Yes, Virginia, the EPA Is Still Cracking Down on You

EPA_CPP_and_Vaby Bill Tracy

Many folks are trying to interpret the Environmental Protection Agency’s final Clean Power Plan (CPP) and its impact on Virginia. The EPA, along with its August 3 rule announcement, released a large volume of on-line support material including the popular State-at-a-Glance Summary sheets.

Unfortunately, Virginia’s state summary sheet is misleading. EPA made relatively large adjustments to Virginia’s 2012 Base Case, not shown on the state summary sheet. The adjustments were necessary to account for natural gas power plants that were already under construction. The 2030 final targets for Virginia do not seem logical unless you compare them against EPA’s adjusted 2012 base numbers.

Fortunately, EPA does give us enough source data in the State Goal Visualizer spreadsheet to allow me to calculate the adjusted 2012 base, shown below, according to my math:

Carbon intensity (pounds of CO2 emission per megawatt/hour of electricity):
2012 lbs CO2/MWhr: 1,477
2012 lbs CO2/MWhr: 1,366 (EPA Adjusted 2012 Base)
2030 lbs CO2/MWhr: 934

Total CO2 emissions permitted:
2012 CO2 Short Tons Mass: 27,365,439
2012 CO2 Short Tons Mass: 35,733,501 (EPA Adjusted 2012 Base)
2030 CO2 Short Tons Mass: 27,433,111

Now we can see that Virginia’s mass CO2 reduction target (23.2%) makes a lot more sense. The actual degree-of-difficulty is better described by the carbon intensity data (CO2 per MWhr), and Virginia’s 934 lbs target works out to a 31.6% CO2 reduction mandate.

To see how Virginia compares, I’ve hand-entered the data for all 50 states and plotted them up (see the graph above). The first conclusion that jumps out is how well Virginia (in purple) is doing, already operating at relatively low CO2 emission rates. The second conclusion is that Virginia does indeed seem to fall above the trend line, with our 31.6% CO2 reduction target. A bit lower target (27.5% reduction) would appear more equitable, assuming my trend line is correct. Virginia’s final carbon intensity mandate (934 lbs CO2/MWhr) could have been closer to a more manageable 1,000 lbs CO2/MWhr.

Those familiar with these numbers will recognize that 934 lbs CO2/MWhr is the approximate CO2 yield of a clean natural gas power plant. In others words, Virginia probably cannot operate many coal plants and still meet their 2030 CO2 target. In fact, EPA seems to be assuming that Virginia will shut down all but one coal plant by 2020, before CPP even kicks in. I’ve asked EPA to check their numbers to see if there is an error on the Virginia state summary sheet data for 2020.

Bottom line for me is that the Virginia CO2 targets appear very challenging. But somebody needs to check my numbers, and preferably EPA should show their adjusted 2012 base numbers on the State-at-a-Glance summary sheets. Meanwhile please be advised that most of the Virginia CPP information out there on the Web is using our non-adjusted 2012 base data.

Bill Tracy is a retired engineer, concerned citizen, and grandfather residing in Burke, Virginia.  

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  1. LarrytheG Avatar

    well if the premise is true – it’s more than a calculation error – it’s a blatant misrepresentation of the facts by the EPA and I guess I would think the SCC and Dominion would be all over it – if that were the case.

    Dominion’s response to the CPP has been mild and I guess I would have thought they would have easily seen the same error – realized that it meant closing all coal plants – and all hell broke loose with the Va GA and GOP leading the charge.

    here are the coal plants in Va:

    Birchwood Power Partners, L.P. King George County
    Dominion – Chesterfield Power Station Chesterfield County
    James River Cogeneration Company Hopewell City
    Hopewell Cogeneration Ltd Partnership Hopewell City
    Spruance Genco LLC Richmond City
    Dominion – Mecklenburg Power Station Mecklenburg County
    Dominion – Clover Power Station Halifax County
    American Electric Power Glen Lyn Giles County
    American Electric Power-Clinch River Plant Russell County
    Portsmouth Genco, LLC. Portsmouth City
    Dominion – Southampton Power Station Southampton County
    Dominion – Yorktown Power Station York County
    Dominion (VA Electric & Power Company) Wise County

    if all of these but one are going to have to close – Wouldn’t that be heavily pointed out by the SCC and Dominion and other opponents of the CPP?

    I’m not saying Mr. Tracy’s numbers are wrong – yet. But we really don’t see how he got his numbers.. he just showed his results.

    It’s hard to believe the SCC and Dominion missed this, but if
    they did and Mr. Tracy is correct, I would expect to hear a major outcry shortly.


