Strife in the Coalfields

Dominion wants to build a state-of-the-art “clean coal” power plant in Wise County to meet the growing demand for electricity in Virginia. Not surprisingly, opposition has surfaced. I described the proposed power plant back in July as an inter-regional transfer of wealth. That criticism didn’t gain much traction, but opposition to the project on environmental grounds has.

In “Strife in the Coalfields,” Peter Galuszka delves into the environmental pros and cons of the $1.6 billion facility, which would generate enough electricity to power 146,000 homes — mostly in the eastern part of the state.

While Dominion proposes loading up the power plant with virtually every new clean-coal technology known to man — which prompted my questions of whether the plant could possibly be a cost-effective means of generating power — it’s still not clean enough for the greenies. As Galuszka summarizes their fears, the plant “would generate huge volumes of greenhouses gases, inflict pollution that causes potentially fatal respiratory disease, employ heavy coal trucks that will crumble highways, and encourage mountaintop removal, a method of surface mining on a vast scale that Virginia has so far largely escaped.”

As readers of this blog know, I’m no apologist for Dominion. However, it strikes me that several of the environmental criticisms of this project are potentially without merit. Let’s take them one by one.

(1) Mountaintop removal. Mountaintop removal is indeed a highly destructive mining method that literally scrapes off entire mountaintops to reach coal seams. But Dominion hasn’t sourced its coal yet. If the power plant is approved, the power company likely will sign long-term contracts with one or two suppliers for the bulk of its coal. Presumably, the SCC could require, as a condition of approval, that none of the coal originate from operations using the mountaintop removal mining method.

(2) Coal trucks. Heavy-loaded coal trucks do pound local roads, creating a massive maintenance headache. But coal trucks also pay a significant tax per ton to help pay for the maintenance. If that fee is insufficient, the solution isn’t rejecting the power plant but increasing the tonnage fee.

(3) Respiratory disease. Critics cite American Electric Power Co.’s nearby Carbo power plant as an example of the impact the Dominion facility would have on local air quality. But Carbo is 50 years old; Dominion would use much more advanced cleaning technology. I don’t profess to know whether the Dominion facility would worsen local air quality or not, but I’m quite certain the impact will be minimal compared to AEP’s Carbo facility. If clean-air standards are not met, Dominion will not obtain — nor should it deserve — a permit from the State Air Pollution Control Board.

(4) Conservation and renewable energy. Instead of building a coal-fired power plant that emits C02 and contributes to global warming, environmentalists argue, Dominion should invest in conservation and renewable energy. I can’t think of any blog or print publication in Virginia that has espoused the virtues of conservation and renewable as aggressively as Bacon’s Rebellion. But I’m realistic enough to know that conservation/renewable can’t meet all of Virginia’s energy needs at an acceptable cost over the next decade or two. The conservation/renewable technologies and business models simply aren’t mature enough. We have no choice but to supplement conservation and renewables with some old-fashioned electric power capacity.

Meanwhile, opponents overlook a major environmental positive. The Dominion plant would use a technology that could burn waste coal found in the “gob piles” that litter the coalfield counties. These piles of coal dust and pulverized rock, which is refuse of mining that often took place decades ago, leach acidic water into local creeks and rivers. By recycling gob piles, the new plant would help address one of the region’s worst environmental problems.

Here’s my beef with the environmentalists. They don’t like coal. They oppose uranium mining in Southside. They want to block natural gas production off the Virginia coast. But what happens when entrepreneurs tried to build a wind farm in Highland County — a truly “green” energy source? Environmentalists tried to thwart it on the grounds that it would kill too many birds and bats! Some environmentalists seem to be against everything. (I recognize that the “environmental” movement is highly diverse, and that not all environmentalists oppose all new energy sources. My criticism applies to the extremists who have nothing constructive to offer.)

I’m not yet persuaded that Dominion’s Wise County power plant is good for Virginia. By the time all legitimate environmental issues are addressed, it may be so darned expensive that it can’t be justified. But I’m not terribly impressed with the environmentalists’ case against the plant to date.

(Photo credit of Carbo power plant: Camille Galuszka.)

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62 responses to “Strife in the Coalfields”


    my challenge back to Jim and others is, what are you doing to stop the new coal plant?

    Virginia ranks at the bottom for states in utility investments in energy efficiency. This means we have affordable energy-efficiency resources right now in our existing infrastructure. With these energy resources, it is likely that this coal plant would never be needed. ? There are Cheaper Options than Another Coal-Fired Power Plant.. It would be far cheaper and more cost-effective for Virginia ratepayers if Dominion invested in energy efficiency and conservation instead of building this new coal-fired power plant. Electric energy efficiency programs typically cost 2 to 5 times less than building new coal plants. ? Dominion has no plan to control global warming pollution from its proposed coal plant. In its advertising, Dominion calls this plant ?carbon capture compatible.? Yet in its application to the SCC, Dominion admits, ?Carbon capture technology is not commercially viable …? Dominion?s only ?plan? is to set aside a small! plot of land, so that if someone invents the technology to capture carbon, Dominion might build it on this plot ? but only if the SCC approves yet another rate hike. This is misleading to the SCC, and to the public. ? Dominion Power has failed to consider the costs of future greenhouse gas regulation. Congress will soon enact some form of climate change legislation, meaning that the company will have to account for the CO2 emissions from the Wise County coal plant. If built, this plant would annually spew 5.4 million tons of CO2 into the air. The cost to control these emissions may exceed $100 million each year. Attorney General Cuomo of New York has launched an investigation into several utilities, including Dominion, over the failure to disclose investor risks associated with these anticipated costs. In a subpoena to Dominion, Cuomo noted his concern that ?Dominion has not adequately disclosed? to shareholders the ?increased financial, regulatory, and litigation risks? associa! ted with building a new coal-fired power plant. ? Dominion has low-balled the cost of building the Wise County Coal Plant. Around the world, power plant construction costs have soared in recent years. A proposed coal plant Florida saw its estimated costs rise 25 percent, or $400 million, in just 17 months. The per-unit cost of a North Carolina coal expansion proposed by Duke Energy has increased 80%. The costs for a South Dakota coal project have increased by 60 percent since the project was first announced. In fact, Dominion first projected the cost of the Wise County coal plant at $800 million. But that figure HAS MORE THAN DOUBLED, and now stands at $1.62 billion. The final price tag for Virginia ratepayers will likely be far higher. If we are serious about building a wise energy future, then we need to prioritize energy efficiency, conservation, and clean, renewable energy over dirty and expensive coal. I live near Dominion Power’s corporate headquarters as well as train tracks with many, many coal trains. I see the problems and wast! e every day.

  2. Anonymous Avatar

    Jim Bacon’s rather thoughtless and dismissive synopsis of my article bears comment.

    (1) Dominion does not propose loading up the plant with every new clean-coal technology known to man. That’s an an idiotic statement. Dominion is proposing using a technology that, as I state in the story, has been around for about 30 years.

    (2) Dominion’s failure to state where it will get its coal and whether it will contribute to mountaintop removal is a ruse to avoid the issue before the SCC. Unlike Bacon, I have personally seen what mountaintop removal is and regard it as horrible. I wrote about it for Business Week ten years ago from southern West Virginia.

    (3) Coal trucks are always an issue in the mountains whether Bacon wants to recognize it or not. Nearly 600 heavy trucks a day
    is a lot and I wonder what Bacon might say if suddenly, 600 coal trucks showed up every day on Parham Road next to his house. When I returned from the coalfields, my first order of business was washing my car of coal dust.

    (3) Bacon misses the point by noting that Carbo is 50 years old. It has caused a lot of health strife for those years and is STILL not cleaned up. It is the No. 2 air polluter. The Dominion plant would be the next No. 8 or 9 air polluter. Imagine having these two plants in the same geographic area. Bad air can get trapped in the steep mountains and their hollows. I know this because I have lived in coal country. Bacon never has.

    (4) Conservation and renewable energy. My, Bacon is certainly quick to put the burden on the people of Wise and Russell Counties. Maybe he should go out there and try explaining to them why the plants are necessary just there and not in Henrico (or along Parham Road). I’m sure he;d get far.

    Lastly, I do not appreciate Bacon’s introduction to my piece. He should have written a straight intro, not a dismissive editorial. He can state his views on the blog. My purpose was to go out there on my own time and dime and write a fair, balanced and analytical piece. Period.

    Peter Galuszka

  3. Larry Gross Avatar
    Larry Gross

    well you could be one thing.

    If this plant were proposed to be in Henrico County – there’d probably be significant opposition beyond your “standard” environmentalists.

    If this plant were proposed to be just about anywhere where the increased electrical demand is – there probably would be opposition.

    so.. yes… perhaps there can be some frustration with the environmental community with respect to what kind of power besides green power should be chosen – but what about the folks who need the power but prefer it to be tucked away out of mind and sight – including the power lines?

  4. Jim Bacon Avatar
    Jim Bacon

    Peter, I apologize for creating the impression that I was dismissive in any way of your reporting on the Dominion power plant. That certainly was not my intention. Indeed, I thought the column was well researched and balanced. To my mind, you presented both sides of the issue fairly. Although it was clear that you had sympathies, they were for the people of Wise County, not Dominion, nor, in my reading, the environmentalists. It was with that understanding that I wrote my introduction. I directed my critique toward the protestors, not toward you, much less the people of SW Virginia.

    Rather than address all the specifics in your comment, I would add only that I do have some familiarity with the coalfields of Virginia, having covered the industry for four years as a reporter for the Roanoke Times and having worked as a communications manager for AMVEST Corporation, which owned a coal operation in Wise County. That was a long time ago, I readily concede, and I don’t profess to be an expert on current conditions, but I don’t speak from total ignorance.

  5. Jim Bacon Avatar
    Jim Bacon

    Scott, I totally agree that Dominion needs to invest more in conservation and energy efficiency. I have used this blog as a platform for showing how much potential exists to reduce electricity consumption, and to explore changes in the regulatory structure that would give Dominion (and other power companies) more incentive to promote conservation and energy efficiency.

    However, I think it would be naive to assume that conservation can do all the heavy lifting by itself. Dominion cannot be blamed for making conservative assumptions in that regard. If conservation efforts do fall short, and if blackouts or brownouts occur, Dominion will be the first to be blamed. They have a moral responsibility and, I believe, a statutory one, to ensure that Virginians have sufficient electric power.

    Dominion also has deep instituational memory of the 1970s when it (as Vepco) when out-of-control increases in electric rates made it the most reviled company in Virginia.

    My point is simply this: The power has to come from somewhere. Conservation can help a lot. And we need to ramp up on renewables. The 12 percent voluntary goal for renewables called for under current state law is probably a low-ball estimate of what is possible. But I am dubious that Virginia, with its growing population and economy, can achieve zero growth in electricity consumption except at tremendous cost — a cost that most Virginians probably will be unwilling to bear.

  6. Jim Bacon Avatar
    Jim Bacon

    Larry, You’re right, if the power plant were proposed in Henrico County, the locals here would be up in arms — just like they would be in Northern Virginia, or anywhere else for that matter. People don’t like to live near big power plants.

    However, I would hasten to add that many people in SW Virginia — the politicians, at least — would very much like to see the power plant built in Wise County. They regard it as a major source of tax revenue and, to a lesser extent, jobs. No doubt their support for the power plant also can be traced, to some degree, to big donations from Dominion. But, then, much of the opposition to the power plant originates from outside Wise County. So, neither side is totally clean in this debate. In that regard, I am inclined to agree with Peter: The people of SW Virginia are pawns of the energy producers, environmentalists and others from outside the region who seek to advance their own agendas.

  7. Anonymous Avatar

    That plant is being proposed simply because leaders and legislators in SW Virginia wanted it, mainly to support the coal industry generally. (The jobs at the power plant itself are ancillary – this is seen as promoting Virginia coal). There are many things you might call Sen. William Wampler, but “pawn” is not one of them. The plant was a bargaining chip offered by Dominion and APCO to secure the local delegation’s support in the manuevering over regulation-deregulation of the entire electric power business in Virginia. That is why construction of the plant is dictated by the Code of Virginia, not any economic analysis. Whether it is best choice for the ratepayers remains an open question that simply is not going to be asked — the law prohibits asking. The plant shall be built.

    That said, the technology itself is interesting and it is understandable that the coal industry wants a working demonstration of it — and Virginia does need additional generation. The nuke plants will be far more efficient from an energy and economic standpoint.

  8. Matt W. Avatar

    Peter’s responses to this apparently well-intentioned, but unresearched post is right on the mark.

    Far from using all state-of-the-art technology, Dominion’s plant appears to be the dirtiest new plant proposed for the region – at least compared to those proposed in nearby states such as NC, SC and WV.

    According to a recent mapping project conducted by an independent professional mapping firm for Appalachian Voices, at least 29 mountain peaks have been destroyed in Virginia. Just because Virginia’s DMME chose to essentially define mountaintop removal out of existence doesn’t mean it doesn’t occur. Whatever you do with the resulting mine waste, when you blast away an entire mountaintop for coal, fill in nearby valleys, and change the contours of the land drastically, it fits comfortably within any reasonable definition of mountaintop removal – certainly well within OSM’s 1985 definition, which is the one used by Appalachian Voices.

    Most egregiously, simply saying that conservation and efficiency measures can’t meet Virginia’s electricity demand doesn’t make it true. In the summer of 2001 when California faced an “energy crisis” (which we’ve since learned was almost entirely brought about by Enron’s illegal and immoral practices), the state enacted measures that – in one summer – reduced demand by 5,500 Megawatts. That’s 10-times what the Wise County plant would generate – and the projected rolling blackouts were avoided.

