Tag Archives: CVOW

Youngkin Endorses Dominion Wind Project

by Steve Haner

Republican Governor Glenn Youngkin’s administration has filed a letter with the State Corporation Commission asking the regulators to approve the Dominion Energy Virginia application to build a 176-turbine Coastal Virginia Offshore Wind (CVOW) project.

The letter was on Department of Energy letterhead and signed by that agency’s director, John Warren, a holdover from the Democratic Ralph Northam administration. Continue reading

Miyares Challenges Secrecy in Dominion Wind Case

The Luxembourg-flagged Vole Au Vent is seen here installing one of Dominion Energy’s two experimental wind turbines 27 miles off the Virginia coast.

by Steve Haner

Virginia Attorney General Jason Miyares (R) has moved to open to public inspection much of the secret data and analysis about Dominion Energy Virginia’s proposed Coastal Virginia Offshore Wind project. His petition filed with the State Corporation Commission April 29 comes about two weeks before formal hearings on the application begin in mid-May. Continue reading

SCC Asked for Hearing on Secret Renewables Costs

by Steve Haner

Appalachian Power Company has asked the State Corporation Commission to schedule a separate hearing on Attorney General Jason Miyares’ motion to break the seal on exhibits in its application for new renewable energy sources.

Miyares’ April 6 motion was first reported by Bacon’s Rebellion, in a story on Appalachian’s pending application for approval of the projects and of its overall plan for complying with the Virginia Clean Economy Act (VCEA). Appalachian’s response motion was filed April 13, claiming irreparable harm to its stockholders if the actual line-by-line project cost projections were revealed to its customers.

Although some of these discrete items may appear innocuous on their own, collectively they would enable a savvy party to discern the price paid for the facility, which is competitively sensitive.

What do they say in swanky restaurants? If you have to ask the price, you cannot afford it. Revelations could be politically sensitive, as well, given the partisan divide on the VCEA itself. Continue reading

SCC Staff: Dominion May Exceed Wind Cost Cap

A schematic from the application for the proposed 14.7 megawatt turbines for the CVOW, with measurements. Click for larger view.

by Steve Haner

A similar article was published this morning by the Thomas Jefferson Institute for Public Policy.

Testimony filed by the State Corporation Commission staff on April 8 opened a slight possibility that the Commission could reject Dominion Energy Virginia’s proposed $10 billion Coastal Virginia Offshore Wind project off Virginia Beach. It all depends on how the SCC decides to calculate the CVOW’s levelized cost of energy (LCOE), the dollar cost of every megawatt hour of electricity it produces plus the transmission costs.

When the 2020 General Assembly adopted the Virginia Clean Economy Act and related legislation, it set a cap on that key LCOE measure, which is used to compare the costs of various methods of making electricity.

If the utility failed to stay under the LCOE cap, the SCC would have the authority to reject the proposal as imprudent and unreasonable. If the project remains below the cap, legislators mandated approval by the SCC, despite any other doubts about its prudence and without considering less expensive alternatives.

The cap set was $125 per megawatt hour, after deducting the value of the very large tax credits granted for wind projects under federal law. In the application it filed late last year to build the facility, Dominion estimated the LCOE (after the tax credits) at about $83 per megawatt hour. But Katya Kuleshova of the SCC’s Division of Public Utility Regulation challenged several of the assumptions in her testimony and noted that if the assumptions prove wrong, that number rises substantially. Continue reading

AG Expert: Wind Project Unneeded, Accounting Off

Exhibit submitted by Office of the Attorney General showing the excessive generation Dominion Energy will have compared to its expected demand, funded by ratepayers. The black line in the middle is the projected customer demand. Click for larger view.

by Steve Haner

There is no justification for Dominion’s $10 billion offshore wind project other than that the General Assembly has ordered it, a witness for Virginia’s Attorney General has testified. The utility doesn’t need its electricity, doesn’t need its renewable energy attributes, and is ignoring lower cost alternatives if it does need generation in the future. Further, its claims of economic benefit are based on faulty assumptions.