    1. Hi Larry- It’s me!…That is a nice list of coal plants thank you. Quite a few are slated for shutdown soon or certainly by 2020. The figure I was questioning is the 2020 (without CPP) value of 959 lbs CO2/MWhr on Virginia’s State-at-a-Glance sheet. As far as I know the 2020 number does not enter into calculations, it just gives everyone the impression that even without CPP, we are already almost at the target. In reality I calculate we’d have about 3500 MW of the above coal plants still running. Note that I am just a concerned citizen, I have no knowledge about Virginia’s long term plans. I just presume Virginia wants to keep a few plants running. For one thing our renewable energy is already getting up to 6.5% due to the “hybrid” nature of one or more of the plants.

      1. Rowinguy Avatar

        The 2012 baseline emission numbers cited by the EPA in that state at a glance document did not appear to include full annual emissions from 3 Virginia power plants, the Wise County coal plant which entered service mid-way into 2012 and the Brunswick and Warren County gas fired plants. Thus, it appeared that only minimal emission reductions would be necessary to meet the 2022 interim targets. Including the expected emissions from those new plants as have entered or will enter service would show more accurately how extensive the “lift” actually is.

        The final regulation is much more logically constructed than the proposed regulation was, but it will still be a challenge to achieve.

        As Larry’s list shows, Dominion owns many of the coal units and will be retiring some of them. Appalachian is retiring or converting all its Virginia coal units to natural gas. What are the independently owned plants going to do?

        It also remains puzzling to me why the EPA’s final CO2 target for the existing fossil fleet in Virginia remains BELOW the CO2 limits set for new sources that must, by law, employ the best available control technologies.

        1. LarrytheG Avatar

          well I suspect that the EPA counting plants they though were already going to close. If you look at the 2014 Va Energy Plan – you can see the plants that they thought would be closing also.

          perhaps the “at a glance” doc is not the one to be looking for the more detailed stuff… is there a more comprehensive doc that might discuss rationale and assumptions?

          but again – the CPP proposal was on the table for a while and the SCC and DOminion had every opportunity to rebut the EPA numbers using the approach you are using.. I just fine it a little bit of a stretch to think that neither of them knew or they did but chose to not make that case – given the vitriolic response from the SCC anyhow.. why would they not make the same argument you are – and undermine the EPA and make them look even worse?

          The private plant question – like the Birchwood Plant near Fredericksburg is a good question.

          That plant is owned 1/2 by GE and 1/2 by JPOWER. Originally Birchwood was built by Southern Company… which is a curious thing… given it’s in Dominions territory …. why would Dominion choose that option rather than building their own? It’s a fairly modern plant… and is co-located next to a mega landfill – which takes their spent coal byproducts (as well as out-of-state trash and regional trash).

          it is classified as a co-generation plant and it’s heat used to feed greenhouses for hot house tomatoes but that went belly up.

          there is also a significant hot water output into the Rappahannock River which is no problem except during the hotter times of the year when the flow is minimal due to drought..

        2. Good comments. EPA I believe is assuming renewables will dilute the CO2 down from the new source limits. 2012 was indeed a low coal base year, another issue. Virginia seemed to draw a bad hand, maybe because 2012 base %coal was low and/or maybe because EPA utility model tells them Virginia can automatically hit the targets. Orig I was thinking Va. made good comments to EPA draft, now as a skeptic, I am starting to wonder if Va. state level told EPA to let us have it, we’ll make them shut down the coal. That seems to be what EPA model shows to me.

          1. LarrytheG Avatar

            the question is – if SCC and Dominion KNEW that 2012 was a low year – why didn’t they make that part of their comments?

            it’s not like the SCC was talking “nice” to the EPA…they let them have it with both barrels but they left out something that actually would have conclusively demonstrate the EPA approach was wrong?

            I don’t think I’m buying that idea…

            remember when Bill Howell came out trumpeting the SCC response and used it to hammer the EPA for it’s war on coal?

            what better way to have a real potent argument – not just political – by showing that the EPA ..did screw up?

            something is not fitting together with this line of thinking.

  2. TooManyTaxes Avatar

    News Flash – government agencies make up data or use incorrect data to advance their agenda.

    I’m not opposed to reducing CO2 emissions. I sit on a committee that is looking for ways to reduce CO2 emissions in the Greater Washington Metro Area. But I still believe scientists and government officials lie and lie often about “global warming n/k/a Climate Change” to get power and money.