    If California could do this in one summer, surely Virginia could eliminate the need for 1/10th that amount in the 4 years it would take to build the plant. Even minor measures would go a long way but, as of 2006 (according to a 2007 ACEEE report), Virginia ranked last in the country in spending on C&E measures – actually, it was tied for last along with Kansas and Wyoming. How much did these states spend? $0.00.

    Isn’t it a little pessimistic to write off the possibility of C&E offsetting demand before the state has even spent a single dollar on it?

    As for alternatives, most people still haven’t heard that California-based Nanosolar began shipping the first of a new generation of thin-film solar panels on December 18th, 2007, which (depending on who installs them and the details of the installation) can produce electricity at a lower per-watt cost than coal – not including the cost of carbon regulation that almost everyone agrees will be passed by Congress in the next few years. While it would take a long time for solar to replace coal, strategic placement of solar installation to offset peak summer demand, combined with C&E measures could easily eliminate the need for new coal plants for the next few decades. Moreover, in the most recent Scientific American, a team of scientists demonstrated how a combination of solar, high-voltage DC transmission lines, and energy storage technologies could affordably generate 2/3 of America’s energy demand by 2050.

    I appreciate that you’re trying to take a reasonable position on this, but your post is awfully naive. Dominion wants to build a new coal plant because it would be a cash cow for 30-50 years into the future – especially if they can get it grandfathered out of impending carbon regulations. I urge you not to take their misleading and overly-pessimistic projections at face value, and to do a little more research on the latest news about the potential of C&E and renewable energy.

  9. Larry Gross Avatar
    Larry Gross

    I don’t think folks should try to stop the coal plant unless they are also willing to offer an alternate path to the future…

    But in this case, the time will come, perhaps in our lifetimes, when Dominion will answer the “why can’t we use available and PROVEN modern green technology – like the Future Gen Zero Emission Coal Plant in Ohio with this..answer:

    “sure we can go to modern green technologies.. but you’re going to have to pay us our “stranded costs” for the old technology that Virginia mandated us to build in 2007.”

    The GA has given away the store to Dominion…. They can choose whatever technology they wish, no matter how dirty or obsolete much less not forward looking.. and they are guaranteed to recoup their costs no matter what.

    Virginia ratepayers -otherwise more correctly called CHUMPS are being committed to pay for NOT adopting modern technologies.. courtesy of some really shortsighted folks in the GA.

    This is more of the same .. special interests from the Corporate World with the acquiescence of our own elected, lining their own pockets and showing a total irresponsibility for the public interest.

    That coal plant will end up like the Mirant Plant in NoVa…

    we yammer on about the “abuser” fees while this kind of ratepayer/taxpayer abuse is not even on our radar screens.

  10. Anonymous Avatar

    Dear Matt W,
    I do appreciate your comments. As for the extent of mountaintop removal in Virginia, all I know is what Appalachian Voices says and what the state regulators say. It may very well be that nearly 30 mountaintops have been removed. I had the time and money to spend two days in the coalfields. I would love to report more there. You might well be right. If I were you, however, I would try to document my findings a bit better than what I saw at your presentation in St. Paul.
    As far as a cash cow, well, that was what I was alluding to in my AEP using cheap mine-mouth plants to pump out cheap electricity. I know the example I had reported it for Business Week albeit some time ago. That was at the time of de-reg (in the Clinton Administration no less, so no need to blame the GOP).
    Given the closeness of the coal supplies and the supposed political weakness of the folks in the Va. coalfields, it is not surprising that a utilty based a six-hour drive away would try to take advantage.

    Peter Galuszka

  11. Matt W. Avatar


    I, too, appreciate your comments and I apologize that the presentation isn’t as well sourced as it should have been – I gather that Keith Strange at the Coalfield Progress had the same criticism.

    I put most of that presentation together a month or two ago with the assumption that I would be presenting it (and identify and explain sources verbally), but there was quite a demand for the resource so I made a bunch of copies and distributed it to a number of folks. Clearly I should have put the sources in the slides, but, well, you know how it goes… Grassroots is a sloppy business (one of the difficult things about transitioning from scientist to activist).

    Anyway, if you or anyone else are interested in the maps or sources for other info on socio-economics, the rapidly dwindling coal supply in VA and all that, I’ll certainly be happy to send it your way. Give me a shout at if you need anything specific.

    Again, thanks for your original post and for your comments – I think your analysis on the financial underpinnings of the decision to build the plant there is also right on the mark (though, as someone pointed out, politics – especially Senator Wampler – is the real 900 pound gorilla regarding incentives for building the plant in SW – 125 miles outside of Dominion’s service area).

  12. Anonymous Avatar

    There is nothing preventing anyone who wants solar from going out and buying it.

    If solar really is about to be cheaper, then there is nothing to prevent them from acting on their beliefs. If enough people act, then they will be correct.

    California reduced a lot of megawatts, but California is a much bigger place than Virginia. And California didn’t reduce that energy use at no cost. A similar reduction here would cost Virginia a lot more.

    We don’t want it here, we don’t want it there, and we don’t want to freeze in the dark. Sooner or later, someone is going to have to cut a deal.

    The best way to promote green energy is to build some more dirty energy, and the best way to get dirty energy built is to argue over it until the lights go out.

  13. Groveton Avatar


    Your points were well taken even if they unintentionally upset Peter. In particular, the point about one environmental group or another opposing every approach to additional energy generation is right on the mark. Conservation will help but it’s not going to solve the problem entirely.

    Matt W.

    I am very confused by your point about California, “…and the projected rolling blackouts were avoided.”.

    Please follow this link to PG&E’s web site. Please click on the section titled Rotating Outage Block. What do you think this means? In addition, many parts of California have astronomically high electricty prices. I am sorry to be blunt but have you been to California? I am in CA at least once a month and 1) nobody thinks Enron caused almost all of the problem, 2) it was not fixed in one summer and 3) it is still a big problem.

    Maybe you are right about the proposed coal plan in Wise County but you are wrong about the situation in California.

  14. Larry Gross Avatar
    Larry Gross

    thinking outside the box….

    what IF the Wise County location was a new NUKE plant?


    what IF it was a massive series of Wind Turbines?

    So… would it matter to Wise county people as long as jobs resulted ?

    Is the environmental community (as distinguished from NIMBYs) basic position that ANY new power source is unjustified until we have addressed our overall consumption of power?

    I think this is important from a couple of perspectives.

    First, as long as there is a carbon footprint or nuke storage consequences from energy usage AND the folks of the US continue to demonstrate much higher levels of consumption vice the rest of the world – even the rest of the industrialized world…

    should we care and if we do, is the answer technology and it’s cost as opposed to reducing our standards of living to be closer to the way the rest of the world lives….

    and the second perspective is – as has been mentioned…

    and I’m not quite sure how to state this without it being a pejorative but those who are self-avowed environmentalists (as opposed to the “green” feel-good hypocrites)…are “environmentalists” any less a hypocrite if they essentially choose to advocate a societal change in the use of energy without “leading” the way themselves?

    One CAN live off the grid or 90% so with a combination of very expensive solar power, expensive state-of-the-art appliances and just plain old sacrifice…

    So… in theory .. a “movement” of what I’d call True Green Believers could be started where folks who decry the emissions and mountain-top removal and other harmful consequences show by example that the rest of us ARE wanton in our uses where there are clear alternatives available if we truly want to be “green”.

    Sometimes.. I think I “hear” from the environmentalists that what they want is for the government to “force” all of us… the wantonly wasteful AND the self-deluded “greens” as well as the “true believer” environmentalists – all of us to be “forced” to be “green”.

    .. in essence.. because we simply are not capable or willing to make the hard choices ourselves.. so we must be treated as undisciplined children…”grounded” until we learn the correct way…

  15. Matt W. Avatar


    Sorry – once again I should have provided references. In answer to your questions, there were indeed rolling blackouts in 2000 and again in January of 2001, but that was before the state implemented an aggressive conservation plan. The real crisis was projected for the summer of 2001 and that’s where the projected rolling blackouts were avoided as stated above. For a pretty good story on what happened in California, as told by the state officials that were in charge at the time, check out the following video clip from the documentary Kilowatt Ours:

    I spend quite a bit of time in California, as my brother lives in Santa Monica and sister lives near Santa Cruz.

    Regarding the Enron issue, I think the wikipedia page on the energy crisis does a pretty good job of summarizing Enrons “Death Star” plan that FERC agreed was largely behind the “crisis” – here’s the link:

    Hope this clears up the confusion.


    While I can’t speak for all “enviros,” I can say that I and my organization are quite supportive of wind power and various other energy source development in the mountains. There’s no question that wind power provides a lot more jobs per kilowatt than a coal plant.

    In terms of “forcing” everyone to be “green” – the problem is that we all have to live with the consequences of air pollution and global warming. Fortunately, the alternatives really don’t involve a lot of sacrifice. For instance, with conservation and efficiency measures being considerably less expensive than building a new coal plant, implementing minor measures such as building codes for government buildings or higher air conditioner efficiency standards would save Virginians money both in terms of how much electricity they use and in terms of the price of electricity they purchase from Dominion.

    What really frustrates me, though, is everyone’s assumption that alternatives are so wildly expensive. As I mentioned, the newest generation of solar panels that began shipping in December have reduced the price by about 80% – here’s the story from the New York Times if you don’t believe me:

    I would also argue with your contention that “greens” have to have an alternative before criticizing a new coal plant. Do you really think Dominion, with all of their experts wants OUR energy plan? They clearly have the capability to do what’s needed – and if it involves passing a bill, they certainly don’t need our help. These guys could pass a bill in the GA blindfolded with both hands tied behind their backs.

    It would be awfully convenient for Dominion if we stopped holding them to account and spent all of our resources trying to do their job for them – while they go ahead and build a new coal plant.

  16. Anonymous Avatar

    “There’s no question that wind power provides a lot more jobs per kilowatt than a coal plant.”

    So what? That doesn’t mean a thing, except that wind energy is likely to be more expensive that coal energy. If you have a government policy that creates more jobs in one sector, you can’t necessarily claim that as a benefit. You have to consider what jobs were lost, as well.

    The guy who is scrubbing dead birds of the rotor vanes may not be getting paid as much as he would have been for running or maintaining a sophisticated flue gas scrubber.

    Neither do the price of solar cells or solar panels mean anything. You have to consider the cost, availability, and reliabilty of the entire system. That means you have to count the cost of the land the solar cells sit on, and the storage system they supply.

    (Otherwise, I agree the prices ARE coming down. But so far comments like this are simply far to pollyannish to be remotely real.) It will come, but we have a lot of work to do, first. If we want it done, then we had better figure out how to pay for allthe research and development needed.

    Dominion CAN do pretty much what they want. They want to make money. If they thought for a split second that they could geta big jump on the competition by spending their own R&D funds, then they would do it. So far, the profit just isn’t there. But if we beleive it is, then we had better be prepared to put our money where our mouth is.

    It is just hypocrisy to say we don’t need an energy plan and then criticize Dominion for the one they have.

    One estimate I have seen is that cleaning up the causes of global warming can be accomplished for around 1% of the global GNP. Some people think that is not a lot of sacrifice. But it is a HUGE sacrifice for all those people tht don’t have 1% of slck in their budget. To say that it is not a sacrifice is just a lack of imagination.

    If all the people who can’t afford it don’t pay, then the burden is going to fall on those that can pay. That is why a clean environment is a luxury the rich can afford.

    We are going to have to figure out, how to allocate that 1%. And that 1% on top of the 30% to 50% that developed nations already pay for social and governmental costs. And it is only one cause that deserves 1% additional, among many.

    We do all have to live with the consequences of global warming. We also all have to live with the consequences of combating it. We have to live with the consequences of wasting resources if we go about combating it badly.

    I think that being frustrated about everyones assumptions that the alternatives are so wildly expensive is indicative of combating it badly. Sure, I have my assumptions, and I’m willing to be proven wrong.

    So, one company is making cheap solar cells. Show me the rest of your assumptions. Show me where the money comes from and where it goes. Who is better off and by how much.

    Otherwise, your assumptions are no better than mine, and probably not as good as Dominion’s.

    For example, you assume:

    “For instance, with conservation and efficiency measures being considerably less expensive than building a new coal plant, implementing minor measures such as building codes for government buildings or higher air conditioner efficiency standards would save Virginians money both in terms of how much electricity they use and in terms of the price of electricity they purchase from Dominion.”

    I have studied energy management. It is true that some conservation measures are cheaper than producing more electricity, over time. But it is a huge leap from there to the claim that enforcing conservation codes will lower the price we pay.

    For example, we have codes taht enforce the use of silt fence. If all the silt fence used lived up to its potential we would stop a lot of sitation. But the way the codes are enforced, ensures that a lot of silt fence is used wastefully, and a lot that is needed, is’t required. Silt fence is a billion dollar industry, but no one is claiming it lowers the price that we pay.

    I don’t have a problem with your argument, I just don’t think it is anywhere near complete. Until we can sit down at the table with Dominions Engineers and Cost Estimators and beat them at their own game, in their stadium, we will be considered just a bunch of whacko greens.



  17. Larry Gross Avatar
    Larry Gross

    re: criticizing without offering alternatives.

    The enviros are free to criticize without offering alternatives but what does that accomplish if their so-called commitment to the environment is not to be a force for change?

    And simply stated – a force for change has to have credibility if they public is going to consider them … legitimate…

    So.. if you are an enviro.. the performance test is … are you effective in your advocacy? my view, it’s warm fuzzies for righteousness and little more.

    If substantial numbers of Virginians are going to rise up and challenge Dominion and the cynical GA types that “mandated” the coal plant – they’ll have to believe that either that plant is unneeded OR it is the WRONG path to the future.

