Agencies | Governor
Virginia Regulatory Town Hall
Department of Environmental Quality
Air Pollution Control Board
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Reduce and Cap Carbon Dioxide from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17)
Stage Proposed
Comment Period Ends 3/6/2019
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3/6/19  4:21 pm
Commenter: Jane Maxwell Twitmyer

Carbon Trading and the risks of continued fossil fuel use.

Thank you for this opportunity to again speak to the roadmap to Virginia’s energy that will be created if we limit carbon emissions.  I know and appreciate how important it is to listen to your community.

Reasons to leave natural gas and coal in the ground ...

  • Our coal plants should close.  90% of them have reached the end of their designated useful life,
  • Toxic coal ash ponds remain.  “Nine out of every 10 coal plants with reportable data have tainted nearby groundwater with at least one coal ash pollutant, with a majority having unsafe levels of at least four different toxins
  • The shale revolution Is now a ‘shale bubble.   The paradox of shale industry is that it has never made money despite the rapid growth of oil and gas production.  Low interest rates gave Wall Street the ability to fund a decade of oil and gas production via fracking, incentivizing production over profit. Investors are now worried.
  • Each fracked well requires between 2 and 10 million gallons of fresh water over its 2-3 year productive life.  This processed water cannot be returned to the water cycle as it contains deep earth elements such as radon.  The processed water is currently being reinjected into the earth where it is demonstrated to caused earthquakes.

More gas and new pipelines are not required ....

  • Dominion’s natural gas plants currently operating have contracts for the natural gas they require with another pipeline, including the gas for the new Greensville plant, and Dominion has canceled plans to build two major gas plants in the mid 2020’s as demonstrated by their latest IRP.
  • Load growth has failed to materialize as forecast. Dominion’s projected demand, based primarily on data center growth, ignores the fact that data center operators have made commitments to run on 100 percent renewable energy.

Alternatives to gas and coal can meet Virginia’s need for energy.

  • Buildings use 70+% of our region’s electricity.  Virginia ranks 26th among the states with a score of 16 out of 50 on the latest ACEEE rankings. “The state still falls well below the national average on energy efficiency program spending and energy savings.  Repeated attempts to introduce energy efficiency goals and resource standards have not been successful.” 
  • Efficiency could produce a meaningful reduction in electricity demand. Most projections see a possible 30% reduction in the amount of electric energy we use by 2030. Pipelines are built to last for 40-50 years. Scientists tell us we must decarbonize completely in 30 years.               
  • Virginia’s untapped renewable resources include ...... Both offshore wind and rural solar which can each produce more electricity than Virginia currently uses.  Rooftop solar can meet 25% of Virginia’s demand, according to NREL
  • Within 5 years batteries will compete and win against gas ‘peaker plants’.  The all Republican Arizona board of regulators sent their utility back to the drawing boards to examine a storage alternative for meeting peak demand. In Florida, North Carolina and New Hampshire regulated utilities have begun factoring substantial amounts of storage into their grid planning in order to tackle peak demand.
  • The synergistic combination of offshore wind with solar is another alternative way to meet demand now met with gas ‘peaker’ plants.  Rooftop solar combined with Virginia’s extraordinary offshore wind resource can meet all of our summer peak demand.

When measuring the level of tolerable risk contained in the continued use of fossil fuel, Climate Change is the greatest risk.  Hampton Roads in now a national leader in designing ways to address the effects of climate change the area is beginning to experience; the recurrent flooding that comes with sea level rise.  Norfolk, where sea level rise is combined with land subsidence, is one of the worst positioned places on our U.S. coastline.  The area has help from the Navy, but their problems are not theirs alone.  The rest of the state needs to step up and address our contributions to climate change, including our continued reliance on fossil fuels.

Your leadership, as one of our regulators, is absolutely necessary. Carbon trading with increasing limits on carbon emissions is a start.

Thank you

Jane Maxwell Twitmyer