    1. Interesting about the committee. We shouldn’t get off the CPP subject but I feel Virginia’s car taxes inhibit greater adoption of hybrids and plug-ins. Car tax in Va. can easily be $5000 more than DC or MD on something like a Prius. Tesla Model-S you could be talking up to $20000 more car tax in Va. I think it really hurts our economy and car sales. Unfort. we do not seem to have a good auto sales report like California gets quarterly from their Ca New Car dealers Assoc ( so I cannot prove my point without paying Polk or someone for the Va. auto sales data. I have wondered if we could reduce auto CO2 by encouraging higher MPG and then take the credits over on the CPP side. I know that’s not in CPP now, just saying. Of course, this all on Virginia as MD and DC have much lower car taxes including incentives for hybrids (DC) and plug-ins (DC and MD).

  3. Dominion has reached essentially the same conclusion as Bill. After examining the final draft, they came up with the same numbers as Bill:

    Starting point — 1,477 lbs/MWh
    2030 target — 934 lbs/MWh
    Reduction — 37%

    The observation from my source at Dominion: “It is not easy to compare the proposed and final carbon reduction targets because the baselines and the way the EPA did all their calculations changed from the interim rule to final. Frankly, it’s all a big mess and states will most likely ask for extensions to figure out how to implement. There is a long way to go…Virginia has a very aggressive requirement.”

    I put in an inquiry with Appalachian Power Co. as well but have not heard back from them.

    Based on Dominion’s conclusion, and Bill’s verification of his conclusion, I have to repudiate the preliminary conclusions that I drew in a blog post three weeks ago based on the EPA’s “State at Glance” document, along with the conclusion that the draft represented any kind of political victory for Governor Terry McAuliffe, who had lobbied for major revisions to the CO2 emission targets in Virginia.

    Bottom line: Meeting these goals will be very painful.

    1. Correct and full disclosure, in some parts (South Jersey) I am known as an accomplished slayer of coal plants myself. I am somewhat in awe of EPA essentially taking down the whole industry in one fell swoop, and pronto. I now call Figure 1 above the America-at-a-Glance summary sheet…Figure 1 is basically the whole CPP plan in one chart. It is awesomely aggressive I think. So if EPA is going yield that kind of “terrible swift sword” there better be total clarity of what we doing (none of this “powder puff” talk to hide the true impact from the public) and the numbers gotta make perfect sense. It’s almost like there was so much change between draft and final, we need a whole new review, and I’d probably give some states to 2040. I personally would have more time to see why Virginia is getting slammed so hard.

  4. We should keep in mind that the current version of the CPP also designates a specific role for grid technologies that can help reduce the net amount of power being generated from carbon-emitting, fossil-fuel-fired power plants. Under certain compliance options available to states, those reductions could translate into “emission rate credits” or ERCs, that power plant operators could implement themselves or buy to offset their GHG reduction burdens.

    These technologies fall into two main classes. The first are those that directly affect the transmission and distribution portion of the grid. EPA explicitly recognizes as compliance measures any T&D options that reduce line losses, like volt/VAR optimization (VVO), or that reduce end-use demand, like conservation voltage reduction (CVR). VVO could save Michigan about $110 million in CPP compliance costs, for example.

    On the demand side of the equation, the CPP does talk about demand response as a reliability tool. To the extent that demand response produces that reduction in net megawatt-hours, it can qualify for credit.

    This is dependent on how individual states decide to create their CPP compliance programs — whether they choose mass-based or rate-based options, whether they decide to join multi-state compliance regimes or do it on their own.

    Dan Delurey, CEO of the Association for Demand Response and Smart Grid, noted, “This is not to say that demand response and smart grid get any kind of preferential treatment in the CPP. All options will have to compete against each other to get into a state compliance plan.”
    “But it does clearly put those options on the menu for states, and that is good for those in the [Distributed Resources] DR and smart grid community. And, through the new value that is created via credits for CO2 reductions, it also puts one more benefit on the pile when DR and smart grid projects are being evaluated for cost-effectiveness,” he added.

    These comments are intended to show that compliance with the CPP is not just limited to shutting down old coal plants. Innovative utilities are investigating a variety of ways to optimize their response to the CPP in ways that better serve customers and reduce their costs.

  5. LarrytheG Avatar

    I guess I would have still expected a more targeted response from Dominion and the SCC given the 37% reduction that has been calculated.

    What wouldn’t, for instance – the opponents come out with a list of plants that have to be closed, their total mega watts that would be lost – and the costs required to build replacement gas plants?