    There is no shame to a principled attempt to get Virginia to move to a different/alternative path but to oppose something without at least addressing the underlying need … in my view.. undercuts the entire environmental movement and relegates them, in the eyes of the public, to well meaning but naive do gooders.

    I think it is a weak argument to claim that since Dominion is the “expert” that there is no way to show a realistic alternative path.

    They do not hold the font of information.. they merely use the parts that support their case.

  18. Groveton Avatar

    Matt W:

    Thanks for the response. Enron definitely had a role in the California energy crisis although I still wonder if it was as overwhelming a role as has been portrayed. Enron was as crooked as a country lane. However, I think they now make a good scapegoat for not only problems they caused but other problems as well.

    You seem to be very well versed in the overall question of energy conservation – not just coal fored energy. So, I’d like to get your opinion on a couple of things:

    1. What price per kilowatt hour would you consider acceptable for residential electricity in Virginia?

    2. Would you support a multi-tiered electricity pricing approach whereby those with more money or those who use more electricity per home pay a higher rate?

    3. In rough priority order, what conservation measures do you think are the most effective for single family residences?

    4. Beyond conservation, what alternate energy approaches do you think have the most promise (if any)?

    Thank you.

  19. Larry Gross Avatar
    Larry Gross

    re: ….”..You have to consider the cost, availability, and reliabilty of the entire system. That means you have to count the cost of the land the solar cells sit on, and the storage system they supply.”

    who says?

    this is just another version of advocating for the status quo.

    No one went through all these calculations when coal plants were built – did they?

    so… now.. we have to “prove” on a system-wide basis that competing technologies are “better”?

    I’d say .. no more or no less than the technologies that they seek to replace .. went through those same numbers…themselves…

    like I said.. this is just another version of claiming that the status quo contain change unless it jumps through a bunch of “what if” hoops.

    If solar panels come down 80% and someone can reduce their electric bill by .. say 30% – under the current regime – what happens?

    Dominion will raise their rates 30% to recover their “stranded” costs and they’ll do so with the full agreement and support of the General Assembly and the SCC because to NOT force ratepayers to pay the stranded costs then it could imperil the company itself.

    That’s why I say.. when these plants on approved under the current rules that what it does in effect, is to lock us all into a technology that may well become obsolete because Dominion recovers all their costs.

    What will happen… ultimately is that when Green technologies mature – that people will use more and more.. some even getting off the grid except as a backup power source… that the repayment of the stranded costs will be placed on a smaller and smaller pool of ratepayers.

    What Dominion is doing.. is essentially gambling that that plant and their rate structure will remain financially viable before Green technologies mature to the point where consumers will us them en mass.

    If the maturity of Green Power accelerates faster than Dominion has guessed…and we reach a tipping point far earlier than they projected… there will have to be a government bail-out…

    Of course if everyone who claimed to be an environmentalist converted their home to Green Power in the next couple of years.. they might force Dominion to reconsider the timeline..

  20. floodguy Avatar

    Unfortunately, I agree with the thesis, “where is the electricity going to come from?” It is sad a county like Wise has to be scarred by a coal plant. I have been to Wise, plus many other small towns and communities in SW Va and WV many times. I am no apologist for DVP as they have let our state down terribly making no effort to become a more efficient and smarter utility.

    The sad fact of the matter is, most people have little idea how the process of electricity is proposed, sited and governed. Our government, the SCC, Dominion Power, and the PJM, does not dictate what new source can be proposed. Any proposal for new power is driven by the market and more importantly, it is accepted that if the market doesn’t present itself with a viable alternative, one must not exist. Furthermore, with comments like the following from one of the most senior legislators in Congress, it is easy to believe the energy industry has bought off politicians, or better yet, it leaves many searching for solution.

    “I am very pleased by Dominion’s selection of a site for the future development of a new clean-coal power generation plant in Wise County. I will work with Dominion to ensure all federal regulatory requirements are resolved as expeditiously as possible.”

    Cong. Rick Boucher (D-Abingdon) May 16, 2006
    Member, House Committee on Energy and Commerce
    Chairman, House Subcomittee on Energy and Air Quality

    What many do not realize is our state, which was once considered to have ample electricity per NERC in 2005, is being drained of its electricity by the urban centers to our north, from D.C. up the I-95 corridor to NYC. Two extra high-voltage powerlines were just installed in 2006/7 from north Jersey to Long Island. To make matters worse, five aging power plants in NJ were just recently approved for decommissioning. D.C.’s only two power plants were approved in 2007 for decommissioning. And by the time Wise Co. is built, more than likely the 50+ year old 514 MW coal-fired power plant in the city of Alexandria will be proposed to be taken off-line. Meanwhile, interstate extra-high voltage transmission lines were proposed from WV to VA, from WV to PA, and from PA to north NJ. And just last fall another 500kv line was proposed from No.Va.’s Possum Point plant in Woodbridge to south Jersey. Nuclear expansion @ North Anna will not come on-line soon enough, and the proposed expansion by 2016 would only be enough to keep up with new demand forecasted for our state.

    What disturbs me is, the heavy demand areas from urban Northern Va, northward from D.C. to Philly, NJ and NYC, there is no mandate for energy efficiency and conservation. These states have no new sources, or have insufficient sources in the near-term to meet their electricity needs. Yet these areas continually demand more electricity despite having no means to meet their demand w/i their own borders. Because our grid is connected to theirs, our state and the citizens of Virginia are at the mercy of the regional authority, the PJM, who believe other states like Virginia should serve the energy needs for those urban centers along I-95 north. The marketplace is free and DVP has offered resources in our state to be imported, while replacing it with new expansion in state. Generation had just expanded 1835.4 MW this decade in our state, and it was all in Northern Va. I say, it should be a law that utilities in those areas of high demand, advertise CFL’s, and promote their own conversation plans by signing up volunteers amongst their heaviest users in a demand response program. These programs should be free and would return revenue to the participant depending on their level of participation. Furthermore, it should be mandated that smart switches on all electric hot-water heaters and outdoor a/c units be installed by those utilities, and that they manage their peak loads more effectively, for it is peak demand which is the primary driver of grid expansion, not baseline growth. Areas demanding electricity, which result in the proposal for grid expansion, must be required to prove they have made use of a certain % of the wasted electricity which exists in their part of the grid. The state of California has it right, as they had made this law in their state in June 2006 – EEC should be the top rank in the list of order when demand requires new generation or transmission.

    Even the PJM believes with modest implementation, grid expansion could be put off for 7 years. EEC is available now, and these measures cost less than the generation or transmission. EEC is quicker to implement, creates no pollution, does not require the condemnation of private or public land or public waters, and is not restricted by geographic location. While 7 years is not forever, instead of opting today to power their homes and businesses with coal which produces plums of soot and ash which would rain down on the property in our state and inhaled by its citizens, 7 years is time those states to our north can implement alternatives, such as a smart-grid, upgrade T&D equipment, EEC, or other green sources. This should be something our state assembly should pass and our Governor to introduce to this Nation’s board of governors.

    Call your utility and ask/demand a smart switch for your electric hot-water heater and your outdoor a/c unit. You, your family, and your business will not feel the difference. It will not cost you a dime, and if you don’t like it, you can have it removed. The more people have them installed, the more we make the existing grid efficient which lowers the price per kwh everyone pays and it allows our utility to supply more customers while reducing the need for grid expansion like Wise County is about to experience.

    God bless the people of Wise County. Do your part, get efficient!

  21. Anonymous Avatar

    I’m not advocating for status quo, I’m advocating for change, but I’m telling you that you can’t get it with half an argument, or an argument that is half true, or one that is an outright deceit.

    Of course the power companies figured out all the costs associated with their installations: land, infrastrucure, parking, cost of money, you name it.

    You are right, to some extent the companies will raise rates to cover their stranded costs. But they will only be able to do that to the extent the General Assembly sees those costs as necessary. In New England one entire coal plant was dismantled and re-sold to a company in Brazil, so we are not stuck with those costs forever.

    What is more likely, is that solar/wind will be more expensive, and they will raise their rates to cover the new additional costs. we will still need other sources to provide power at night, cloudy days, and windless days, or we will need big storage facilities, and a bigger, more dynamic grid.

    Either way, it is to our benefit NOT to endanger the company, but to realize they are a valuable ally and resource. We need a plan that ensures they will make enough money so that they will be interested in the plan.

    Cheaper solar cells is just one part of the problem. Unless you have a solution that meets the actual requirements, system wide, then you have got nothing.

    When renewables are only marginally more expensive than conventional, and cleaner, then they can compete, politically and economically, but we are not there yet.

    We need to be smart enough to arrange our plan so it has a soft landing, instead of a tipping point. Precisesly so that we don’t shoot ourselves in the foot with a government bail out. What you are suggesting with the stranded costs being dumped on a smaller and smaller pool of ratepayers is exactly the problem we have been arguing about with respect to roadways.

    We want people to drive less and pay more, and use the money for transit. If we succeed, one of two things will happen: we either give up the argument that drivers are not paying their share, and encourage driving in order to pay for transit, or else the price is so high everyone moves to transit, and then transit has to pay its own way.

    Either one of those is suboptimal, and we still need the roads, in this case the grid and backup power. So we need a plan that funds both efforts, each to the point that makes economic and environmental sense, without boxing ourselves into a corner or accepting undue risk.

    If everyone who claimed to be an environmentalist had $120k lying around that they were willing to make 1.5% on, then we would be wealthy enough that we could afford to be environmentalists. (I suppose they could add it to their mortage and get the mortgage deduction.)

    If all the things you have IF in front of come true, then we will see a different story. But I know that the fastest way for me to be able to afford solar, is to invest in something else that pays more. I don’t see those IFs happening any time soon.

    As long as we have green whackos moaning about profits, and trying to get business to pay for everything they want, investments that pay more are going to be hard to find. We should be pushing for investments that make money. We should be ready to cut a deal, rather than being intransigent, and we can use the money from our part of the deal to buy whatever we want.

    Converting to solar is still a dumb idea for most folks, but solar assisted hot water is pretty much a no-brainer (except a lot of installations are ugly). Let’s push for what works.

    If we are serious about building a wise energy future, then we need to prioritize on accurately assessing what is wise. We don’t do that by assuming a prioritization of energy efficiency, conservation, and clean, renewable energy over dirty and (allegedly)expensive coal.

    We could be wrong. We are probably not, but we don’t yet have an answer that is truly a no-brainer.

    It could be that burning coal and spending truly astronomical amounts on cleanup is still cheaper than something that doesn’t work. It could be that clean up technology advances faster than renewable technology.

    We will sooner find out the answer with a neutral, rational, and accurate position than we will by being seen as green whackos.


    Hey Waldo, how is your solar project going?


  22. Anonymous Avatar

    Flood Guy is right.

    Our environmental friends in New England have been fighting coal and nukes for decades, and the result is that they have exported their power requirements, and now we have to live with them.

    But we are not going to get anything worthwhile with mandates. That kind of thinking can only backfire in your face.

    Even if you believe that conservation buys us seven years, then what? We are right back where we are now, but with more risk, less reserve capacity, and more built up latent demand. Its a set-up for creating a tipping point. Waht leverage do we have to force states to our north to economize for our benefit?

    I simply don’t believe that buying less energy lowers the price per kilowatt. My customers that buy a lot of hay get a better price than the ones that are a pain in the butt and only call me when they have already fed their last bale, and they have an “emergency”.

    I’d like to believe that kind of stuff, but I just don’t see it.


    I just bought a water heater with a smart switch. It cost $200 more than the regular one, and now I never have enough hot water when I want it. I either jack up the thermostat so the hot water will carryover, or I don’t have hot water when I want it. If I can’t make it work better than it does now, I’ll eventually diable the switch. I don’t know what the difference in the electric bill is yet, but I doubt if it enough for the aggravation and cost.

    I can’t economize on AC, because I don’t have any. When I get around to it, it will be geothermal.



  23. Anonymous Avatar

    Geothermal is not as robust in Virginia as it is in some states. Solar is the way to go, especially for heating water. I am setting aside money for my own solar array.

    New Jersey and other states are actually doing a lot more than Virginia to conserve and harness renewable energy. Check out the wind turbines outside Atlantic City or the Solar Schools program.

    When it come to this new pcoal plant, the biggest costs are the opportunity costs. Dominion is dooming the Commonwealth to a weak, expensive, poisoned future.

  24. Larry Gross Avatar
    Larry Gross

    ahhh.. I’m getting the drift…

    first.. we take the North East garbage… and then we build dirty coal plants to light them up.

    Here we are pitying WVa and Wise county…

    talk about your locational variable costs…!!!

    So.. we build coal plants in Va so that Cape Cod does not have to put up with those awful wind turbines offshore… or those dangerous Nukes near their urban areas.


    Gee.. and here I thought that our own SCC was looking out for Va Taxpayers instead of Dominion Investors.

    musta landed on my hand falling off that turnip truck…

  25. floodguy Avatar


    EEC is being mandated in federally owned facilities and operations, and similarly in our state buildings and operations as of 2007. Most all of the states do not have this implemented or proposed. Basically all gov’t, fed, state, and local should mandate themselves to do this. For public and businesses, that’s another story. We shouldn’t force customers to conserve, but we should force the utility to devise EEC programs to promote and offer to volunteering customers.

    EEC should be treated no different than any other source of generation, by that utilities should receive compensation for every kw saved. The cost of the DR programs during peak usage, plus the compensation to the heavy users would be priced to all of the utility’s customers. For example, lets say in New Jersey 1000 MW is needed. If PSEG in NJ is able to obtain an add’l 1000 MW from its volunteering DR participants, the cost the utility incurs for running such a program, as well as paying those participants their “reward” money, is passed along to all of its customer base, and the utility can still charge others who use the 1000 MW they just obtain from DR as though it is coming from a power plant. Otherwise, the 1000 MW demand would have to come by way of new grid expansion, transmission or generation, at a rate more expensive.

