Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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8/24/18  8:30 pm
Commenter: A.G.Randol III, PhD, Va Scientists and Engineers for Energy and Environment


The Commonwealth of Virginia is an energy beggar state...we have to depend on others to produce what we consume is spite of the statutory requirement to "minimize the Commonwealth's long-term exposure to volatility and increases in world energy prices through greater energy independence".

We must expand affordable baseload supply to secure Virginia's economic security with reliable energy.

The irresponsible rush to increase dependence on natural gas has made us vulnerable to global competition.

By law (Virginia Code § 67-101 and § 67-102), DMME must propose a plan that:

1. Ensures an adequate energy supply and a Virginia-based energy production capacity (DMME: minimize reliance on other states for our energy, especially electricity);

2. Minimizes the Commonwealth's long-term exposure to volatility and increases in world energy prices through greater energy independence (DMME: use our resources-coal and uranium, minimize our dependence on natural gas exposed to LNG export supply and price competition);

3. Ensures the availability of reliable energy at costs that are reasonable (DMME: reliable baseload not intermittent WIND and SOLAR power is required)and in quantities that will support the Commonwealth's economy;

4. Establishes sufficient supply and delivery infrastructure to maintain reliable energy availability (DMME: maintain the existing plants, build the necessary pipelines and forget about wind and solar)in the event of a disruption occurring to a portion of the Commonwealth's energy matrix;

5. Removes impediments to the use of abundant low-cost energy resources located within the Commonwealth (DMME: protect our consumers from UNRELIABLE AND COSTLY WIND and SOLAR) and ensuring the economic viability of the producers, especially those in the Commonwealth, of such resources; and

6. Develops energy resources and facilities in a manner that will not impose an adverse impact on economically disadvantaged or minority communities(DMME: many consumers at or below the energy poverty level need to be protected from the costs of WIND and SOLAR).

The preoccupation with “virtue signaling” by imposing intermittent wind and solar on consumers by ignoring economics and technical reality is not a viable energy policy as discussed below.  

EPA’s announcement of the Affordable Clean Energy rule to replace the “Clean Power Plan” clears the way for Virginia to maintain its coal fleet.? The rule will achieve the same reduction in emissions as the CPP: 34% below 2005 without crippling existing coal plants or the resilience of our grid.

Contrary to the obligations set out in the VA statute, we import almost all of what we consume:

In 2017, natural gas fueled 50% of Virginia's net electricity generation, nuclear power provided 33%, coal fueled almost 12% and renewable resources, including biomass and hydropower, supplied more than 6%.

In 2016 the installed summer capacity was 26,662 MWe, generating 92,600,000 MWhrs net. Retail sales were 112,300,000 MWhrs at an average cost of 9.1 cents/kwhr (rank 34th nationally)

The 19,600,000 MWhrs of electricity imports amounts to 21% of the amount generated inside Virginia.To generate the shortfall, it will take an additional 3,000-6,000 MWe.?

80% of our natural gas (20% is supplied by coal bed methane, 120 bcf in 2016)…so we are dependent on interstate natural gas pipelines for supply to homes, businesses, industrial plants and utilities.

The unregulated division of Dominion operates an LNG EXPORT facility (Cove Point MD terminal) that diverts 5.1 Million Tonnes per Annum (MTPA) of Marcellus and Utica shale gas to foreign markets. Added East Coast shipments will amount to 36 MTPA. The total drain on East Coast supplies of natural gas will be 2 trillion cubic feet. The unregulated side of Dominion is in direct competition with the SCC regulated Dominion Virginia Electric in addition to residential, industrial, and business consumers of natural gas…an obvious and unacceptable conflict of interest.?

100% of our uranium…while we have a world-class uranium resource at Coles Hill that could fuel our nuclear plants for 75 years.?

100% of the petroleum and products…we at least had a refinery at Yorktown until it closed. Offshore exploration for oil and gas has been blocked. Shale gas exploration and production has been blocked.?

DMME must become an advocate for expanding our energy and fuel supply as required by law, including native base load electric generating plants using clean coal and uranium.?

Full economic analysis needs to be performed on each proposed addition to the supply system

DMME should rely on the SCC staff to perform the INDEPENDENT economic and grid reliability analysis of every new proposal. DMME needs to conduct a full Ratepayer Impact Measure (RIM) cost-benefit analysis to comply with the statutory requirement that the energy plan “(will) not impose a disproportionate adverse impact on economically disadvantaged or minority communities”. Virginia has a substantial number of seniors on fixed incomes and minorities that are at the energy poverty level or could be pushed into energy poverty as a result of wind and solar additions to the grid.

This economic analysis needs to include the full cost of hot standby backup for the unreliable wind and solar. 

US emissions have been reduced, contrary to the fake news

The United States announced its intentions to withdraw from the Paris climate agreement last year, but still reduced its carbon dioxide emissions more than any other country in the world in 2017. In fact, it was the ninth time in this century that the United States has had the largest reductions in carbon dioxide emissions in the world. U.S. carbon dioxide emissions declined by 0.5 percent or 42 million metric tons in 2017. It was the third consecutive year that carbon dioxide emissions declined in the United States.