    TMT says govt lies.. probably true – but why wouldn’t the SCC/Dominion just ignore what TomH is saying COULD be done – instead – and just go for the jugular of naming the plants to be closed, the locations impacted with jobs lost, etc, etc?

    Without them coming out and saying that – unlike Jim – I do not accept these numbers as facts, in part, because I’m not seeing how the “adjusted 2012” numbers were calculated – AND I’m not seeing that kind of response from Dominion -either…

    so where are we really at?

    Jim should take the bull by the horns by the horns here – get back to his source and ask for confirmation that all these coal plants would have to be closed to meet the CPP targets.

    how about it?

    1. TooManyTaxes Avatar

      Perhaps, Dominion & other power companies are awaiting the results of the challenge to the EPA’s claim of authority to regulate power plants. One battle at a time?

      1. LarrytheG Avatar

        why wait ? chances are they won’t be any more successful than they were with CO2. EPA’s authority has been challenged just about every time it has issued a regulation ..

        besides – the current narrative about the EPA’s “war on coal” would just explode if this was true and hit the fan…

        something’s not quite right about this … Nothing would be more effective in a campaign against the EPA – than a list of coal plants to close, jobs lost, costs for new gas plants.. show that increase on people’s electric bills, etc… You’d have Virginia’s Congressmen promising legislation to prohibit closing coal plants.. etc… they’d be running on that issue at election time.

        1. TooManyTaxes Avatar

          Larry, I don’t disagree with your argument. I’d go in multiple directions. Jobs are a big issue with people and politicians.

    2. Rowinguy Avatar

      The SCC document that you have been so exercised about were its Staff’s comments to the EPA regarding the proposed CPP.

      The EPA significantly altered the proposed rule when it issued its final rules two weeks ago. The final rule eliminated some aspects that the SCC Staff found objectionable, and pushed the initial compliance date back by two years to allow more time to develop the replacement supply (or demand) resources that may be needed to achieve compliance.

      There will not be any opportunity for anyone, including the SCC Staff, to comment on the final rules.

  6. UPDATE- EPA did kindly respond to my question about 2020. Note that I have no “inside” contact at EPA, I am just using the readily available CPP contact form on-line.

    I am paraphrasing, basically the EPA said the state 2020 numbers are coming from EPA’s Utility model. The model knows what Virginia definitely plans to do, and then the model predicts what things like low natural gas prices (specifically mentioned) will do to predict Virginia’s likely future decisions. The EPA stressed, and I fully agree (sort of), the 2020 model results are for indicative purposes only, and not used in their regulatory target setting.

    OK, but I’ve done as many guesstimates as the next guy: if EPA’s model says Virginia will already automatically, without CPP, achieve 959 lbs CO2/MWhr by 2020 and say 810 lbs/MWhr by 2030, no wonder they might have tailored the final Va. equations to give us a hard initial 810 target, that was later relaxed to 934 lbs/MWhr in the final rule (which reportedly shifted a bit more of the burden to coal states). I am a skeptic, I know.

    The $64,000 question is: does anyone in Virginia agree with the EPA 2020 model? I am all ears because I have no crystal ball nor inside scoop. But this is a brand new Virginia state issue, per EPA, the new CO2 control boundary is the state line. I can sort of imagine Gov McAuliffe’s position being nobody should fight this anymore, let’s get behind the plan, as challenging as it might be for us. Since we are not a coal state (who knew?) we can actually do it if we want to.

    Here’s EPA model link, I don’t think it clarifies exactly what the 2020 plan is.

    1. LarrytheG Avatar

      thanks for working the issue Tbill!

      not be snarky … but I guess I would have thought that both the SCC and Dominion would respond with specifics including their own counter calculations, etc.

      Hell.. even I , MIGHT BE CONVINCED with a substantiative response from the SCC and Dominion.

      So far what I “got” from the SCC was a overtly political generic venting of the spleen.. by some sort of sketchty “staff” “but we’re not the actual SCC” type foolishness – trumpeted so quickly by Bill Howell that the SCC response he referred to was not even on their website yet.

      how about a real response with real numbers and real coal plants and real jobs lost if that is the reality they are purporting to be in store ?

      I’d bet dollars to donuts – that IF 3rd party companies were allowed to build gas plants in Va – they could build and operate them – cheaper than Dominion can – it’s coal plants AND meet the CPP specs without breaking a sweat.

      someone tell me that’s wrong!

      1. Larry, My sense is that Dominion is still trying to decipher the final EPA rules and targets, and only then can it decide what plants to shut down. The EPA was not a model of clarity, apparently, which hasn’t helped matters. I haven’t gotten a response yet from Appalachian Power Co. either.