    DR programs provide incentives or promote a program which will convert wasted electricity in major business operations and industry to usable electricity by addressing lighting, unused heat or steam, unused electricity from idling machinery or inefficient manufacturing & assembly designs. The EIA reported in 2003 that appx 40% of electricity purchased by industry is never used in the course of its process. Its just wasted.

    My other suggestion is that utitilies (and new home builders) should install smart switches on outdoor a/c units. The end-user once educated, could elect to have it deactivated if they so choose. Air conditioning during peak hours for example, is controlled by the end-user’s thermostat, which cycles on-and-off at variable times and for a variable duration during the day. The utility has no idea when these a/c’s are on or off, so they essentially have to have enough electricity on hand as though these a/c’s are operating 100% of time. A/c during the summer is the major component in energy spikes during in peak demand, and peak demand is the primary driver for grid expansion.

    By having a smart switch, the end-user essentially gives control of one’s a/c thermostat to the utility company during peak hours. Radio signals are sent by the utility which cycle on and off a/c units. I wholeheartedly believe the # of minutes cycled off is no different with a smart switch than without. The advantage now is the utility company knows when the ac will be on and when it will be off during peak hours. This is called load management.

    Imagine all 6,000 a/c units within a town are controlled via a smart switches. From 6pm to 2pm the next day, the a/c cycling is controlled by the end-users’ thermostat. But b/n 2pm to 6pm, the utility cycles off 1/3 of the units for :10 minutes every :30 minutes. Instead of traditionally having enough electricity for 6,000 a/c units 100% of the time b/n 2pm and 6pm, the utility company only has to estimate electricity for 4,000 a/c units 100% of the time, and can now deliver the electricity saved from 2000 a/c’s to another town a/c needs. Seems like alittle, but just think of the # of a/c from NYC south to Hampton Roads, Va?

    The hot-water smart switch I mention is smilar to an a/c switch, but peak is 5-10pm during 3-months of the winter. I’m not sure if you have such a radio-controlled switch on your new hwh or not.

    A mandated CFL promotion campaign, offering tv commericials, saving coupons, and free CFL’s to lower income should also be considered.

    The EIA also reported in 2003 that appx ~17.9% of all electricity meant for market is lost due to inefficient transmisssion and distribution equipment. Some of this waste can be eliminated via equipment upgrades already avaiable. Just last year, the Edison Electric Institute recommended to FERC to mandate these equipment upgrades.

    My point is, a state proposing need for grid expansion from out-of-state must demonstrate it has made the existing grid efficient as set forth in my 4 examples of EEC. This isn’t my idea, this is from a state which has been at the forefront of new sound energy policy – California.

    ”Even if you believe that conservation buys us seven years, then what?”

    Well we have more time which is vital to a lot of things.

    EEC makes the grid efficient so expansion, when it does occur, can be sited more appropriately with less overlap. This saves future investments and by reducing other needs for expansion all by itself.

    7 years eliminates x amount of GHG from entering the atmosphere, those aiding utilities to meet many states RPS requirements.

    7 years provides for additional time for the development, testing and implementation of smart-grid technologies, clean coal, nuclear, distributed generation of solar, wind, biomass, and storage.

  26. Anonymous Avatar

    Geez, Larry. Where have you been?

    When I said geothermal, what I meant was ground source heat pump, not true geothermal. Groundsource heat pump works great, saves energy, and it’s quiet. It costs more to install, but the payback is reasonable.

    Solar hot water is better on a return of costs basis, but the amount to be saved is pretty small. Hot water only costs a buck a day.

    The solar schools program is a boondoggle that is making political points and costing taxpayers money. When the real percapita usage of energy in NJ is lower than in Viginia, and when it is falling faster on account of longstanding government projects that work, then I’ll agree they are doing a better job. Right now, they are doing better advertizing. I want to see results.


  27. Jim Bacon Avatar
    Jim Bacon

    Floodguy, well said. Instead of chastising Dominion and other power producers for pursuing their self interest under the current regulatory regime, we should set create incentives for them to conserve and invest in energy efficiency. Fortunately, we don’t have to do a lot of original thinking ourselves: We can simply look to the example set by California.

    One caveat: Techniques and technologies that work in California may not necessarily work in Virginia, where electricity is some 50 percent less expensive.

  28. Anonymous Avatar

    “Basically all gov’t, fed, state, and local should mandate themselves to do this. For public and businesses, that’s another story. We shouldn’t force customers to conserve, but we should force the utility to devise EEC programs to promote and offer to volunteering customers.”

    That’s a lot different and a lot better. I still have a problem with government mandating themselves to do this. What they should do is mandate that these issues be considered and applied wher they makes sense. They won’t make sense for every building.

    That’s the problem I have. We say gee this is a good idea, we ought to do this, and then we do a lousy job, and waste a lot of resources.

    Even if a particular project IS a good idea, a mandate means that some other project cannot be considered, even if it is a better idea. With enough mandates we can no longer even consider other ideas, because we are out of money.

    I agree in principle that EEC should be treated no different than any other source of generation. I also note the plan to reward the losers in such a way that everyone comes out ahead. This is the proper approach.

    I understand about demand management and process waste, and what I’m telling you is that it is not as easy or profitable as you paint the picture. I’m not saying that it isn’t worth doing, just that it is not all worth doing. For example. EIA says all the power bought by industry is not used in their process. That does NOT mean that the rest is wasted.

    Some air conditioning and heat pump units are undersized, which means they run pretty much continually during the hottest and coldest periods. If you shut them off one third the time, you get one third the air conditioning. Anyway, the compressors cycle on and off at random, so the sytem is already self averaging. The difference you describe is who controls the averaging, and the cost of doing it is not free.

    Line losses in transmission are different, and a more localized grid can help. There are useful technologies that work, but they are capital intensive. You may not get the efficiencies that a big plant gets, so you lose some of the gain in transmission loss. Youmay have more pollution closer to where more people live, and suffer more damage, not less.

    None of this stuff is free, and it all takes a lot of work. That’s perfectly OK for those tasks that pay, but it is an environmental and fiscal disaster when they don’t pay. We put up millions of dollars of polyethlene silt fence every year, some of which is doing nothing or less than nothing. But, it is mandated. How many smart switches could we buy with the money we waste on silt fence?

    The question was, if it buys you seven years THEN what. You have used up all your savings, and now you are in a worse condition than before, with higher capital costs to be met later. This is trying to beat off a lee shore with your smallest sails up. If it works, you saved a lot of energy and grief. If it doesn’t work, then you are shipwrecked.

    My water heater is not connected to the power company. I’m too far in the boonies to get radio waves. They still send someone to read the meter. But the water heater has a processor in it that determines or (learns) when I use hot water, and turns back the heat the rest of the time. Apparently it hasn’t leaned my schedule, or my schedule is erratic. So far, it was a waste of money, and I’m not sure the power company can do any better.

    You can get a similar device and put it on your main water line. Whenit senses unusually high use of water, it shuts off. This can save you major flood damage in your house in case of a broken pipe etc. It only has to work once, and it will save you many thousands of times what the smart switch on your water heater will save.

    Like you say, saving is exactly the same as generating more money, and it should be treated the same. If you are offered four little jobs, or one big one for the same money, which do you take?

    Your argument is technically and politically correct. These things can save money and power and GHG. Maybe. Or maybe we wind up with a zillion service techs driving around to fix all the inoperable gadgets. So, your argument is correct, but it’s not entirely proven,and you can’t get all the savings you think you will.

    Sure, there are hypermilers taht turn off their engines going down hill. Then they don’t have power steering or brakes. They think they are saving money, I think they are whackos.


  29. Matt W. Avatar


    I just want to say that this is an excellent conversation and I appreciate folks being respectful of different viewpoints. Before I get to answering groveton’s questions, I just want to point out that I think just about everyone on this thread is on pretty much the same page.

    While I am quite confident, based on the experience of various states that conservation and efficiency measures are at least as affordable as building new coal generation (not sure if everyone knows that Dominion’s original estimate of $800 million for the new plant has now doubled just in the last two years).

    But in terms of market incentives for Dominion to promote conservation, I completely agree with what folks have said. If Dominion wants to pass a bill to get such incentives passed, however, they could do it quite easily without our help. As I said earlier, these guys could get any bill they want passed through the GA blindfolded with both hands tied behind their backs – just look at the godawful re-regulation bill they wrote that passed earlier this year, it’s the most shameless money grab I’ve ever seen.

    Regardless, I’d love to work with Dominion on that if they had any interest. The problem is that, as Dominion knows well, as soon as you start implementing EEC, smart grid technologies and a renewables-friendly grid, it starts to eat away at their monopoly. In the long run, it will reduce their power and, as by far the most powerful lobby in Richmond, they’re just not real interested in that.

    All that said, I suspect the proposed Wise County boondoggle has a lot more to do with Senator Wampler and the irresistable incentives he got passed when the Republicans controlled the Senate rather than a burning desire to build a coal plant all the way out in Wise County. But with a guaranteed 14% rate of return on investment with rate-payers taking 100% of the risk, it’s pretty hard to imagine a better investment for Dominion shareholders.

    Only in Virginia.

    Anyway, on to groveton’s questions:

    1. What price per kilowatt hour would you consider acceptable for residential electricity in Virginia?

    I wish I had any idea, but I don’t think it’s really about absolute costs but rather comparative costs. While VA has relatively low electricity prices now, the fact is that our cheap coal supply is not nearly as cheap as it used to be and is projected to get a LOT more expensive in the next few years. Virginia coal production peaked in 1990 and has been declining ever since – particularly in the last few years, even though prices have been at record levels since 2003 (and Virginia’s coal is the most expensive in the nation).

    Why? Because all the easy-to-get coal has long since been mined out. The same is true for the rest of Central Appalachia (where VA gets almost all of our coal from). Here’s what the USGS had to say in the most recent report on coal reserves in Appalachia:

    “Sufficient high-quality, thick, bituminous resources remain in [Appalachian Basin] coal beds and coal zones to last for the next one to two decades at current production.”

    – United States Geological Survey (USGS), 2000

    This is of no concern to Dominion, as fuel prices get passed straight through to rate-payers, but it should be of major concern to those paying the bills.

    If you want to read up more on VA coal issues, here’s a little report I put together last year for members of the GA:

    All this is to say that electricity prices are going up rapidly whether it’s coal-based generation or alternatives. It’s going to take someone a lot smarter than me to figure out the relative costs of various options, however.

    2. Would you support a multi-tiered electricity pricing approach whereby those with more money or those who use more electricity per home pay a higher rate?

    I’ve never hear of an idea like this. My gut feeling is that it’s untenable to base rates on income, but I do like the idea of some sort of price threshold on electricity use, with homes or businesses paying higher rates above a certain level. Seems like it could create an excellent incentive for conservation or home-based or business-based solar and other alternatives. Is this your idea, or are there people working on such a plan? I’d love to hear more about any plans along these lines that have been developed!

    3. In rough priority order, what conservation measures do you think are the most effective for single family residences?

    It sounds a little cliche these days, but installing compact fluorescents is absolutely the place to start. Even changing out a few makes a huge difference – especially in terms of outdoor lights that stay on for a long time. Equally important is plugging all appliances in to power strips and turning the strips off when not in use.

    I managed to cut my electricity usage down to an average of 9 KWh per day by installing almost all compact fluorescents (except for a few full-spectrum incandescents that my fiancee insists have to remain in the living room), by getting rid of the ridiculously inefficient standard water heater and installing a tankless model, and by putting all of my appliances on power strips that are turned off when I don’t need them (I’ve heard that 75% of the lifetime energy consumption of the typical appliance is consumed when it is turned off).

    Total cost: about $1,000
    Savings: About $1.30 per day
    Time to break even: about 2 years

    The truth is, though, I don’t have a lot of expertise in this area but I would refer you to the website – most of what I do know I learned from Jeff Barrie who put together the site and a documentary that every American should watch called Kilowatt Ours.

    4. Beyond conservation, what alternate energy approaches do you think have the most promise (if any)?

    While it may be a while before solar power displaces a significant amount of coal-based electricity, the price per watt really is close to comparable with the newest generation of thin-film cells. Given that enough solar energy strikes the earth every 40 minutes to power the entire world’s energy demand, this is clearly the most promising technology. It also has the advantage that it generates peak power right around the time that there is peak energy demand (late afternoon in the summer), meaning that even a small amount of installed photovoltaics could reduce the need for new coal plants because, as someone mentioned earlier, the problem Virginia and most states face in the next decade has little to do with base-load generation and everything to do with peak demand. Reducing peak demand by a few percentage points would completely obviate the need for the Wise County plant.

    Hope that helps, and I’d love to hear what anyone else has to say about these questions.

  30. Larry Gross Avatar
    Larry Gross

    radio waves are not needed for smart meters.

    they use the wire to move data.

    My meter is read remotely by my provider as well as they have the ability to cycle on and off my water heater.

    But I’m leery about the heat/air cycling on an arbitrary basis unless it is also sensing the indoor temperature. One size will not fit all …

    Peak hour pricing and step increases for higher usage – yes.

    Incentives for BOTH Dominion AND the consumer – which starts with decoupling…

    so you make Dominion “whole” on their stranded investments plus incentivize them to NOT build new plants UNTIL we’ve exploited at least the low-hanging conservation fruit…

    incentives, tax, loans for tankless water heaters, and geo-thermal heat/cool, fluorescents/leds, etc.

    and a small editorial comment:

    The things under discussion are the things that I would welcome from the environmental community as leadership in the directions we need to be heading as opposed to .. just opposition to new plants and feel-good fuzzy ideas about conservation…

    I still continue to believe that we had great .. unused/wasted swaths of land along power-light and road right of ways… bridges, etc and if solar panels are dropping in price… why not make that part of the equation?