The world largest emitter of carbon dioxide emissions is China, whose emissions increased by 1.6 percent in 2017—by 118 million metric tons, or almost 3 times as much as U.S. emissions were reduced. According to the BP Statistical Review of World Energy, China produces 28 percent of the world’s carbon dioxide emissions. India is the world’s third largest emitter of carbon dioxide and had the second largest increment (93 million metric tons) of carbon dioxide emissions in 2017, more than twice as much an increase as the U.S. reduction. Together, China and India accounted for almost half (212 million metric tons) of the increase in total global carbon dioxide emissions (426 million metric tons) in 2017. The world’s increase in carbon dioxide was more than 10 times the reduction of the United States.

True costs of wind are hidden

IER analysts found that from 2005 to 2014, the cumulative subsidy allocations from the PTC, ITC, and Section 1603 to the wind industry are at least $18.58 billion.

The study also found that over the last decade, taxpayers in 30 states and the District of Columbia paid more in taxes to the federal government to support wind subsidies than wind producers who own wind facilities in those states received in subsidy allocations.

Although the report discusses states and regions in terms of net losses and net subsidies to show the geographical distribution of federal wind subsidies, we note that the ultimate recipients are actually the owners of wind facilities, while losses accrue to all Americans who pay federal taxes. In other words, subsidies to wind producers come at the expense of all U.S. taxpayers.

Electricity from New Wind Three Times More Costly than Existing Coal

WASHINGTON – Today, the Institute for Energy Research released a first-of-its-kind study calculating the levelized cost of electricity from existing generation sources. Our study shows that on average, electricity from new wind resources is nearly four times more expensive than from existing nuclear and nearly three times more expensive than from existing coal. These are dramatic increases in the cost of generating electricity. This means that the premature closures of existing plants will unavoidably increase electricity rates for American families.

Grid security is a major issue for offshore wind

Dominion is proposing to “research” placing wind turbines offshore. We have trouble enough securing the onshore power grid. The notion of reliance on an array of turbines with unprotected power lines stretching 27 miles in the open Atlantic is a ridiculous concept.

Putting wind turbines in the Atlantic “hurricane alley” is an equally irresponsible concept. 

DMME needs to challenge the Dominion proposal pending before the SCC on these issues.

Offshore wind turbines threaten the viability of the VB Naval Air Station and coastal security 

Virginia Beach/Norfolk operations could be severely affected by the siting of wind turbines offshore. Radar can be blinded by the operation of wind turbines up to 80 miles. The Department of the Navy has raised the issue at Naval Air Station Patuxent that will be replicated in Virginia:

The Department of the Navy (DoN) believes that wind turbine projects could have an adverse impact on military operations and readiness in the NAS Patuxent River area, including critical Research, Development, Acquisition, Test, and Evaluation (RDAT&E) activities conducted by the Naval Air Warfare Center Aircraft Division (NAVAIRWARCENACDIV) operating the ADAMS and air traffic control (ATC) services provided by the DASR in Patuxent River, Maryland. 

Characterization of potential siting interactions: 

The primary areas of concern to NAS Patuxent River for wind turbine development are the Eastern Shore of Maryland, Virginia’s Eastern Shore, and the Atlantic offshore areas. 

Wind turbines operating within range of ADAMS will induce a Doppler shift to the ADAMS radar signal. In addition to the Doppler shift, the RCS of wind turbine blades detected by ADAMS is representative in size to that of a commercial aircraft, creating additional observable energy returns.These combined effects contaminate the intended target return signal, resulting in the rise of the “noise floor” which obscures targets, significantly degrading precise signature return measurements, and preventing validation of weapon system specific requirements. 

…wind turbines interfere with the radar’s ability to accurately detect and track primary radar targets. Wind turbines are highly reflective and can be detected by the DASR as flying objects. In addition, the energy return from wind turbine blades can confuse the radar system and cause it to dedicate excessive amounts of processing power on false targets at the expense of detecting real targets. 

Opposition to offshore wind plants is substantial

The presentation included information about the location of the existing and proposed wind farms in relation to the established commercial and recreational fishing grounds. Because the proposed location of the wind turbines is in close proximity to the shipping lanes for oil tankers and other cargo ships, the wind farms can be dangerous. It can be difficult to differentiate between a wind turbine, another vessel, or a super-tanker in the area because the electro-magnetic activity produced by the wind farms snarls radar and creates hazards for vessel traffic.

The wind farms also pose dangers to sport fishing such as the White Marlin Open—a tournament held in Ocean City each August. The 2017 tournament consisted of 359 vessels and 3,000 contestants. If the wind farms are constructed, the participating fishing vessels would have to go through the wind farms to get to the canyons.

Wind and solar plant footprints are a major problem

Dominion’s future plans call for a plant of 200 turbines. A nameplate capacity of 1000 MWe requires 169 turbines (Note: the utilization factor is between 30% and 40%). The spacing between turbines is between 7(inefficient interaction) and 15(efficient) times the rotor diameter. The rotor diameter for a 6 MWe turbine is 490 feet. Thus the spacing for the turbines is between 0.6 miles and 1.4 miles. The plant will require a footprint of up to 326 square miles. The exclusion zone will preclude passage between the turbines denying access to all boat traffic including fishermen.

The Spotsylvania solar plant requires 10 square miles for a 500MWe plant. The solar plant has a lower capacity factor (20%-25%) than a wind plant.

Over-reliance on natural gas is unacceptable

The opposition to new interstate natural gas pipelines is substantial. Virginia is dependent on these pipeline expansions. Delays and/or cancellation will undermine our critical supply system.?

Many of the opponents to the pipelines also oppose shale gas exploration and production, including the Marcellus in Virginia.



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