        1. LarrytheG Avatar

          well how long did the EPA has the proposal out for comment?

          I thought it was out for quite some time … wouldn’t that had been
          the time to lay out potential impacts?

          I still think if 3rd party companies could build gas plants in Va -like Panda is – – they could render moot – the whole issue about emission targets. Virginia could easily meet those targets… the adverse impacts would be fiscal ones to Dominions coal plant assets.

          How about some good old free-market disruption?

          1. Rowinguy Avatar

            The proposed CPP was issued last June by the EPA. Comments were to be filed on that proposal by October 15, 2014. Later, the EPA extended the comment period to December, so interested persons (all 4 million of them) had six months to analyze and comment on the proposal. The SCC Staff filed its comments on the original date of October 15.

            The recently released rules are final rules–there is NO more comment period. They are quite different from the proposal published last June.

            New units, such as Panda, do not have to meet the CPP rules. There is another, laxer, standard for new sources.

        2. When New Jersey was trying to solve its trash/waste importation issues in the 1970’s and 1980’s, it took control of the state boundaries. But we did not ask the landfills for guidance. There was a state policy, and the Gov was leading, and DEP head was leading and we drew up smaller regions (counties) and they had to develop county plans. I am just trying to say what a state boundaries approach looks like organizationally. Gov McAuliffe might want to ask Thomas Kean and Jim Florio for a sense of a state boundaries approach. That could be fun meeting for him anyways. I think Kean was more operationally the one who implemented.

          And we ended up sending all our trash to Virginia, a win-lose for me! That was not the intent, just path of least resistance.

      2. “I’d bet dollars to donuts – that IF 3rd party companies were allowed to build gas plants in Va – they could build and operate them – cheaper than Dominion can – it’s coal plants AND meet the CPP specs without breaking a sweat.”

        I doubt that a 3rd party could build a gas plant cheaper than Dominion can. They are one of the largest utilities in the United States (maybe 12th). A small third party would have a much higher cost of capital than Dominion would. Nor would they have as easy access to capital or to the SCC for approval of the facility. It would not be nearly as advantageous for Dominion to purchase wholesale power compared to adding a multi-billion dollar plant to their balance sheet and rate base – so rates might be higher if supplied by a third-party for a gas plant.

        However, if you were interested in promoting more jobs in Virginia you would produce many times more jobs than are currently associated with the old coal plants by replacing them with solar facilities. Because the coal plants are old and inefficient and expensive to maintain (and are probably used in an intermediate load rather than base load capacity) solar might be nearly cost competitive with them now, and very likely significantly cheaper than these plants by 2020.

        1. LarrytheG Avatar

          I got to third party by looking at Panda… and was thinking if Panda could build a plant – and presumably make money at it – in one place – why not other places?

          Old Dominion operates the gas plants in Accomack…on the Eastern Shore… which contradicts the idea that Amazon solar went to Maryland because Dominion would not buy it.. you might have thought Solar would be a good complement to the Gas plants that Old Dominion operates on the Eastern shore.

          1. Rowinguy Avatar

            Larry and Tom, independent power producers ARE allowed to build power plants in Virginia. At one time, back in the late 80s and 90s, Virginia Power got rid of construction risk by contracting for the output for a number of independent power plants built here. It had a competitive bidding program in which it solicited proposals for independent power. That has since changed. In 2007, the law was amended to incent Dominion (and, to be fair, other investor owned utilities) to build their own plants again and provided separate cost recovery mechanisms and added additional profits to the construction of power plants by incumbent utilities

            Tom, during this period, an independent might have been able to build a cheaper plant, because it would not be eligible to receive the bonus return on its equity invested that Dominion could. Some independents protested when Dominion proposed to build that Brunswick plant, for instance. The law has been amended again to eliminate some of the bonus returns (still apply to nuclear or offshore wind plants).

            Larry, ODEC does not operate any gas plants on the Eastern Shore. One very small and very old peaking unit (3.9 MW, 1947) in Tasley, VA, is operated by the distribution cooperative (A&N) that distributes power to the ES.

            There is one big oil-fired plant on the ES that is independently owned. I believe that it runs very little. It’s in Accomack County, which is also the site of the Amazon sponsored solar facility. That’s Virginia, not Maryland.

          2. Rowinguy,

            Thank you for the clarification. I am still getting up to speed with how things are done in Virginia. It is unique.