    Finally.. keep in mind… “solving” the electric power puzzle has huge implications on automobiles and oil if there is success… because plug-in autos that will use electricity instead of oil .. has the potential to transform this country’s energy footprint..

  31. Anonymous Avatar

    “radio waves are not needed for smart meters.

    they use the wire to move data.”

    There are several technologies available, and each of them has limitations. Some use radio waves, some use telephone wires. As I undertand it, to transmit over the electric wire needs a lot of repeaters because the signal gets lost in the transformers. I think that system works best for relatively local areas, then you need some kind of collector.

    It works in some areas, but it won’t work here for quite some time. Not to say it can’t work because it obviously does in your case. making it work universally and consistently is an entirely different problem.

    You are right about electricity leakage from “instant on” appliances, etc.

    Suppose you do save some KW and then sell them to others as you described. What have you saved?

    Or is it only a transfer of wealth form those we think have a lesser value for their use to those with a higher value for their use?

    “Given that enough solar energy strikes the earth every 40 minutes to power the entire world’s energy demand, this is clearly the most promising technology.”

    This really makes me crazy, because it is a totally bogus argument. It is repeated and repeated and repeated, like the idea that a transit line can carry 40,000 passengers per hour. It sounds nice, but it is just wrong.

    Yep, that much energy strikes the earth. Now how do you catch it in a usable way? Collecting, concentrating, storing, and delivering al lthat diffuse energy is an enormous job. This little factoid, while true, still distorts and trivializes the facts.

    I think that kind of environmental activism is just wrong, because it is misleading. The actual truth is still good, and it makes a much better story.


  32. floodguy Avatar

    Jim while that may be true, DVP is being allowed to import our electricity to the north, where the cost per kwh is higher. It is there where the grid is extremely older and more inefficient. Furthmore, due to the size of the load up I-95, the potential savings is very large, if not the largest in the nation. And lets not forget, because of DVP, our state is 50th in the nation in energy conservation.

  33. floodguy Avatar

    Larry – I understand you are concern – a cycling off of your unit when your thermostat is about to cycle on, as 2pm approaches and a signal turns off you’re a/c unit. I don’t believe these switches consider this. However, once your :10 minutes is up, yes you will then encounter a rise in temp above your indoor temp setting, but your unit will probably run nonstop during the next :20 minutes before it cycles down.

    I too was skeptical at first, and concerned my house would heat up. But last year, neither my wife or 3 kids at home complained and none noticed the switches were even installed. Remember, you can always have it removed.

    I should also say the NOVEC installer stated the switches he installed were controlled by radio frequency. Perhaps my community is in close proximity to a substation (?) He stated there are about 6 different types and they would do not install the same frequency type on any one building unless there are 7 or more units. I have a two zone system, so my two a/c units have 2 different switch which do cycle on and off at different times. Btw, NOVEC uses a :07 cycle per every :30 minutes. I also might add that the indoor system still runs the fan for about 2 or 3 minutes after they are cycled off, so the :07 minute downtime feels shorter.

    RH – I think you are missing the point I was trying to offer. Not all waste is recoverable, and where it makes no financial sense, I’m sure it will not be attempted. As for gov’t mandating themselves, if the program is intense, a curtail specialist can be hired. If it is light, then it can be managed in-house. As you and I know, most gov’t buildings are older and more than likely, there is plently of waste as we can imagine. The net result should definitely have no costs onto the participant after the savings, and it should cause no decrease in access to the electricity supply. To me, EEC for a governnment body it seems there is no way to lose other than by not participating. Congress already passed it. Gov. Kaine issued an executive order just last year, and my county voted on it and passed a resolution 5-2. (Both democrats voted against it believe it or not!) You should look up some very recent papers from NARUC to FERC, FERC to Congress, and NAPEE, on the subject “demand response” and ‘advanced metering”, much of which is now being promoted in EIAS Act of 2007 section xiii.

    The bottomline forme is, to allow utilities in the states to our north to maintain and operate aging & inefficient grids, while requiring out-of-state grid expansion to meet their own needs, such as Wise Co and the Meadow-Brook to Loudoun 500kv line, is painfully unfair.

    Our RTO, the PJM (which by the way stands for Pennsylvannia, Jersey and Maryland), should require any utility seeking out-of-state expansion for their own customers, prove they have reasonably exhausted all resources beforehand.

    If the EEC is fully implemented at a set % or standard is met and expansion is still required, so be it. But to build out the existing grid with its continued inefficienies at the price Virginia is paying after just adding 1800+ MW this decade, plus another 800-1100 MW in the proposed queque, isn’t sound energy planning. EEC buys time for states like those to the north to have a chance to find other solutions.

  34. Anonymous Avatar

    ” Not all waste is recoverable, and where it makes no financial sense, I’m sure it will not be attempted.”

    That’s all I was trying to say, at least we can hope. I’ve just been around long enough to see a lot of waste in the name of trying blindly to conserve.

    Some of those old buildings, it might be worth to tear down and replace.

    But when you say “The net result should definitely have no costs onto the participant after the savings, and it should cause no decrease in access to the electricity supply.” then you are singing my tune. It’s a similar message I have been preaching with little success.

    Put that up front, repeat it often, and show concrete examples along the way, and THEN I’m on your side 100%.

    “The bottomline forme is, to allow utilities in the states to our north to maintain and operate aging & inefficient grids, while requiring out-of-state grid expansion to meet their own needs, such as Wise Co and the Meadow-Brook to Loudoun 500kv line, is painfully unfair.”

    Yep. Three of the proposed routes for Meadow brook to Loudoun go through my property. And as a former New Englander, I saw what happened up there to bring us to this.

    So here we have the Urban areas to our north requiring much more electricity to be shipped across the countryside. Some will tell you it is more efficient to use and reuse our urban spaces more densely and it is those in the countryside that don’t pay their full costs. Here is an example of the opposite.

    Sooner or later, though, somebody, somewhere, is going to get stuck with a power line or power plant they don’t want, conservation or no.

    We need to work just as hard or harder to take the unfairness out as we do to prevent new construction or promote conservation. Taking the unfairness out will raise the price of new construction, and make the alternatives more attractive. There are millions of potential users who will use the new service every day and pay for it every month. The poor SOB that gets stepped on will get paid once, and at a rate determined by the value of the previous use.

    Painfully unfair is an understatement.

    Like I said before, one way New England exhausted its resources was by shipping an entire plant to Brazil or Guatemala somewhere. How much GHG did that save?

    I’ll look up the papers when I get a chance.

    Nice Cahtting, and good luck.


  35. Larry Gross Avatar
    Larry Gross

    re: transit capacity

    I fess up. It’s not 40K but only 20K (which is only about 10 times more efficient than road capacity).

    “Capacity of light rail versus roads

    Roads have capacity limits which can be determined by traffic engineers. Due to traffic congestion they experience a chaotic breakdown in flow and a dramatic drop in speed if they exceed about 2,000 vehicles per hour per lane (each car roughly 2 seconds behind another). [15] Since automobiles in many places average only 1.2 passengers during rush hour[citation needed], this limits roads to about 2,400 passengers per hour per lane. This can be mitigated somewhat by using high-occupancy vehicle (HOV) lanes.

    Light rail vehicles can travel in trains carrying much higher passenger volumes.[16] If run in streets, light rail systems are limited by city block lengths to about four 180-passenger vehicles (720 passengers). Operating on 2 minute headways using traffic signal progression, a well-designed system can handle more than 30 trains per hour, achieving peak rates of over 20,000 passengers per hour per track.”

    good enough RH? Will you accept 20K capacity vs 2K capacity for roads?

  36. Larry Gross Avatar
    Larry Gross

    re: NOVEC conservation initiatives

    Isn’t it interesting that NOVEC and REC (Rappahannock Electric Cooperative) appear to have much more advanced and widespread conservation initiatives than Dominion.

    Also.. the Electric Cooperatives rebate real money at the end of the year if they end up with more money than expenses.

    This all goes back to Dominion taking the path that will yield the most sales and most profits – as a seller of electricity not only in Virginia but apparently the North East.

    I don’t begrudge Dominion their business opportunity nor their profit nor the idea that they ought to be compensated for their stranded investments but I do begrudge them “using” Virginia’s “supportive” policies for building more plants – to sell power to folks outside of Virginia – who will not have to pay for Dominions stranded investments if technology overtakes Dominions business plan strategy.

    The day will come when Dominion’s strategy will unravel… and that day could come much sooner than they think…, but their bases are covered because no matter how bad their investment strategy is in power generation… Virginia’s ratepayers are committed to pay those “stranded” costs..

    So.. Dominion’s “risk” in making wrong decisions about which technologies to use is.. minimal.

    I think for Virginia’s elected officials to allow that to happen is a disservice.

  37. Jim Bacon Avatar
    Jim Bacon

    Larry, that’s an excellent point regarding the potential for Dominion’s standed investments. When power plants have life expectancies of 50 years… renewable energy sources may not be competitive for the next ten years. But they may well be more than competitive in years 11 through 50. I had given insufficient attention to that angle.

  38. Anonymous Avatar

    From your Wikipedia reference:

    “Most North American systems are limited by demand rather than capacity and seldom reach 10,000 passengers per hour per track.”

    Which is pretty close to what I said metro is hauling during rush hour. Who has ridden the Orange line during rush hour and thinks it can carry twice as many people as it does? If they could carry twice as many people, then why are they taking seats out of the cars?

    So, no, I don’t buy it. I don’t think you can reasonably expect to run vehicles with 150 people on board, some boarding and dis-boarding at eash stop and run on two minute schedules. That is a high end estimate. It’s like saying a horse can run 25 miles per hour: doesn’t tell the whole story. It’s that “all the solar energy that hits the earth in 40 minutes” idea.

    Show me one system that actually does it, and let’s take a closer look.

    Your reference points out that Calgary has a low cost system that cost ONLY 24 million per mile, and since it has high ridership (250,000 per weekday) its operating costs are only 27 cents per ride. (we don’t know how long a ride is so we can’t figure costs per mile.)

    But they have 26 miles of track and they operate on 5 minute schedules during rush hour. Which is about what metro runs, (I think.) I could be a little faster in some places, but then they count some places as two lines.

    Your Wikipedia site says a Calgary train averages 600 passengers per hour, with five minute headway. That means 7200 passengers per hour, not 20,000.

    And the numbers don’t add up. 250,000 passengers with an average of 600 per train means 416 trains a day. If they operate for 12 hours a day that’s only 35 trains per hour on the entire 26 mile system. That’s only 17 trains each direction, per hour, which means they are 1.5 miles apart. To keep a five minute schedule they are running 18 miles an hour on average. Which is about what Metro runs. If they operate more than 12 hours a day, it either gets worse, or else they don’t keep a five minute schedule.

    Then there is the question of whether they can actually keep their five minute schedule. We know Metro has problems: trains back up because you can’t get the people on and off fast enough and the escalators back up.

    Their total ridership divided by the miles of track they have suggests they carry 10,000 passngers per mile of track. At 27 cents per ride, that would average to 27 cents per mile – operating costs only. That’s actually pretty good for transit.

    But,i If I drove my Prius 18 miles per hour it would operate for less than ten cents a mile – and I get a seat, my own schedule, and my own route.

    And Calgary is a heavily used system. For everbody else, it’s even worse.

    What is the point of building twice the potential capacity people will use? Especially if you can’t really reach that capacity in a usable fasion.

    What is the point of selling a system on its potential capacity if it will never be used. We are thirty years into Metro, they should have had time to build their ridership by now.

    What’s the point of bragging about how many people you can potentially carry, if you can’t give them a seat, or go where they want to go?

    What’s the point of bragging about how many people you can potentially carry, if they travel at an average of 17 mph?


    Your article does say that there are European systems that operate at max loads, but they don’t say how it is done. Longer trains and stations? Multiple tracks or sidings?

    I never said that there are not places where trains make sense, just that there are not very many of them. If you need to build a special place, just so that they do make sense, then part of the capital cost of building gets allocated to the transportation system (and so would part of the value of that construction, as a benefit.)


  39. Matt W. Avatar

    Quick clarification to anonymous:

    Clearly we couldn’t tap into even a millionth of the solar energy that hits the earth, but the point is that a millionth of it would still be a lot.

    In terms of where and how to capture some of that energy and get it on to the grid, there are plenty of ideas out there and it’s not clear to me at all why you have such a problem with it. Please don’t take offense at this, but it seems that you’re just ignorant of how solar is being used now and how people are planning to use it in the future and so you just keep saying how it won’t work or is too difficult without anything to back that up. The fact is, solar energy is gaining traction quickly despite all the nay-sayers who keep saying it doesn’t work.

    Briefly, here’s a synopsis of the issue:

    As mentioned above, the per-watt cost of generating energy from photovoltaics is rapidly closing in on the price of coal-based electricity (and some are arguing the gap has already closed).

    Now, we all know that the sun doesn’t shine 24 hours/day and photovoltaics are less efficient on cloudy days, so how can we depend on solar energy for reliable electricity supply? There are two answers to this.

    First, simply connecting solar power to the grid that’s generated on the top of buildings, houses and strategically-placed solar farms can go a long way to offset peak demand during summer afternoons when the peak can approach double the typical baseload demand. Even using solar to generate 3-4% of peak energy demand would eliminate the need for the Wise County plant.