Virginia’s Attorney General Jason Miyares is the customers’ main representative at the table as the State Corporation Commission reviews this pending application. By law the AG office serves as Consumer Counsel in these matters.  Despite all the concerns raised in his expert’s review, Miyares is not recommending that the SCC reject the project.

In fact, as mentioned in an earlier Richmond Times-Dispatch review of the case testimony, no party so far has recommended that the SCC reject it. That was noted by a triumphant Dominion spokesman at the end of the newspaper’s story when it might properly have been the headline.

That is the headline at this stage of the case. The language inserted into the 2020 Virginia Clean Economy Act by Dominion and its environmentalist allies demands approval of the project without regard to proving necessity, reasonableness or prudence. The law orders the SCC to find the project prudent unless it misses a very high cost target or fails to have a plan to start operation by 2028. (Note, it doesn’t have to be in operation then, merely have a plan.) Continue reading

No Other State Plans Utility-Owned Wind Farms

Clean Virginia’s witness prepared this list of current U.S. offshore wind projects, their owners, size and contract structure. Click for larger view.

by Steve Haner

The table reproduced above may one of the most interesting exhibits submitted to the State Corporation Commission as it considers Dominion Energy Virginia’s offshore wind application. Two things jump out, both highlighted in pre-filed expert testimony sponsored by environmental activist group Clean Virginia.

First, only in Virginia is such a project being financed directly by the captive ratepayers of a monopoly electric utility. Only in Virginia will the turbines be owned by the utility rather than a private investor. Continue reading

Wind Case Spinning Up; Your Comments Sought

Yes, it is that big. Click for larger view, and note the on-shore transmission expansions.

by Steve Haner

In the coming weeks, Virginia’s State Corporation Commission takes up one of the largest utility investments ever undertaken in the Commonwealth, where the cost and the risk will rest squarely on Virginia’s citizens: Dominion Energy Virginia’s $10 billion Coastal Virginia Offshore Wind project.

In applications and appendices filed late last year, probably running to hundreds of thousands of words and hundreds of technical drawings, Dominion outlined its request to build the project 27 statute miles (24 nautical miles) off the mouth of Hampton Roads. The project area covers 176 square miles of seabed. It uses about one square mile for each of the planned 176 turbine towers. Continue reading

Key Data on Dominion Wind Project Still Secret

Cover page blocking public access to the engineering and cost details for Dominion’s proposed $10 billion plus Coastal Virginia Offshore Wind project.

By David Wojick

A previous article published by Bacon’s Rebellion and the Committee for a Constructive Tomorrow challenged the notion that Dominion Energy Virginia can build a huge amount of wind and solar generating capacity and retire all of its fossil-fueled generators with almost none of the enormous storage capacity that is required to make the renewables viable.

This proposed long-term plan does not work and Dominion knows that, but in the short run it can make billions in profit by building the unreliable wind and solar. The disastrous unreliability shows up only in the long run.   Continue reading

What Dominion is Hiding in its Wind Application

The cover page that declares we the ratepayers cannot see how Dominion Energy Virginia has calculated the levelized cost of energy for its $10 billion offshore wind project. The SCC should break this seal and open this document.

by Steve Haner

When an applicant at the State Corporation Commission claims certain information is proprietary, or extraordinarily sensitive, a reader not privy to the full document can at least get an idea what is missing.

What is missing from the application Dominion Energy Virginia recently filed at the SCC, a document so dense and complex it was broken into eleven volumes, with 61 separate documents (here)? (That is not counting the tables of contents.) Here are some of the topics masked from view that turned up in a cursory review (in the order they appear in the documents): Continue reading

Turbine Costs Appear on Dominion Bills in 2022?

Illustration of Dominion’s wind project from its Bureau of Ocean Energy Management documentation.

by Steve Haner

Customers of Dominion Energy Virginia will begin to pay for its planned 176 wind turbines off the coast of Virginia Beach next September, years before the first electricity is produced, if the company’s request for initial project funding is approved by the State Corporation Commission.