            In other states that I have experienced, the regulators and the legislators represented the interests of the ratepayers and citizens, while the utilities looked out for the shareholders. Between them a somewhat balanced approach was usually hammered out. The dynamic doesn’t seem to be precisely the same here in Virginia.

            If a utility pursues a plan that could result in higher rates, stranded costs and a diminished business climate, with whom do you speak to discuss other possibilities? We need the utilities to be healthy, but they should prosper as their customers benefit as do unregulated businesses. They should not benefit at their customers’ expense.

  7. LarrytheG Avatar

    here’s another example of private sector interest and investment in SOLAR – in Virginia –

    Firm seeking to build $35 million solar facility in Buckingham

    they say they’re selling it to Dominion.. but not much detail on the arrangement…

    this is 20mw on 200 acres..

    anyone who has taken a drive down in Southside Va – or just looks an an aerial of the actual landscape knows that there are thousands and thousands of unused acres … much of it former cropland…

    between gas plants and solar – who still believes that Va needs coal plants in 2030?

    1. Larry- Thank you for the 2014 Energy Plan. Interesting coal for elec was 30% in 2013, vs. 20% in 2012 (EPA CPP base). 2012 was a low % coal outlier. My article above is just looking at math of the 2012 case, without *yet* getting into the fact 2012 was bad year for EPA to pick for Va. in the first place. I know Dominion in its comments to EPA mentioned the 2012 base was a low coal year. I have not had time to understand if EPA took that into account.

      Wish we could have a workshop with EPA or something like that. Also the EPA CPP plan has a communication provision that the public is supposed to be advised what is going with Va CPP. That would be something state should be doing to explain all of this.

      1. LarrytheG Avatar

        Tbill – you’ll have to explain how coal-generated electricity has a “bad” year.

        what happened? did they shut down plants then fire them up again later?

        but I MUCH appreciate your thoughts and continuing dialogue… sometimes – at various points – in such dialogue – folks end up understanding more than they did.. and that’s always a good thing and I’d be the first to admit – that I do learn.. I have mistakes corrected and the insights gained lead to more and better understanding of issues.

        it’s clear to me from the continuing dialogue across the various blog posts of recent:

        1. – the dialogue is totally on the subject and not about people…a very good thing

        2. – that energy and electricity , especially in Va is a complex subject of which very few folks outside the industry really understand.

        I have great optimism that with the current participants that much more can be discussed and learned…

  8. LarrytheG Avatar

    re: Old Dominon on the Eastern Shore..

    got that from the DEQ list of power plants:

    61410 Old Dominion Electric Cooperative – Unit 7 TRO Natural Gas Accomack County  Peaking

    61411 Old Dominion Electric Cooperative – Unit 8 TRO Natural Gas Accomack County  Peaking

    61412 Old Dominion Electric Cooperative – UNIT 5 TRO Natural Gas Accomack County  Peaking

    61413 Old Dominion Electric Cooperative – Unit 6 TRO Natural Gas Accomack County Peaking 

    61414 Old Dominion Electric Cooperative – UNIT 9 TRO Natural Gas Accomack County  Peaking

    61415 Old Dominion Electric Cooperative – UNIT 10 TRO Natural Gas Accomack County  Peaking

    61416 Old Dominion Electric Cooperative – Portable 61416 TRO
    Natural Gas Southampton County  Peaking

    61417 Old Dominion Electric Cooperative – Portable 61417 TRO Natural Gas Southampton County  Peaking

    is that wrong? looks like the DEQ list has errors…

    where does the Eastern Shore get their power?

    I found this other Old Dominion History:

    ” 2008
    ODEC acquired transmission lines from Delmarva Power and Light Company in connection with A&N Electric Cooperative. ODEC entered into a settlement agreement with one of its then-current members, Northern Virginia Electric Cooperative (NOVEC), resulting in the termination of their contract. ODEC amended and extended its contract with the remaining 11 members through 2053.”

    right now A&N is listed as the rural cooperative for the Eastern Shore.

    1. Rowinguy Avatar

      Larry, I was also looking at that DEQ list when I replied last night but the last page did not open for me. I do see those ODEC units now. They appear to be all diesel combustion turbines, each producing 2 MW. They are peakers. ODEC has 2 member cooperatives in Maryland and Delaware as well as A&N on the Eastern Shore of Virginia. It owns some generation in Maryland and is building a large gas-fired plant in Md. I expect it obtains some power for A&N from Delmarva Power, an IOU that operates now only in Del and Mar. They exited VA operations a few years back and sold their distribution territory to A&N.