    Second – and more importantly, as a team of scientists laid out in the cover article of the most recent Scientific American, solar and wind power can be stored with minimal losses using simple technologies such as compressed air (an excellent use of abandoned mines in Southwest VA). Which is to say, we’re talking about baseload power here, not intermittent 8-hours per day power.

    These experts lay out a “Grand Plan” using existing technologies and more-than reasonable cost projections to show how solar power could affordably meet 63% of America’s energy demand by 2050 (including 84,000 Megawatts by 2020, which is about 150 times what the Wise County plant would produce).

    I really think you should read up on how solar is being used and planning to be used before going off on how it doesn’t work. And I hope others won’t take your ignorance of how it works as some sort of evidence that it doesn’t work!

  40. Anonymous Avatar

    “Mumbai’s suburban railway is the densest route in the world. It is approximately a little more than 50,000 passengers per kilometer, transporting 65 lakh (6.5 million) commuters daily. This has resulted in severe overloading in the trains which carry 5000 commuters per 9 car train which are designed to carry less than a third of that amount. The density of passengers in peak hours is as high as 15 people per sq metre.

    We went to the busy Dadar station today at rush hour to watch the spectacle, which should not be missed in any visit to Mumbai. The event can best be described as a sport for the men. It takes speed, agility, strength, perseverance and concentration. “

    So the densest capacity in the world is 50,000 per kilometer, and it is overbooked by a factor of three, meaning it is designed to carry a max of 16,000 per hour.

    It is a problem of overselling what is reasonably possible.

    And it is the same with Matt’s analysis. If I cam e to my CEO with an anlysis like that, I’d get thrown out.

    True, the cost of generating with solar voltaic is getting lower, the cost of coal generation is getting higher.

    “how can we depend on solar energy for reliable electricity supply? …” We simply use a solar grid (that we don’t have yet) and strategically place it (not so simple) and plan on getting just when we need it for peak load, and only 3 or four percent, of that.

    How is that depending on solar for reliable energy?

    What you came up with wasn’t what was promised in the intial question. That looks like shooting yourself in the foot.

    Simple technologies like compessed air are really dangerous. There are rules about pressure testing tanks only with hydraulics for just that reason. Show me a mine that has actully been used for repeated pressurised storage. Materials fail when you cycle them like that.

    As far as I know, it has never been done, and the cost of that has to be added to the cost of generating solar.

    So what we have is an unspecified Grand Plan to get 63% of our power by 2050, at unspecified but reasonable costs, which are sure to over-run. And which are put together by scientists,not engineers.

    I never said it doesn’t work, or that it couldn’t work. I do a little reading, I have completed graduate studies in environmental and energy management and economics, and I’m still no expert, but I’m not ignorant, either. What I do know is that things are never as easy as they look. I’ve seen estimates of waht it will cost to meet North Caolina’s mandate, and it isn’t pretty.

    I pretty much agree with John Whitehead, a noted environmental economist.

    “There are currently no viable alternatives to coal and oil without government subsidies.”

    “If oil production begins to slow, if the United States pursues climate change regulation, then the price of coal-generated electricity will rise. With further research and development subsidies and technology-forcing mandates, the cost of renewable energy is likely to fall in the future.”

    “The transition from oil and coal to renewable energy sources is not likely to increase the number of jobs in the U.S., despite wild claims by those who are currently pushing government policies to mandate renewable energy sources.”

    “There would be positive economic effects. such as the improved health and recreation from improved air and water quality and mitigation of climate change.”

    “Environmental regulations raise the cost of production, and that reduces profit. Business firms will attempt to pass the additional cost of regulation onto consumers in the form of higher prices, but consumers will respond by buying less of the product or postponing the purchase decision.”

    “I don’t think people should go out of their way to live greener, unless this is what they enjoy doing. I expect people to respond to incentives, and right now we don’t have the right incentives in place to transition to a more sustainable economy. Higher prices for products that generate pollution during the production and consumption process are necessary to get consumers to change behavior in a big way. Instead of spending a bunch of time recycling and buying green-labeled paper towels, consumer-voters should do as much as possible to get a $1 per gallon increase in the gas tax.”


    That is what he says, and my training and experience says he is right.

    Businesses will have to provide products consumer want, within a regulated environment. But we need to be careful because this is a self regulating feedback situation.

    When consumers find that they cannot get what they want, they may start blaming the environmental mandates that put them in that position. The question (eventually) becomes whether the improved health and recreation benefits are worth more than your inability to acquire your daily needs, which is waht shutting off your electricity is all about.

    This is not a question of whether solar and wind will work, and I never said otherwise. We can make it work. The trick is going to be to make it work in such a way that the pleasure is greater than the pain. And in convincing others that they should have the same standards of pleasure and pain that we do.

    When you have an actual solar, or wave, or wind system that works, a whole system, and you know what it costs, then come back and talk to me. We can demonstrate solar or wave or wind turbines work. No problem. But that is a long, long way from having a total system that works. It’s a long way from getting to 20%.

    When you can show me an actual transit system that carries 20,000 people per hour and we understand all the costs and all the benefits, and all the outside requirements and externalities (like mandates).

    Then we can talk reasonably about what works “better” and costs “less”.

    I’m not skeptical or disbelieving, just realistic. Realistically, we need better plans, better figures to back up the plans and a lot better sales pitch.

    Calling people ignorant, doesn;t qualify.


  41. Larry Gross Avatar
    Larry Gross

    I keep saying that anon RH is “Mr. Status Quo”.

    We cannot change nor embrace change without a “though” and exhaustive “investigation” to determine all the potential unintended consequences including figuring out all the oxes that could be gored….

    … even though no one did such a thorough and exhaustive investigation on the things that are now Status Quo…

    so .. if something saves energy.. we cannot do it until we makes sure that it does not result in folks who make parts for coal plants might lose their job as a result of switching over to solar…

    .. etc, etc


  42. Anonymous Avatar

    Not true, Larry. I’m in favor of change, and an early adopter (Prius and ground source heat pump for just two examples).

    I don’t think we need, or can afford necessarily, exhaustive analysis. When the study cost more than you are likely to save or lose, then it’s time to stop. It’s also tme to admit you can’t prove whethehr you will gain or lose.

    But we need analysis that is a whole lot more that “This is better and cheaper and it will save the world.” Repeated over and over and over until the morons believe it.

    There are far too many people who will use tht kind of lousy thinking as an excuse to grab (or sell) what they want and run. Or push what they dont want onto someone else.


  43. Anonymous Avatar

    A lot of people used to make their living building things tha tno longer exist. But those things got replaced by new things with more capacity that were better and cheaper. Not by things that the government said “YOU MUST BUY”.

    When renewable energy gets there (better, cheaper, more capacity), I will be the first in line. I can’t see it’s tere yet. I cansee it is getting closer. It’s been getting closer for a hundred years.


  44. Larry Gross Avatar
    Larry Gross

    Capacity and Cost Comparisons of
    Rapid Transit Modes

    Typical Capacity Ranges- Heavy Rail
    Peak-Hour Capacity 13000 to 41000
    Highest Observed in U.S. or Canada

    page 14

  45. Larry Gross Avatar
    Larry Gross

    I’m just tweaking you RH…

    I think the main point I was trying to make on the energy question is that … do you think that green/solar/etc will be cost-effective before a new coal plant will become obsolete?

    Because if you do.. what will happen if some big breakthroughs happen and people start buying solar WITHOUT incentives?

    What will happen is that as more and more people use less and less coal-powered energy – Dominion gets squeezed on paying for their plant – but since they got a guaranteed payback from ratepayers.. there is NOT a level playing field for people to actually choose for themselves.

    You’re saying that Government should not force people to buy a certain kind of power – but isn’t that, in fact, what they are doing if they approve a guaranteed return for Dominion on their coal plant?

    Why not let Dominion take the risk and the gamble on that plant instead of Virginia ratepayers?

  46. Anonymous Avatar

    “isn’t that, in fact, what they are doing if they approve a guaranteed return for Dominion on their coal plant?”

    Why? You can buy your own generator, as Mennonites do. You can go off grid, if you invest enough. You can go all gas.

    Individually, you are free. But the government recognizes that dependable electric power is central to safety, security , and economy. And it is not very amenable to competition.

    What we do is limit Dominions return to a reasonable one, as opposed to letting them charge what the market will bear. In exchange, they get a monopoly position.

    Now, if the county limited my ability to build houses and charge wha the market will bear, but guaranteed me a minimum return on what they let me have instead, I’d be in a lot better shape.

    If we want Dominion to take all the risk, then we should expect to let dominion take all the profit.

    Realistically, when renewable energy comes on line, Dominion will be selling it, and getting a guaranteed return. Right now, I wouldn’t bet against them. Anybody that wants to, can go buy stock in solar companies, and sell Dominion short.

    Or you can pay extra and have Dominion buy your power from a green source.

    Even with a big breakthrough in solar, we still need a breakthrough in the system. I think the breakthroughs will come gradually and the shift will come gradually. I f the coal plant is obsolete,it won’t mean it isnt useful. I’ve got tractors that are obsolete, and I still use them.

    Isn’t it the people who want mandates the ones who think we should buy a certain kind of power? If they mandate solar, and I discover that for my small and intermittent uses I’m better off with my own generator, would that still be allowed, or outlawed?

  47. floodguy Avatar

    One industry example of a successful DR program.

    Demand Response Award Winner
    Unilever Foods North America
    Unilever’s margarine-manufacturing plant has adjusted HVAC temperatures, turned off non-essential lights and equipment, and explored a pre-cooling process that allows them to turn off an ammonia refrigeration line on high-demand days. Average demand reduction has been approximately 300 KW – 25% of site demand. Unilever also installed a high-efficiency boiler, replaced metal halide with high bay linear fluorescent fixtures, and initiated rigorous energy conservation. The company has been a consistent participant in PG&E and CPP demand response programs. Unilever voluntarily participated in a PG&E integrated audit and is currently pursuing the incentive applications that the auditors recommended.

    Example websites from utilities regarding the a/c switches I mentioned.

    NOVEC (NOVA electric coopoerative)

    San Jacquin (CA)

    PG&E (CA)

    I am also seeing more articles about the importance DR will play with renewables. Due to their intermittent nature, solar and esp. wind, will require DR to keep the supply stable, especially the more such renewables increase in overall capacity.

  48. Larry Gross Avatar
    Larry Gross

    I think the comparisons between Virginia’s Rural Electric Cooperatives and their conservation initiatives and Dominions general lack of such initiatives – telling.

    The RECs with the exception of one all buy their power rather than produce it and so it helps them and their customers to NOT buy any more peak power than they must so that’s why they offer the water heater load management programs as well as other programs to reduce consumption.

    Why does Dominion not at least offer equivalent programs?

    RH sez that it’s wrong for the government to mandate that you must buy something.

    But, he’s wrong because the government CAN and does do this if it has determined that it is in the public interest.

    RH says that people should be the ones to decide what to buy .. but if people did this.. they’d buy and use DDT and/or not buy cars with pollution equipment, use lead paint, and smoke cigarettes in hospitals….

    so the government can and does mandate what people can buy – based on the public interest.

    By giving Dominion a guaranteed return “safety net”, Virginia is not only committing future Virginians to possibly pay for plants determined to be obsolete but they remove all risk from Dominion choosing such a technology instead of Dominion having have a forward looking strategy with respect to their investors.

    This is why Dominion is such a cash-cow investment.

    No matter what decisions they make about the future – their bets are automatically covered.

    This is not good public policy but it’s actually not in Dominion’s best interests either because instead of being a leader in embracing new technology -they’re invested in .. essentially.. the status quo and attempting to stop change from happening.

    They’re doing the very thing that most monopolies do that in the end in their downfall… similar to American Car companies that firmly believed that their foreign competition would never challenge them.

    Energy efficient entrepreneurs will “back door” the next 10-20 years… selling energy efficient homes and systems that incorporate computer control technologies and perhaps even solar to reduce consumption.

    Technology especially computer control technology is moving at light speed. The tipping point for home systems might even come sooner than 10 or 20 years…

    who knows.. what is on the horizon?

    but I do reluctantly agree with RH – Dominion has a direct responsibility to provide adequate power to everyone – no matter who wants more “green” and if they fail that mandate – even the “greenies” will be after their hide…

  49. Jim Bacon Avatar
    Jim Bacon

    Floodguy, a number of Virginia manufacturers are stellar examples of what industry can do to conserve electricity, too. I was a judge for the Governor’s Environmental Excellence Awards and reviewed several impresssive programs where companies conserve energy, conserve water and recycle. Unfortunately, I was not allowed to keep the award submissions, or I would have happily blogged about them.

  50. Anonymous Avatar

    “so the government can and does mandate what people can buy – based on the public interest.”

    So did the Soviets. From each according to his means, to each according to their needs, to “the public” first, no matter what it costs. If you can’t see the economic disaster lurking in there, then God help us.


    “RH sez that it’s wrong for the government to mandate that you must buy something.

    But, he’s wrong because the government CAN and does do this if it has determined that it is in the public interest.”


    You are misquoting me again. I actually think it is alright for the government to require that we pay for things that are in the public interest.

    But I insist on a VERY high, and concistent, standard of how the public interst is defined and measured. You accuse me of supporting DDT, PCB and lead paint, etc. when I actually think those things are pretty well prohibited because it is proven they are NOT in the public interest.

    For the most part, these meet the standard. (There are some specialized applications for which coatings which include lead are still the best technology available, and unlike lead housepaint, they are small in use volume and remote from places where it is likely to be ingested. It’s not a major deal, unless you have need of that application, but it is an other example of how mandates sometimes wind up with unintended consequences.)

