Thank you for considering these comments.

Background: I am a homeowner in northern Virginia (city of Alexandria) and have 16- years’ experience in energy and electricity sector. My comments are entirely my own and reflect no clients and no compensation by anyone. But the comments are informed by experience in energy (electric utility, oil and gas). I  served on a 2017 NERC (North American Electric Reliability Corporation) reliability study as unpaid advisor. I do not invoke any of these parties to suggest I represent their views or they are in agreement with my own.

1) Diversified Generation Mix: We need a balance of all fuel types (baseload fossil/nuclear in combination with intermittent renewables (biomass, hydro, and solar/wind -- and use of hydro pump storage.  While lithium ion batteries are proving more economical--they are not yet commercially justifiable in terms of cost on a wide application. Perhaps one day tidal power if that proves more economical but not yet. Dominion is to be commended for its investments in many generation types--including the gas pipeline/compressor station infrastructure to support natural gas. 

2) Consumer impacts and making sure consumer is adequately informed: While there is nothing wrong with solar panels, the Commission should be wise to the long-term costs associated with solar arrays on residential roofs. Many solar panels on homes may not have lifetime of more than 5-10 years (perhaps less if broken or damaged by hail storms, hurricanes, tornados, or broken tree limbs).  And some homes have too much tree canopy to make solar really economical. Homeowners often don't realize there are significant costs associated with hazardous waste landfill disposal of any solar panels that cannot meet the TCLP test (EPA's toxicity regulation under Resource Conservation and Recovery Act). This is not a statement against solar.

Concentrated or community solar or directional solar panels on large industrial, commercial, governmental buildings may be more productive than residential rooftop panels even though those costs are decreasing. Many homeowners simply don't understand many of the indirect costs or structural integrity questions on older homes that were not designed for the weight. The commission should ensure that solar panel sellers and those engaging in solar energy buy back with residential users have full disclosure on weight of panels, and clear language on who owns the panels, who is responsible to replace or dispose of the panel and the contracts should give real world examples on what the disposal costs might be. I fear many homeowners may be surprised and disheartened far too late. The state should also require very clear language about shut off valves for rooftop solar panels to protect fire and EMT personnel who might have to gain access to the home's roof. This language should be very clear in all contracts. Additionally, of course, the consumer should have clear understanding of how much they will actually save on energy bill. For some, rooftop solar may be far less productive than a replacement of an aging HVAC system or new roof, new windows etc. 

I believe that State Corporation Commission should encourage residential and commercial geothermal energy for HVAC and demand side management equal to solar and wind. Residential use of geothermal HVAC systems (especially for new homes where yards are not yet planted), may be far more useful and economical over the lifetime of the home. Until state agencies encourage this type of investment, ill-informed consumers may invest in solar that may not make as much sense for their home. Further, it is not clear to me if VA can ever support all the wind generation needed given the mountainous areas and areas with less or no wind. Community solar should also have appropriate incentives that make it smart investment for utility and for electricity users.

Additionally, electric utilities should be able to be compensated for using district steam, water reuse, and other water-energy efficiency measures. 

2) IRP and remaining useful life of plants: State's ultimate decision should require the IRP to show a balance of electric generation types that balances costs, investments, remaining useful life of existing plants and infrastructure. IRP should include demand response programs where those can economically minimize large capital investments where electricity demand is not increasing significantly and there is no need to build additional generation for commercial or industrial purposes. Some communities in rural VA will face declining populations and the utility won't want major investments there. DSM helps in most cases.

Plants (even coal) should not be forced to retire if they have invested in all appropriate regulatory requirements to meet safety and public health (environmental) standards if they have as many as 8 years left. In some cases, the state commission may determine there are "must run" or reliability needs over a short term until either new generation is fully operational or the electric or gas transmission infrastructure is fully approved and built.