  9. LarrytheG Avatar

    re: ” There is one big oil-fired plant on the ES that is independently owned. I believe that it runs very little. It’s in Accomack County, which is also the site of the Amazon sponsored solar facility. That’s Virginia, not Maryland.”

    this is pretty confusing.. A&N is listed as the utility… but so is DelMarva (and it may have been DelmarVa that bought Amazons solar).

    look at this map:

    notice that there are TWO providers on the Eastern Shore (A&N and DelMarVa – and who knows what plants are powering that area!)

    notice also – Dominions territory verses other utilities including APCO.

    finally – as hard as I try – I cannot find – yet – a complete list of all electricity generators in Va and it’s clear to me that what Dominion is listing is not that all inclusive list.. it’s only their list.

    1. One interesting place to look, go to Clean Power Plan and get the State Goal Visualizer spread sheet. Go to the master list Appendix 1 ALL UNITS. Now sort on Virginia, the list is thousands long so its hard to understand but its every landfill gas turbine etc. for 2012. If you add the (non excluded) columns MW and CO2 you get EPA’s exact base number 1477 lbs CO2/MW

      Also I believe the overall presentation has a map you click on for sources.

    2. Rowinguy Avatar

      The map you linked is out of date. Neither Delmarva nor Potomac Edison serve any customers in Virginia, having sold their operations to A&N Coop (Delmarva) and Shenandoah and Rappahannock Coops (Pot Ed). These transactions took place in 2010 and the map has not been updated since at least 2009.

      1. LarrytheG Avatar


        how about the Dominion territory?

        that’s a lot less than I had imagined.

        they don’t look to be much larger than AEP yet they appear to have
        a much larger political presence than AEP…

        1. Check out Slide#3 has all the fossil fuel power plants (interactive map)

          1. Rowinguy Avatar

            Bill, this is a very useful map and tool you have linked, but it too is not up to date. It purports to show fossil plants and their emissions as of 2012, but the Virginia City coal plant, energized in July 2012, is not shown. Units under construction and impacted by the CPP are not shown either. Thus the big gas plants in Warren County, online in 2014, and Brunswick County, expected online in 2016, do not appear either.

          2. LarrytheG Avatar

            Thank TBill.. it’s a cool map… !

            but alas .. it too is missing info as Rowinguy found

            at least 2 places on a quick look.

            the Birchwood plant just east of Fredericksburg

            and the plant in Hampton scheduled to be closed.

            or is this a map that assumes both of them will close and are not part of the CPP?

            I have not heard that the Birchwood plant would close. It’s a fairly modern plan – 1996….

          3. Here is another resource. Caution fairly big Excel file. But is the whole EPA data base for 2012. Appendix 1 is list of plants (tens of thousands) and Appendix 2 is new plants under construction (by 2014 I think it is).


          4. LarrytheG Avatar

            big file… yes… but you can get to the Va stuff… and they have it classified as coal, excluded and others but not sure what it all means

            does not appear to list all existing coal plants in Va.

        2. Rowinguy Avatar

          Dominion serves a much, much wealthier and more populous area of the state, the so-called “Golden Crescent” from D.C. down to Richmond and veering east to the Hampton Roads. They serve more customers than the rest of the IOUs and cooperatives put together, I believe.

          1. LarrytheG Avatar

            I think about 2.5 million customers – households, businesses, etc.

            the more I look at maps – the more disjointed the service territories look… it’s hard to imagine how this would be operated as an integrated grid…but I guess if Dominion owns and operates (or controls) most of the generation – then all the rural electrics (except for OD) are just consumers…

            but you still have companies like Panda… and I note that even on Dominion’s own list of plants which includes “merchant” plants I could not find Birchwood which is just east of Fredericksburg.

            so is net metering just a Dominion issue or does it also apply to all the cooperatives?

  10. Wow. I just got a bulk email from a local Republican Delegate. He said he is a huge fan of renewables and, no ifs ands or buts, sounded like he was saying EPA’s 38% CO2 reduction in the Clean Power Plan for Virginia was a done deal. I am OK with it too, if that is official plan, I can move on to different issue.

  11. LarrytheG Avatar

    here’s a more recent map of utility service districts (2010) from the SCC

  12. That map shows that Dominion is only one of many Va. utility players as far as commenting on EPA CPP. I believe the state needs to take the lead somehow. I don’t think it’s a good option to be passive and let EPA run our state. EPA is giving states control and I believe we may need to accept the responsibility. Whether we agree with it or not, the CPP puts the burden on the State of Virginia to develop a plan, and communicate that plan.

    1. LarrytheG Avatar

      well the map is essentially a distribution map not a generation map.