    And I suggest that it (the public interest) changes over time, so that what we think is in the public interest today, might not be tomorrow. Therefore, government mandates need to have required review cycles. Unfortunately, once a law is in place it is next to impossible to get it undone, even when it is clearly wrong.


    I think we have (at least historically) struck a deal with utilities that says “You get a monopoly, but you don’t get to charge monopoly prices: we control your rate of return, and we guarantee that it will be “reasonable”. In doing so, we agree to share part of your risk: the risk that you will overinvest, and that means we get some oversight in your investments.”

    It is one thing to require that Dominon offer DR services: that might be a legitimate means of oversight. It is something else again to require that customers buy and use the services, even if they don’t meet their needs or provide any savings to them.

    What’s going on here is that some activists are latching on to PART of that agreement and saying it is unfair. What’s unfair is to not consider the whole agreement and all its ramifications.

    Either that, or we are complaining that those doing the oversight don’t see things the way we do. But they are part of the elected goverment, so we have no one to blame for this but ourselves.

    Certainly, nobody can deplore the examples given where significant energy savings are made, especially when the investments benefit those that make the investments. But it starts getting murky when private investments are required solely to benefit someone else in “the public”.

    Then, you have crossed the point at which you are “taking” private property for public benefit, and then it is appropriate to have compensation. Unfortuantely, some people will regard such “incentives” to be subsidies, and then we get right back intothe mire of what is actually a public benefit.

    That is why I think it is appropriate that a public benefit be defined such that it only exists when the “winners” can pay off the “losers” and still come out ahead.

    If you have a company that made a million a year before the mandate, and half million a year after, then it shuld be pretty clear what his losses are. If the winners are basing their claims on some far into the future intangibles, they might have a problem with and object to, making good on the losses.

    What this means, when it happens, is that maybe they are not so sure about the public benefit, after all. When you suddenly have to pay for something that you thought you were going to get for free, things look a lttle different.

    It is the same problem, and based on the same issue as, what we call property rights. The only people who are against property rights are those that think they can get something for nothing by diminishing them.

    Instead, what happens is that more and more property is considered to be public. Then it gets harder and murkier to figure out what the public benefit is, because since more and more property is considered public, the public winds up stealing from itself.


  51. Anonymous Avatar

    The short way of saying this is that if I’m required to spend $800 to install a smart meter and it winds up saving me ten dollars a year, then I have a problem with that. If it saves me $80 a year, then not so much.

    I have the same right to a reasonable return as anyone else, including dominion.

    On the other hand, if the meter saves “the public” $80 a year then either they should pay for the meter, or they should pay me the $80 return. If it saves the “public” $100 a year and they pay me $80, so much the better.

    If it save me $80 and them $100, then we both win, but I’m likely to want to renegotiate what we think is a reasonable return.


  52. floodguy Avatar

    RH – for the last time, an ac smart switch won’t cost you a dime, and you won’t get paid a dime for it either. However, the more folks like you and I who install these switches, you can be assured, it will decrease (albiet small) the cost of kwh everyone is charged.

    More importantly, what you’ll do by having an ac smart switch is allow your electricity provider to manage the most costliest period of electricity management. Your utility’s inability to decrease this high energy period will cause grid expansion. This is what has happened from NOVA north to NYC and is the primary reason why you may end up with 500 kilovolts worth of buzzing high voltage on your property, and why Wise County will turn grey from soot.

  53. Anonymous Avatar

    According to a recent nespaper article on Smartmeters they were forecst to cost $400 to $800 dollars and the utility comapny would bill the cost as a surcharge on your bill.

    Even if it won’t cost me a dime and I don’t make a dime, as you claim, why would I put up with the (possible) incnvenience?

    The whole point of this is to:

    a) reduce the (albeit small) cost of electricity to everyone. Presumably that includes me.


    b) reduce GHG which also benefits everyone.

    But what I hear you saying is that it won’t cost me a dime, I won’t make a dime, and it is still better for everybody. Everybody then, gets something for nothing.

    That sounds an awful lot like snake oil, to me. I don’t know of any way that can happen, have never seen it happen, and it sounds like a lie or a slick sales job.

    I agree with all you are trying to say, but I hate the way you say it, and present it. I don’t think it is a useful way to sell your idea, it is incomplete, and appears to be dishonest. That doesn’t mean I don’t think the underlying idea is good.

    Instead show me an accurate estimate of the costs, tell me who will pay the costs, what the benefits are, who will get the benefits, and how the disparities will be addressed. That seems pretty simple, straightforward, and honest, as opposed to snake oil.

    If you can show me that producing less electricity will actually give me a lower price, then I’m interested. If we can agree on how much benefit we get from lower morbidity and mortality from GHG, then we can afford to spend that much, and no more, on reducing GHG, and even then, only if we can’t get more benefit from lowered morbidity and mortality from something else that costs less (like swimming pool covers for example).

    What I’m telling you is that people are very bad at translating probability into a prudent course of action. It gets even worse when politics and geography and benefits to future generations are involved.


    The primary reason why I may end up with 500 kilovolts worth of buzzing high voltage on my property is that we do not have strong property rights. If we did, Dominion would be required to pay me a fair price for my property, and it would no longer be mine to worry about.

    The fair price paid for my property and hundreds of others would be added to the bills of those that use electricity, and they would get the benefit of the elctricity they need. I would get the benefit of property of equal value, someplace else.

    See how it works? Nobody pays for anything they don’t get, nobody gets anything for free, nobody gets totally screwed.


  54. floodguy Avatar

    RH – if you are involved or affected by the new 500kv line, then you know how complex power systems are. The questions never end.


    The cost of ac smart switches installed on all your neighbors a/c units, are charged to the utility’s customer base, no different than new generation or expansion would. If you are in a VA electric co-op, you helped pay for both of my smart switches already. Thank you but I bet you didn’t notice?

    If you decide to get one, I’ll be happy to help pay for ours, because the price for this type of grid improvement, is cheaper than grid expansion, generation or transmission.


    What causes grid expansion? Simply put, demand for electricity during the summertime and its warmest days during the year is the primary cause. These days are numbered usually about 10 to 20 days a year and that’s all, maybe even less.

    Lets say NOVA needed 11,000MW during the 10-20 days hottest days during the months of June, July, and August b/n 2 to 6pm in 2007. This timeframe is by far the highest period in demand for electricity & a/c. This is termed peak demand, and nobody knows except for God and Al Gore what days peak demand will be the highest.

    Keeping it simple, on cooler, cloudy or rainy summer days, and during the evenings, and during the spring, lets say demand in NOVA fell back to appx to 8,000 MWs in 2007. Lets call this level of usage, baseline demand.

    As the populations grows and more development is constructed in NOVA, both peak demand and baseline demand will obviously increase, so lets say in 2008, growth for both types of demand will increase by an even 10%, so that peak is 12,100MW and baseline is 8,800MW this year.

    Simply put, utilities in NOVA have to supply 12,110 MW this summer to met the peak demand which they have no idea what day this will occur. But if utilities only have enough to meet the 11,800MW, they need to obtain add’l 310MW in new generation for the expected peak usage or curtail demand back 310MW b/n 2pm and 6pm. The baseline demand of 8,800 is still met and the extra capacity during these times, runs idle on standby or is shut down. FOr actual demand # check out DVP website.

    This is the main reason for grid expansion and since air-conditioning accounts for the primary increase of demand during 2pm-6pm, gaining control of its usage is a primary way to manage peak demand. By control I mean energy star appliances, programmible thermostats, and of course smart ac switches.

    Now, combine NOVA’s peak demand with DC-MD metro, Baltimore, Philly, NJ, and NYC, because together the I-95 corridor is the heaviest energy load in the nation, and since we are all tied together in one grid, what goes on north of DC, does matter to places like Wise County, Va.

    Combine this relationship, thanks to the PJM, and the exporting of power from two 500kv transmission lines from NJ to Long Island, the decommissioning of 8 powerplants, 2 in DC and 1 coming in Alexandria (most of which are used solely for peak demand, aka peaking generators), and a new proposed 500kv transmission from Woodbridge, VA to south Jersey, now you get the picture why all this grid expansion is taking place.

    Another ball-kicker is the fact that since 2000, 100% of Virginia’s expansion in generation, 1800 MW, occurred in Prince William and Culpeper counties for NOVA.

    Dominion told everyone these powerplants are for Virginians. The Meadow Brook to Loudoun which was just proposed in Nov 2006, we are told is to supply power from a Eastern WV coal-plant which only runs part of the time, for NOVA. But in Nov 2007, PJM decided to export the same amount of electricity as this powerline, to South Jersey via a 2nd powerline originating at the Possom Point power station.

    Now because of its own peak demand, Virginia will now need a plants in Wise County and other in Caroline Co, because what we had is being shippped to the north. In the 2016-2020 timeframe, baseline demand will be met with the North Anna expansion, well that’s what DVP and PJM has been telling everyone as of last year.

    So you see RH, this is complex even w/o even discussing EEC or global warming.

    Look up Virginia’s Energy Plan 2007 Section 3.

    Check out the state of CA EEC site

    Dont’ trust the folks in Cali, then go to the Dept of Energy, FERC, look up the words NAPEE, NARUC, PLEM. Read the Energy Security and Indy Act of 2007, Energy Act of 2005. Check out the EIA for endless stats. The PJM is important. The DOE’s Demand Response Coordinating Committee is nice. See Piedmont Enviro Counsel’s expert testimony on EEC by Violette. That guy is top notch. Public traded DR & EEC companies Comverge, EnerNoc, Echelon, ESCO, Itron.

    Virginia isn’t Arizona nor North Dakota so I can’t see solar arrays and windmills onshore or in the bay, doing anything more for our state then fulfilling the wishes of the enviro-supported RPS. Maybe the plan for 300,000 3mw turbines 12 miles offshore will work! Converting old tobacco files for bimoass production would be nice but just how many acres can we spare for this when the price of commodities is going thru the roof?

    All we have in our state is nuclear, coal and a 50th ranking in energy conservation.

    The solutions: more nuclear & clean coal power plants, and energy efficiency and conservation. And since no one is going to be happy with more nuclear & clean coal plants, why not make EEC the top ranked energy solution, YESTERDAY?

  55. Anonymous Avatar

    “why not make EEC the top ranked energy solution, YESTERDAY?”

    Because seven years from now we will have squeezed all the EEC juice out of that turnip.

    Then what?

    We will lbe rright back where we are now with the same arguments, no solutions, and no slack left to play with.

    EEC is fine, so far as it goes. Lets not make it sound like something it isn’t.


  56. Larry Gross Avatar
    Larry Gross

    If we followed your logic – no efficiency improvement would be “worth it” because we’d be taking all the “slack” out of the equation and then be at a dead end… for further improvement..

    have you every heard of “innovation”.

    Innovation is when things like cars come along and replace horses..

    and I’d compare this to someone saying that wagon wheels should not be improved because if we improve them then we no longer will have any way to further improve them…

    well….. DOH!

    this is advocacy of the status quo and opposition to change.. because we cannot imagine how thing could be different … and better…

    It’s like ten years ago saying that hybrid cars would “never work” and that even if they did.. it would harm the interests of those who wanted to stay with conventional cars. (like not being able to use HOV).

    and today.. it’s arguing that plug-in cars won’t work and even in they did.. they should not be used until we figure out ALL the benefits and costs…(because they won’t be paying gas taxes).

    I’d only say that innovation and technology don’t follow these rules…

    You cannot OUTLAW plug-in hybrids even if they disrupt the current status-quo.

    Change IS .. GOING TO HAPPEN .. whether we, as individuals, think it will happen or not or whether it will harm existing interests or not.

    so those that accept realities with respect to innovation and change.. embrace and adapt are much happier and successful than those opposing it – cuz.. it’s a losing battle…

    “Rebels Against the Future

    Witnessing the birth of the global anti-technology movement”

  57. Anonymous Avatar

    “If we followed your logic – no efficiency improvement would be “worth it” “

    Not at all. Airplanes now use dynamic automatic controls because they allow for more efficiency. I don’t think that is too different from the controls being considered here.

    But then look at the extreme case: eventually you get to the point where the airplane can no longer be flown by hand: it depends on a razor thin margin of error that can only be controlled by computer.

    Here is the problem as I see it. We can’t agree on Nukes, We can’t agree on coal, We don’t yet have working renewables in bulk. We can’t agree on property rights, whether we are talking about transmission lines, or exporting pollution to another region, or Dominions right to be able to plan their investments. —- So, we figure we can buy some time with EEC.

    Great. Then six years from now you still have to face the same problem, but now you have no remaining slack or cusion in your peak load problem. (Remember how Matt said the idea was to save energy from one group and sell it to another….)So, you have collected and sold off all your efficiency gains, and you still have the same problems because you never solved them or faced up to the real issues. We’ll be flying on the edge of control, waiting for the computer to crash.

    Is there disruptive technology? Sure, but EEC isn’t that, it’s just common sense (AS LONG AS IT MAKES SENSE.) It also isn’t the solution to our problems, it is a stopgap. And, it is not repeatable: you can’t get to zero by making 10% reductions.

    “Innovation is when things like cars come along and replace horses..”

    Right, so innovation is when you replace a hundred million tons of nitrate bearing manure that washes into our streams with a hundred million tons of nitrate bearing exhaust gas that washes into our streams. A horsepower is a horsepower and chemistry is chemistry.

    Last I knew, conservation of matter and energy still holds. And yet people still continue to think we can get something new and better for nothing.

    Sure, we can improve wagon wheels. We just can’t defy physics and chemistry doing it. We can make incremental improvements in almost any process or product, and each one will necessarily cost more than the last one. After you pick the low hanging fruit, you are still going to need a ladder: you might as well plan on it.

