by 2028, and provide the tipping point for a second wave of lower-cost projects off Dominion Energy’s service territories, notably the Kitty Hawk lease area in North Carolina.

The study should be read with the understanding that Sierra Club-Virginia is promoting Virginia offshore wind generation to advance its long-term goal of eliminating fossil fuels and nuclear power from Virginia’s energy mix. Even with that caveat in mind, the study provides the most detailed analysis yet published of how Virginia can leverage offshore wind into a major economic-development boon for the Hampton Roads maritime sector. The Northam administration has hired a BVG associate to help the state fashion a strategy to build an offshore wind supply chain.

According to the report, Virginia has five big competitive advantages:

  • An industrial coastal infrastructure, with large areas for laydown and storage, quayside length for load-out, and direct access to the open ocean with unlimited vertical clearance.
  • A large workforce with competitive pay scales and experience in shipbuilding, ship repair, ports, logistics, and vessel operation.
  • Highway, rail, and inland waterway connections linking Virginia’s ports to industrial centers throughout the Southeast, Mid-Atlantic, and Midwest.
  • Eastern population centers with high and growing electricity demand, particularly for the Internet economy. Northern Virginia has a large and growing data-center corridor, and two new data centers are being built in Virginia Beach.
  • High-voltage interconnection capability in Virginia Beach sufficient to handle the anticipated commercial wind-lease area after “moderate investment.”

The first two advantages make Hampton Roads an attractive location for the fabrication and assembly of jacket foundations and offshore substation platforms. Two sites in the region could be made ready for a steel fabricator within 20 to 29 months at a cost of $5 million to $15 million. Jacket and substation production could create more than 2,000 new direct and indirect jobs.

The first phase of offshore wind production will be expensive. Wind supply chains in Europe like to see an annual market of at least 1 gigawatt, the equivalent of 80 to 125 turbine nacelles, turbine towers, blades, or foundations. A factory owner would look to produce 200 kilometers of cable per year, a volume needed to apply lean manufacturing strategies. Lacking U.S.-based investment, first movers in offshore wind would have to pay premium prices. Another complication is the Jones Act, which prohibits European-built and based vessels from transporting components between U.S. harbors. Offshore wind-service companies cannot yet justify building state-of-the-art jack-up vessels in the U.S. in compliance with the Jones Act.

First-mover states — Massachusetts, Rhode Island, Connecticut, New York, New Jersey, and Maryland — have committed to build more than 3 gigawatts of offshore capacity. Virginia has committed to build 5 gigawatts of renewable energy, including a substantial component from wind, by 2028. Dominion Energy has proposed to build two turbines with experimental designs to ensure that a larger wind farm could stand up to hurricane conditions frequently experienced in the Mid-Atlantic.

Writes BVG:

By the middle of the next decade, Virginia could be a leading U.S. market for offshore wind, driven by the ability to benefit from the lessons learned from northeast coast states and the maturing U.S. supply chain, complemented by Virginia’s strong infrastructure, location benefits, and deployment of offshore wind at scale.

Suppliers to the wind industry, such as turbine, foundation and cable manufacturers, like to see a regular run-rate for installed capacity. This allows easier investment planning and more efficient facilities. Manufacturers also need projects of a certain size to achieve economies of scale. … The Virginia market in our scenario is … not big enough by itself to attract investment, so the Atlantic Coast market as a whole is crucial. In our scenario, Virginia provides the tipping point, creating the demand needed to support an investment decision.

Some infrastructure investment in Hampton Roads may be necessary. Given the inevitable time lags in gaining regulatory approvals, BVG says, Virginia needs to act quickly. Portsmouth Marine Terminal would need between $11 million and $25 million to upgrade the port for major offshore use, with “additional costs in the facilities themselves.”

The report provides no estimate of how much it would cost to upgrade Virginia’s electric grid to accommodate a massive supply of offshore wind, nor, beyond general statements that wind power is complementary with solar power, does it discuss the impact of intermittent wind power on reliability. Fossil fuel advocates argue that wind and solar provide no surge capacity in extreme, polar vortex-like weather events.

The BVG study make no policy recommendations. It cedes that task to the Department of Mines, Minerals and Energy, which is developing a strategic plant to identify supply-chain businesses and how to market Virginia as a hub for the industry.

Bacon Bits: In with the New, Out with the Old

In with the new…

Data Center Alley too hot to handle. The Metropolitan Washington Airports Authority (MWAA) has sold 424 acres west of Dulles International Airport to data-center developer Digital Realty Trust for an eye-popping $236.5 million — $558,000 per acre. MWAA will place $207 million in a segregated account used to reduce costs that airlines pay to do business at the airport. The transaction expands the large and growing data-center presence of Digital Realty in Loudoun County, reports the Washington Business Journal.