      Dominion probably generates most of the electricity – thought its not at all clear why electric cooperatives could not engage in net metering and/or contract with 3rd parties to run gas plants.

      there is a huge bureaucracy involved not just the EPA but in Va to regulate who, what, when and where new generation with renewables and natural gas can be or not.

      In terms of dealing with the EPA – CPP started out as a proposal with ample time and opportunity to respond specifically and in detail and what I perceived from the SCC was essentially a “we’re not going to do this” political statement” as opposed to a technical discussion of the coal plants and what it would take to replace them.

      I’m just not on the anti-EPA wagon. I’ve seen this play out each time the EPA has proposed some pollution reduction plan whether it was unleaded gas, mileage standards, toxics like dioxin/pcbs, and the ozone holes. Each time the industry would not only oppose it but they would make it political.

      The CPP proposal that you provided the link to shows about 8 billion in costs and 17-80 billion in benefits… to people’s health.

      that has been their approach each time but it’s as if people either don’t believe it or refuse to accept the claim that money is saved – because the money is downstream and accrues to others not Dominion.

      I do think Va chose to go political rather than address the proposal on it’s merits. For instance – where is the Va DEQ statement that perhaps would have disputed the savings of health benefits.

      My basic view is that if Va replaced each coal plant with a gas plant – they’d surpass the targets and because gas i cheaper than coal right now it would even allow for paying down the stranded costs.

      I think if 3rd party providers were allowed to compete not only with gas but with renewables – it would allow the gas plants to modulate their output – based on how much wind/solar was being generated – the very same way that gas in used right now to modulate system demand.

      I think it’s a horrible idea to grant any company the ability to export natural gas when it’s a critical and strategic fuel. I worry more about that than I do the EPA to be honest.

      I just don’t buy the jihad against the EPA. I’ve yet to see any of their past rules – rolled back, repealed because it turned out they were wrong on the cost-benefit. They’ve been right every single time.

      there is no one in their right mind today that would say we need to undo the restrictions on CFCs, or dioxin/pcbs, or unleaded gas or mileage standards, or stricter sewage treatment or clean drinking water, etc, etc, etc.

      however , there is now political opposition to cleaning up the Chespeake Bay – from the same folks who oppose the CPP and prior pollution reduction … it’s always an amalgam of industry and political. It always seeks to demonize the EPA and govt in general in that role.

      I just never got on that bandwagon… and wonj’t now.

      The CPP is a process. if the EPA got the cost-benefit wrong – let’s show them how and work for – compromise – not outright rejection which is where the opponents are.. they don’t want to do ANYTHING. The message from the opponents is “we’re not going to do anything”. We’re going to beat you in court or we’ll beat you at elections.

      It failed before and it’s going to fail again… I predict.

  13. Does anyone know how the SCC defines stranded costs from a financial point of view?

    There is a difference between a financial asset (one that should qualify for stranded costs) and an operating asset (a plant that is still capable of producing electricity but has been paid for by rate payers). It takes approximately twenty years for rate payers to pay off the costs of financing a new plant but the plant is usually able to operate for about another 20 years. Should ratepayers be asked to pay again for something they have already paid for because a technology is now obsolete? We usually don’t expect to get anything (or very little) for our old computers, even though they still work, when we replace them with higher performing models.

    For example, when municipalities take over Investor Owned Utilities (IOU’s) distribution systems – utilities use the highest method of valuation (typically valuing a system with an average age of 25-35 years as if it was newly built at today’s costs). This creates a high financial barrier to avoid doing something the utilities don’t want to do.

    Perhaps we should take the net present financial value of a facility and subtract from it the net present value of future health care costs, consequences of toxic materials (mercury, arsenic), etc. If there is a positive balance we pay a stranded cost, if not – we replace the plant because that provides a net public benefit.

    I have some qualms about this, but many desire market forces rather than government proclamations to govern our choices, but the market is not functioning in its theoretical role in these cases. Theory says that the price reflects all of the information related to the transaction. We have known for decades that in many industries (energy, transportation, mining, agriculture, to name a few) prices do not reflect the true costs of the products. Perhaps if we more accurately priced the choices we were being asked to make, it would clarify our choices rather than confusing them.

    1. LarrytheG Avatar

      ONe of those areas that most average folks don’t know and that the SCC is generous about (though don’t know) .

      but it’s also an aspect of choices made by the utility that could encumber rate payers.. if they choose a technology that gets outmoded quicker than thought. The ratepayer – not the investors gets to be the safety net.

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