    There is no denying that a wagon wheel that is round to .0000001 is better than one that is round to .001. From a practical standpoint, so what? Are we really going to mandate production to a higher standard just because not doing so means we will use more energy, and the externality of that is that everyone pays more for energy: Dammit, let those who use wagon wheels should pay their full costs, other wise they are daamaging me.

    Never mind that the cost of .000001 wagon wheels is a hundred times the cost of the energy they save.

    One of my engineer friends was talking about this recently: “Most people just don’t understand trades. Not the ones they make, and especially not the ones they miss.” We are terrible at making cost effective risk assessments in the faace of multiple probabilities. And the problem is worse when distance and time are involved.

    (I had a set of plans for a working Hybrid car thirty years ago. What I didn’t have was the time and resources and capital to build the thing. It was worth waiting thirty years because Toyota did it better and cheaper than I ever could have. But, let’s not forget, if we just took the electric motor and batteries out of the Prius it would get BETTER mileage than it does now. But you would give up on having the same performance. You don’t get something for nothing, even with a hybrid. Plug in Hybrids won’t be paying gas taxes, half of their energy will be lost in transmission, and the pollution they cause will be exported: I don’t see any reason not to think carefully about such things.)

    Whatever “solutions” we come up with for inequities we discover should be similar to solutions for inequites we discover in other areas: we need a free and fair market in externalities, otherwise your idea of a free market is just a perverse kind of market distortion: the kind you happen to favor.

    So yeah, I could have had my hybrid or my .0000001 wagon wheels thirty years ago.

    It would have been a waste. We could have mandated them then, and maybe technology would have developed sooner. Or, maybe it would have turned out like airbags: $320 million per life saved.

    I believe in the sanctitiy of life as much as anyone, but I know there is a difference between paying for sanctity and paying for life.

    I don’t have any problem with what you and Matt and Floodguy are proposing, but I think YOU need to bear the burden of proof. It is YOUR idea. YOU are the one claiming it will save US money, morbidity and death. I’m perfectly weilling to believe you, and even to sign the contract.

    But,First you tell me it will save me money. Then you say it won’t save me any and won’t cost any, but it will still save everyone. And now we see that smart switches are added to the investment base (just like a generator, Dominion is guranteed a return) and I will pay for them in my base rate.

    Even though I have no AC to conserve on. If I had the LG attitude I’d say that’s not right: they are imposing costs for their decisions on me. Let the people who want smart meters buy their own, and pay for them themselves.

    If you want me to sign up to your contract just because you claim it is for the public benefit, you need to be able to prove it (and prove the benefits are fairly distributed), or I won’t sign.

    And I’m on your side. Imagine what it is going to take to get someone to sign up who doesn’t give a flying fig.

    I just want the full terms and conditions, and I want to see the fine print. I won’t sign up to any Gross Generalizations.


  58. Larry Gross Avatar
    Larry Gross

    re: convincing folks who don’t give a fig.

    No problem. You just charge them what they should have been paying to start with…

    and figuring out how much is not a problem…

    do you think they went through that exhaustive analysis when they decided what the tax on cigarettes would be?

    do you think cigarette smokers will be able to sue the government for “unfair” taxes?

    I’m only pointing out to you that the Government does not need to “prove” anything to you..

    they can mandate it based on what they think is in the public interest.

    All you get.. if the opportunity at the hearing or in your written comments to call them nasty names..


    so.. if enough folks support peak hour pricing and/or green energy.. even costly green energy.. guess what – you get outvoted….

    Now.. if you are a pragmatic person – you’ll accept the fact that the status quo CAN and will be changed without any analysis that “proves” that it is warranted…

    no different than how the status quo came to be in the first place… not with exhaustive studies that “proved” the status quo was the best path but merely special interests affecting decisions….

    so who is to say that environmental “special interests” are any better or worse than other kinds of “special interests”?

    I’m not advocating NOT doing due diligence on any issue but due diligence does not mean that you must prove something that may not even be provable before you can change it…

    If we did things the way you advocate no new law could be passed until the evidence for it’s legitimacy was irrefutable…

    sorta like the cigarette companies who demanded that absolute proof be provided before putting cancer warnings on cigarettes.

  59. Anonymous Avatar

    “You just charge them what they should have been paying to start with…”

    How do you figure what that is, and when do you start?

    “and figuring out how much is not a problem…”

    Because you don’t care, you just want the money.

    “do you think they went through that exhaustive analysis when they decided what the tax on cigarettes would be?”

    Of course not, they did it empirically. they will stop rasing the tax whenit starts bringing in less money.

    “do you think cigarette smokers will be able to sue the government for “unfair” taxes?”

    That depends. Originally the idea was to use the money from cigarette taxes to offset the additional costs to the healthcare system caused by smokers.

    If it turns out that smokers are paying far more than their costs tothe healthcare system, they might have a case. If not a legal one, a moral one. What is our basis for taxing smokers for more than their cost?

    The way things are gong in healthcare, smokers may be SAVING us money by dying early. Not to mention the environmental savings from all that reduction in environmental footprint.

    “I’m only pointing out to you that the Government does not need to “prove” anything to you.. “

    Actually, they do. It’s the law.

    “they can mandate it based on what they think is in the public interest.”

    Yes, but every individual and corporation has a right to input in that process, and no individual may be unfarily burdened by it. It is the law.

    What you are really saying is that they can make bad decisions, depending on how they think. That is bad law, bad policy, and bad public administration.

    Whatever the public interest is, ought ot be measurable, other wise you have no basis to claim or prove that a particular policy IS in the public interest. And, once measured, the oppositon should be allowed to use the same parameters, either for or against the same or different policies.

    “if you are a pragmatic person – you’ll accept the fact that the status quo CAN and will be changed without any analysis that “proves” that it is warranted…”

    Pragmatically I accept that. Ethically it makes me want to puke in your face.

    “who is to say that environmental “special interests” are any better or worse than other kinds of “special interests”?”

    Not me. I claim they are exactly equal and should have equal scrutiny, equal burdens of proof, equal values applied, and they should be reviewed regularly.

    I claim either one can cause unwarranted and unjustified damage to the public benefit, and the environment.

    “due diligence does not mean that you must prove something that may not even be provable before you can change it…”

    It also doesn’t mean you can put the other side in the position of having to prove a negative.

    If you have something that is not provable, how can you claim it is for, (or against) the public benefit?

    God knows we have enough stuff that is provable. Maybe the FDA should be running the EPA. They don’t seem to have any problem making life or death trades, and doing it fairly well.

    “if enough folks support peak hour pricing and/or green energy.. even costly green energy.. guess what – you get outvoted….”

    Yeah, so they win the vote and they lose the argument it is for the public good. I hope they can sleep at night.

    “If we did things the way you advocate no new law could be passed until the evidence for it’s legitimacy was irrefutable… “

    Pretty much, but then, I have high standards.

    “sorta like the cigarette companies who demanded that absolute proof be provided before putting cancer warnings on cigarettes.”

    Case in point. A law demanding cancer warnings, and all the paper that produced, really made a lot of sense. I’m not sure if its legitimacy was irrefutable or just irrelevant. It didn’t solve the problem.


  60. Larry Gross Avatar
    Larry Gross

    Yes – the government must listen to comments .. but they only have to respond or give responses to SUBSTANTIVE comments.

    SUBSTANTIVE means that your comments are dealing with errors of acknowledged fact – as opposed to your own idea of how the world should work.

    So.. for instance, you are free to claim that cigarette smokers pay more in taxes than their health care costs because they die early .. but you won’t get a response if the facts don’t support your claim.

    Further – the basic idea of taxing cigarette smokers doesn’t have to have anything to do with health care per se – but instead the criteria used is that it causes such harm that we want to change behaviors with penalties…

    pretty much the same way that a speeding ticket is NOT tied to any demonstrable cause/effect harm so you get a $100 ticket for 10 mph over the limit and a $200 ticket for 19mph over the limit and a reckless driving ticket for 20mph over the limit.

    There is no study to “prove” anything. The charges are purely arbitrary penalties designed to cause you significant enough economic damage to deter you from that behavior.

    Now.. you can disagree with this concept..but again I’m only pointing out – once again – that the government does not need to prove to you – what you think should be proved… before they make a decision.

    they have to listen – yes and if a whole bunch of people object – they can reconsider AKA abuser fees.. but you don’t see them doing away with DUI fines because no one has proved a one-to-one cause/effect that merits a certain dollar amount for the fine.


    And if they can do this with speeding tickets and cigarettes, they can.. and DO this with other laws and rules – all the time.

  61. Anonymous Avatar

    Actually substantive just means real or based in fact rather than imaginary or epehemeral. No errors of preveiously acknowledged fact need be claimed. The problem is, there are a lot of ephemeral versions of relity out there, so we come down to a question of HOW substantive.

    But based in reality, means based in reality. You have sometimes indicated that the perceived risks of environmental problems are so high that they should have the benefit of the doubt.

    I’m not suggesting I disagree, but there shoudl be standards for how much benefit and how much doubt. And, when the tables are turned, we should accept the same standards as we ask for.

    The farther you get into probabilities and doubt, the farther you are from substantive. Which is not to say that you cannot have good tight statistics and make reasonable extrapolations.

    As a matter of policy, the FAA works at a level of probabilty of “6 nines”. If you don’t like a rule they have, you can propose an alternate procedure: as long as you can show the result of your procedure is 6 nines, they are likely to approve it.

    I don’t think that having standards as a matter of policy is necesarily a bad thing, but we still manage to come up with some lousy standards.


    “for instance, you are free to claim that cigarette smokers pay more in taxes than their health care costs because they die early .. but you won’t get a response if the facts don’t support your claim.”

    Exactly correct. You won;t get any argument from me.


    “the basic idea of taxing cigarette smokers doesn’t have to have anything to do with health care per se – but instead the criteria used is that it causes such harm that we want to change behaviors with penalties…”

    Now you may have stepped off the deep end. What harm are you talking about? Second hand smoke? Accidents caused while looking for a cigarette? Fires caused by smoking in bed? Whatever it is, I assume you mean harm to someone else, otherwise, why try to recover the costs. See, I don;t think this is penalizing the smokers, I think this is protecting our property rights.

    If it is a matter of penalizing smokers then we can charge whatever we want (within the confines of due process). There really is no limit as to what we can do or to whom, once you go down this path.

    But if it is a matter of protecting your property rights, then we really can’t charge them more than they cost us.

    “pretty much the same way that a speeding ticket is NOT tied to any demonstrable cause/effect harm”

    Well, now that’s a problem, isn’t it? Why are we ticketing people if there is no harm done?

    (Actually, I think we know that speed is a factor in accidents, and accidents cause harm. Furthermore, this is an area wher we have a LOT of very good statistics. My position would be that we damn well OUGHT to be able to tie speeding to harm, and apply the penalties accordingly.)

    “The charges are purely arbitrary penalties ” That really is a problem, in my book. We ought not to treat people arbitrarily. Especially not under the law.

    “the government does not need to prove to you – what you think should be proved… before they make a decision.”

    And THAT is a VERY big problem, in my book. Exept, they don’t have to prove anything to me: my standards or expectations may be unreasonable.

    The government does have an obligation to make that proof to the public, and to a reasonable standard of certainty. Frequently, the government ignores that obligation, or persons within the government use their position to support their views. They may have deliberately acquired that position for this purpose.

    We know that a high percentage of pedophiles attempt to become schoolteachers, and we recognize that as a bad thing……

    If a government official goes into a job predisposed one way or another, then takes an oath of office to uphold the law equally, we have a problem. I don’t think that problem is too uncommon.

    They can do as they please with laws and rules – all the time: they get to decide what is and isn’t “substantive”.

    We should grub out that kind of behavior out ruthlessly, and beat it with a stick. Even if it supports “our political position”.

    That kind of behavior and decision making is wrong, and it will cause us more harm than we benefit from having “our side” win.


  62. Larry Gross Avatar
    Larry Gross

    the point of public hearings and receiving comments is to hear from you on what your idea is with respect to a proposal…

    .. and then from everyone else…

    and then to compile substantive “evidence” and from that to make “findings” from which to base “decisions”.

    so they’ll hear from BOTH you .. and I… and if we both make unsubstantiated claims.. they both get ignored – then there is the other possibilities…of one making a good case and the other not such a good case.. and then 100 other folks making good cases and not so good cases… so on and so forth.

    so we outlaw texting ( or reading a newspaper or picking your nose, whatever) on cell phones NOT because we can prove without a a doubt – the 9 sixes rule.. that the “cost” of texting is MORE than the cost of accidents caused by texting.

    because.. HOW would you EVER be able to prove that the VALUE of the texting was MORE than the accidents that MIGHT be caused ?

    and that’s the way that many issues are – in reality.

    This is no reasonable way to measure and compare the ROI…a binary circumstance.

    Note the laws are not based on how much or what kind or how long or any of dozens of other measurements that are quite different from either texting or not texting.

    so .. you’ve been asserting that we should not change the status quo unless we can “prove” things that really are mostly not provable and you’ve also been asserting that the Status Quo IS based on provable metrics – and they are not either.

    So change happens, often for reasons other than the 6 nines.

    The 6 nines is government shorthand which says in essence “we have determined” but we will reverse if you can show that it is virtually certain that we are wrong.

    So the burden of “proving” is on you – not the government.

    The government can and does go through a process that allows you to challenge them on the facts – but the burden is also on you to provide such facts – to the degree – that they are so convincing that they cannot be ignored.

    so this is very different than the government having to prove to you that proposals for change from the status quo meet YOUR own arbitrary (not demonstrable as fact) criteria for ROI.

    You CAN however sue the government for an arbitrary and capricious decision if you can prove that it is.

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