If, for example, there is a power plant that supports a mine mouth coal mine in southern Virginia (that meets its air, waste and worker safety standards), and it makes sense to let the mine-mouth plant run a few extra years because it will be economical mess to a community for loss of jobs at the mine--let’s do it. Common sense needs to prevail as we make transition from coal to gas and coal to renewables with natural gas as back up. That doesn't mean a long-term subsidy to the mine or to the power plant. However, if there is a true justification for relialibty reasons or lack of infrastructure for the new gas plants-- then perhaps 2 years or PJM capacity payments for a maximum of 2 years--this short-term subsidy is acceptable. However, the Virginia Energy Plan should not allow the mess that Illinois and other states have gotten into with subsidies for older coal and nuclear plants that cannot dispatch due to the less expensive generation types. But a short-term subsidy should not be offered to older clunker plants that did not adequately upgrade facility with mercury controls, PM, or ozone standards or nuclear safety standards. Many of the plants that have requested these subsidies in other states do not have adequate justification to ask for the subsidies. Further, the state should evaluate any subsidy to the plant that can ramp fast enough to back up renewables. Most older coal and nukes can't ramp fast enough. If ANY subsidy is needed for short term transition, the subsidy should only be given to those plants that can ramp quickly for reliability purposes. In many cases those plants are smaller CFB plants that can burn many types of fuels--coal, biomass, tires, tree debris from forests after storms (often wet), etc. 

3) Cost really matters to consumer. The VA Energy Plan points to current statewide energy costs at approx. $.8.5c per kwh. But the report does not indicate that many of the changes to renewables and new nuclear investments will ultimately increase these costs. Impacts to residential consumers and the non-Northern Virginia economy need to be seriously evaluated by VA State Corporation economists when reviewing rate design. Northern Virginia's household incomes ranging from $80,000-90,000 are not typical in the rest of Virginia and the commissioners need to keep an eye on this. We don't want our state to look like NY, CA, HI, CT, etc. with extremely high rates--where industries do not want to do business. This is a delicate balancing act because we do want some investments in energy that reduce pollution, reduce CO2 to and increase efficiency. There is a reason that Amazon and other companies are looking at northern VA for massive data center and second headquarters--we have inexpensive electricity that most states in NE do not have. Let’s not mess that up.

4) Don't get lured by siren song of new technology which may be foolhardy: Regardless of what any U. S. EPA regulation says, VA State Corporation should not approve of any projects to geologically store CO2 (carbon capture & geological sequestration) or any other acid gas. Those many technologies for CCS are not commercially demonstrated adequate to justify the expense to consumer. Nor are those investments wise for the investors. Some may not be smart for the environment. Ex. No one knows if CO2 can be retained in a stable manner for 10,000 years. As for costs-- just look at the Kemper Project in Mississippi--a foolish investment by both an otherwise well-run company that meant well. It was also a wasteful use of money from the state and DOE. Perhaps in time an alternative technology may be possible to transform CO2 into fuel or more safely deal with the waste. The issue can be revisited as technology improves.

5) Biomass  obtained from tree debris, forest waste and wood products factory waste that would otherwise be landfilled or burned at the factory should be considered CO2 neutral. This does not mean the state should allow new trees to be harvested for power plant burning. Typically the economics only works with bringing in biomass from 100 miles from plants. Virginia utilities should not be subsidized if no biomass is available within that 100 miles or so that make economic sense. The last thing we need is to follow European utility examples where they were importing wood waste from Southeastern U. S. via ships that chipped the wood en route to Germany.

6) State Commission and DEQ should give dual fuel permits to all generators for reliability/resilience purposes for voltage support and back up generation in non-state or Federally declared storms or outages. This requires coordination with DEP. See NERC's Nov. 14, 2017 report with recommendations on dual fuel.  This also means those utilities must maintain their SPCC (tank) integrity testing to make sure oil spills do not create separate problems.

Currently "dual fuel plants" are limited to non-ozone season run times--and still limited to <10% of the year. Virginia needs to anticipate that we might need dual fuel generation options--even if rare needs during summer ozone season.  This is NOT a recommendation to give carte blanche to VA generators to run during ozone season--creating more sources of ozone pollution. The permit should be set up--for circumstances to maintain relialibty. Not all storms are declared by governor or FEMA fast enough. Give the utility some reasonable opportunity--but not an opportunity to take advantage.