Virginia’s next big solar project? Solar developer Community Energy has applied to build 125-megawatts in solar capacity in Augusta County, reports PV magazine. To offset concerns about neighborhood impact, Community Energy plans to surround the facility with a buffer of vegetation and put into place measures to diminish the limited audio output. Instead of purchasing the land, the power company is leasing it from landowners, providing farmers an ongoing revenue stream rather than a lump-sum payment.

Out with the old..

Gutted newsrooms. Ned Oliver with the Virginia Mercury has quantified the shrinkage of news staff at Virginia’s largest daily newspapers in recent years. After quietly laying off another eight newspaper employees at the beginning of the month, the Richmond Times-Dispatch newsroom has gone from 42 news and sports reporters in 2010 to 26 today, from nine to six photographers, and from 20 to 13 editors. The Virginian-Pilot has dropped from 67 reporters to 33, 35 editors from to 22, and eight photographers to five. Newsroom staff at the Roanoke Times has eroded by 35% to 25 reporters, 11 editors, and three photographers.

“Meanwhile,” writes Oliver, “there is still no clear model for metro and community newspapers to make up for the loss of all that ad money to digital giants like Google and Facebook.”

Tarheel coal ash overflow. In an event sure to impact the debate over coal ash in Virginia, heavy rains from Hurricane Florence eroded a coal ash facility at a Duke Energy power plant near Wilmington, N.C. The utility is investigating the possible release of about 2,000 cubic yards of the material — enough to fill two-thirds of an Olympic-size swimming pool, according to the Herald-Sun. It was not clear whether any of the ash, which contains traces of heavy metals, reached public waterways.

The release reinforces the necessity of removing coal ash from unlined, uncapped containment ponds where electric utilities have been restoring the coal-combustion residue for decades. Environmental Protection Agency regulations were designed to prevent incidents like this by consolidating and capping coal ash ponds. While environmentalists, regulators and utilities haggle over whether it’s better to store the material in lined landfills, a process that could take two to three decades, existing containment ponds remain vulnerable to extreme weather events like Florence.

Florence Could Provide First Test of Dominion’s Undergrounding Program

Image source: Dominion. Click for larger image.

Hurricane Florence may not be the cataclysm for Virginia that everyone anticipated two or three days ago. Forecasts suggest that the hurricane will veer west, not north, when it hits the Carolina coast. But other hurricanes are spawning in the Atlantic Ocean, Virginia is still a potential target, and it is still worth exploring the implications of Dominion Energy’s grid transformation program for disaster preparedness.

A big part of Dominion’s proposed multibillion-dollar grid modernization program involves hardening infrastructure and burying vulnerable distribution lines to reduce the frequency and length of electricity outages in the event of a natural disaster.  The utility already has buried hundreds of the most outage-prone tap lines under a pilot program launched four years ago, and it proposes under the Grid Modernization and Security Act to bury thousands more, funded by profits over and above the level to which it normally would be entitled, in an expansion of the initiative.

No investments have been made under the auspices of legislation passed earlier this year. Dominion has submitted its modernization plan to the State Corporation Commission (SCC) for review, and it doesn’t expect a final order until January.

But Hurricane Florence could provide a test case for the value of the strategic undergrounding program. Over the past four years, Dominion has buried 968 miles of electric line. While undergrounding obviously increases reliability for the customers directly affected, there is a system-wide benefit, explains spokesman Rayhan Daudani. “The system wide benefit is seen when we can reallocate crews more quickly and respond to outages more quickly than we would have been able to before. Fewer down wires means fewer repair locations, which means our crews can respond to the outages remaining, restoring service more quickly for all customers.”

According to data filed with the SCC, distribution lines incorporated into the strategic undergrounding program experienced 29 outage events in 2017. That compares to 1,683 events that were predicted to have occurred in the absence of the burial program. The average outage duration for customers served was 1.05 minutes compared to a predicted 386 minutes.

The Dominion-supplied graphic above shows how the undergrounding program fits into larger disaster recovery efforts. The red bars schematically show the length of restoration time before the Strategic Undergrounding Program (SUP) and the green bars the length of time after. How accurate a reflection of reality this schematic is, I do not know, but it conveys what Dominion is talking about.

On a side note… For rate payers, there may be a silver lining to those hurricane storm clouds. In the past, the repair of storm damages was incorporated into base rates base and passed along to ratepayers. Under the Grid Modernization Act, Dominion’s base rates are frozen. If Hurricane Florence causes millions of dollars worth of damage, the utility will absorb the cost of repairs and restoration.