As with all such projects now, the bill will be paid through a specific addition to monthly bills, a rate adjustment clause or RAC. The cost for residential customers will work out to $1.45 per 1,000 kilowatt hours, but that is just for the first rate year beginning in 2022. In a news release Friday, the company claimed eventually the “net” cost to residential users would be $4 per 1,000 kWh, but that includes assumptions about future tax benefits and future costs of the alternatives abandoned.

The gross cost to consumers may be buried somewhere in the mound of Dominion documents that now constitute the full application. Or it may be among the items of data which the company seeks to withhold from public view.

On Friday, the record of the case was just a few cover letters and the company’s motion asking the SCC to let it keep much of the key information confidential.  Monday up to 40 (40!) additional documents were posted on the SCC’s case file, full of some details, but reviewing a table of contents one can see example after example of information redacted, in anticipation of SCC approval of the motion for secrecy. Continue reading

General Herring: Air All Data in Wind Application

Attorney General Mark R. Herring

An open letter to Virginia Attorney General Mark Herring:

Dear General Herring:

As was reported by the Richmond Times-Dispatch, Dominion Energy Virginia filed on Friday its application for approval to build offshore wind turbines with a nameplate capacity of 2,600 megawatts. The very first motion made to the State Corporation Commission was a request to keep all the important financial and engineering information confidential, away from public inspection.

I write as a Dominion customer and write to you in your statutory role as the representative for consumers before the SCC.  You are my lawyer.

Please do everything in your power to persuade the SCC to reject that motion for secrecy. On behalf of the people of Virginia, break that seal. I hope other likely parties in the case will join you, but you should take the lead. There is no justification for hiding all the reams of information which will be produced in the coming review, and which will have a direct impact on the cost and reliability of our electricity for decades to come.

Waiting until the smoke had cleared from the recent election, in which the company embarrassed itself, the announcement included an admission that the price of the proposed project has already risen more than 20% to almost $10 billion.

There has long been too much secrecy in the SCC’s cases, a complaint I have aired several times in various forums. This has been accompanied by a reduction in the amount of attention given to these matters in the traditional news media, with the most active news source these days hardly objective but instead a cheerleader for this unreliable, intermittent electricity source. Continue reading

SCC Starts Review of Dominion Wind Proposal

by Steve Haner

Acting on its own initiative, the State Corporation Commission has established a docket to consider the coming application from Dominion Energy Virginia for its massive offshore wind proposal, the centerpiece of Virginia Democrats’ plan to save us all from catastrophic climate change.

Earlier this month, the utility started the federal review process with a notice of intent to prepare an environmental impact statement for the project. The clock on the first round of comments to the Bureau of Ocean Energy Management runs out August 2.

If Dominion builds all future planned phases, a full 5,200 megawatts, the sticker price is more than $17 billion, which with profit and financing costs will ding customers in total $37 billion over a few decades. Continue reading

Virginia’s Latest Folly – Offshore Wind Power

Crews install turbine foundations for the Coastal Virginia Offshore Wind pilot project. Image source: Energy News Network

by David Wojick

Dominion Energy is planning to begin construction on 2,600 MW of offshore wind generating capacity within the next few years. The wind farm planned off the cost of Virginia Beach would be the largest offshore project in the United States. We are talking about something like 220 giant windmills, embedded in the ocean floor and sticking hundreds of feet into the air above the water. They will be on the order of one and a half times taller than the Washington Monument, which is really tall.

Two features make this offshore wind plan a folly — too little wind and too much wind. Let’s look at too little wind first.

The proposed site is around 30 miles offshore of the giant Norfolk naval complex. Sites are usually much closer in than this, but maybe the Navy told them to keep their distance. Or perhaps they are out beyond the very busy shipping lanes. Every ship from Central and South America, or the southeast U.S., headed for ports from Baltimore north to Canada, passes through this area. This in itself is a concern but not one we are looking at now.