7) Anticipating storms and back up fuel for crews: The nation learned from the 2017 hurricanes in Texas and Florida. Generators that also have trucks should be allowed to use non-low sulfur diesel remaining onsite for trucks during emergency and have this permission in permits. (U. S. EPA should do the same). The sulfur will chew up the trucks but a utility should have the option to keep trucks running to restore transmission and distribution lines after storms--not waiting for decisions to be made about the relatively small and short-lived exposure to higher SO2 emissions from utility trucks. Be practical. In time there will be no higher sulfur diesel stored in electric utility or water utility tanks.

8) Pipelines: Virginia needs more natural gas pipelines to make the transition from coal to natural gas backing up renewables. VA's Commission is not the only party that must approve these pipelines--some require FERC approval. But VA should do what it can to provide a speedy process for approval. However, the applicants need to consider the following in order to get reviews/approvals in as fast as possible:

- public safety protections must be met demonstrating that the new pipeline will be tested for corrosion or other factors that could cause failure no less often than every five years. Related to this, the pipeline owner must maintain inventory of equipment, materials, & contractors used to build the pipeline with some assurances of corrosion detection through pigging and ILI (in line inspection). Link to significant PHMSA violations should be easily available to be seen on State Commission website. Further, all new pipelines built in VA should have adequate emergency shut off valves, reasonable leak detection/repair practices, and other pressure change monitoring through new technologies. State should have similar requirements for existing intrastate pipelines. Leak detection and repairs should be reasonable. If not a significant public health endangerment, the compressor stations and pipeline leaks should be addressed at the next scheduled maintenance event. Most leaks on existing compressor stations appear to be rare but vexing.

- cyber protection for both electric and natural gas transmission should be a concern by State Commission. The public does not need to have access to this information. But the Commission needs to watch for adequate actions by corporations that they are wise to FERC, NERC, DOE, DHS, DOT regulations and standards. This should also apply to any natural gas storage facilities and their pipelines. For obvious reasons, the public does not need to be informed of any lapses or newly identified risks and opportunities for intrusions.

9) Natural gas storage: Given proximity to Utica and Marcellus and population grown in VA, we should anticipate the need for more gas storage needed in Virginia over time. New gas storage locations should be required to meet highest of designs to avoid undetected pressure loss in subsurface. Unless there is a significant justification by industrial customers of natural gas where odorant can harm their manufacturing process, the natural gas gathered in Virginia should be marked with an odorant (mercaptan or comparable chemical) for identification of leaks by customers and residents.

10) All compressor stations must be placed at sufficient distance to existing homes and businesses to prevent blow down noise that exceeds FERC or local noise pollution standards. These local noise standards need to be reasonable. Preferably State Commission should require all new compressor stations to have re-routing or local LNG facility for natural gas storage during blow down events. This is tricky as the secondary routing can be expensive--and should not be a gimmick for "gold plating" the project. The State Commission should study secondary routing and LNG storage designs to watch for the balance between safety, cost, and noise abatement.

11)River design: Pipelines that pass underwater should be anchored in any locations that have seen 100-year floods within the last fifty years. 

12) Landslide prevention: VA State Corporation should review PHMSA and NTSB evaluation of TransCanada pipeline rupture in June 2018 to determine if there is anything to learn about that design and the cause for the loss of structural integrity resulting in landslide. Fortunately, no one was harmed.

13) Virginia should maintain the healthy mix of diversity in ownership of utilities: investor owned, municipal and electric coops. The mix is good for a variety of reasons including circumstances where the bonds of one party and the capital investment of another party aid the consumer. The mix of ownership is more protective of the consumer. VA may want to watch the emergence of Community Choice Aggregation where local governmental agencies can sell power. It is too soon to embrace it--or oppose it. VA should watch to see if it is good for consumer. (One presumes the VA legislature would have to vote on this first).

Conclusion: These comments are intended to be practical and address some ways to balance the need for energy and protect public from unnecessary environmental damage, property value loss, or unexpected costs associated with solar panel incentives. The comments are also intended to help local utilities make smart decisions in a very rapidly changing time. It is not easy for utilities to make long-term decisions during such disruptive times.

Thank you for reading.

Theresa Pugh; Alexandria, VA