The problem is that this area frequently gets periods of a week or more when the wind is too low to generate any power. These are winds of 10 mph or less. Normal wind turbines require sustained wind of 33 mph or more to generate full power. Some new models with giant blades can do full power at just 23 mph. But neither generates much of anything at 10 mph. It is not a matter of no wind; low wind is enough. Continue reading

Imprudent, Unreasonable, Unnecessary, Approved

The State Corporation today found as a factual matter that the two-turbine Commonwealth of Virginia Offshore Wind (CVOW) demonstration project 27 miles off the coast is imprudent and places unreasonable costs and risks on Dominion Energy Virginia’s ratepayers.  It then approved the project citing the clear legislative mandate in an omnibus energy regulation bill passed earlier this year.

Other news outlets will provide the highlights, so focus on the words of the opinion from Commissioners Mark Christie and Judith Jagdmann:

“The Commission has considered the entire record. The Commission finds — as a purely factual matter based on this record — that the proposed CVOW Project would not be deemed prudent as that term has been applied by this Commission in its long history of public utility regulation or under any common application of the term. The Commission further finds, however, that as a matter of law the new statutes governing this case subordinate the factual analysis to the legislative intent….

 “As listed above, the General Assembly declared, in at least six separate locations, that a project such as CVOW is in the public interest. For specific purposes of offshore wind, the General Assembly further mandated that “the Commission shall liberally construe the provisions of this section.” In addition, the General Assembly made the new prudency proceeding in Code § 56-585.1:4 F merely voluntary.”

 “While we agree with the Sierra Club that, “the General Assembly wants this project,” we do not believe that the General Assembly has directed that facts regarding cost, need or other serious issues pertinent to a prudency petition should not even be developed or included in the factual record, if only for purposes of transparency. Nor do we rule herein as a matter of law that there can never be a set of facts regarding prudency that could overcome the multiple mandated public interest findings in the statutes. (Emphasis added.) There may be, but we need not speculate on which hypothetical factual record would be sufficient to overcome the governing statutes and require disapproval of the petition.”

In truth, it is hard to imagine a worse factual record, a worse example of wasting ratepayer money and imposing ratepayer risk.  For $300 million or more the company will receive only 12 megawatts of power and with the assumed operational efficiency of the turbines that will work out to 78 cents per kilowatt hour.  Then a hurricane may wreck it.

A few additional bullet points from the order’s text.  These are now findings of the Commission, not assertions by skeptics:

  •  Dominion’s ratepayers bear almost all the risk of a project design failure except for a limited amount of risk retained by the EPC contractor during the limited warranty period.
  • CVOW’s energy cost is 9.3 times greater than the average cost of the Vineyard Wind offshore wind project off the coast of Massachusetts, which is 8.40/kWh.
  • CVOW’s energy cost is 13.8 times greater than the cost of new solar facilities, which is 5.60/kWh.
  • The Company estimates that the construction cost of the larger scale offshore wind project would be approximately $1.77 billion, excluding financing costs.
  • The cost of energy from large-scale offshore wind is 13.10/kWh, which is also significantly costlier than several other conventional and renewable energy alternatives as listed above.

That $1.8 billion estimate for a larger wind field in the same location off Virginia Beach, and the estimated 13.1 cent per kWh energy cost, are numbers that had been held confidential during the proceedings.  But the demonstration project will not be using the same turbine technology planned for that larger project and will not have time to demonstrate much of anything before a decision is made on the larger project.

  • The Company asserts that it may seek additional cost recovery from customers if the Project exceeds $300 million.
  • Based on Dominion’s prior CVOW risk assessments, the contingency amount built into the projected $300 million appears low.

The order is very specific that only the $300 million initial estimate (excluding financing) is approved, leaving open the question of who pays for any cost overrun or how such an overrun might be treated in a future review of earnings and costs.   The $300 million plus financing is money that will not be available for future customer rebates.

To further drive home its point, the SCC also approved a Dominion request for a power purchase agreement for 80 megawatts of solar from a third party.  The news release paired the two announcements and highlighted that the other project is prudent, was competitively bid, and places the risk squarely on the shoulders of the third party provider.  The contrast is clear.

This Certainly Demonstrates Something (Don’t Ask)

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