Category Archives: Energy

Rappahannock Water Quality Endangered by Fracking?

Rappahannock River

Rappahannock River. Image credit: American Rivers.

American Rivers has listed the Rappahannock River as the fifth “most endangered” river in the United States. The environmental group claims the river is threatened by industry interest in hydraulic fracturing (fracking) operations in the Taylorsville Basin lying thousands of feet beneath the river. The quality of drinking water of three million people in eastern Virginia are at stake.

The Rappahannock joins company with the Lower Colorado River (the most endangered), which is threatened by excess water consumption; California’s Bear River, which is imperiled by a new dam; the South Fork Skykomish River in Washington, which is jeopardized by a new hydropower project; and six other rivers. These rivers are not necessarily the most polluted. Rather, American Rivers highlights in its “America’s Most Endangered Rivers 2017” report ten rivers whose fates will be affected by the political process in the upcoming year.

The watershed of the Rappahannock, the longest free-flowing river in Virginia, encompasses all or parts of 18 counties, the report notes, and supports thriving agricultural and seafood sectors as well as recreational activity.

American Rivers is concerned that 85,000 acres in five counties along the tidal Rappahannock are leased for oil and gas exploration. Only one of the five counties has enacted a land use ordinance to protect against the impact of fracking. Last year, Governor Terry McAuliffe approved new regulations that would require baseline water testing and monitoring along with the disclosure of any chemicals used in the fracking process. The oil and gas lobby introduced legislation to weaken the regs in the 2017 General Assembly session, but the effort was beaten back. Says American Rivers:

It is clear that the threats that industrial gas development and fracking pose to the rural and agricultural communities along the Rappahannock River are not going away. The first line of defense lies with local government, which has the power to establish local protections to protect the drinking water for millions of citizens.

Last  year Prince George County amended its zoning ordinance to require hefty setbacks for gas wells, effectively making 91% of the county unavailable for drilling. But Westmoreland, Essex, Caroline, and King and Queen Counties have yet to act.

Here’s the source of concern: Gas companies must drill through the Potomac Aquifer to reach the gas in the Taylorsville Basin, which is reported to contain more than 1 trillion cubic feet of gas, equivalent to two-and-a-half times the volume of gas consumed in Virginia in a year. Fracking injects sand and chemicals under high pressure to fracture the rock sufficiently for oil and gas to flow through it. Although oil and gas companies seal off drill holes where they pass through aquifers, environmentalists claim that potentially toxic chemicals still can leak into the Potomac Aquifer and, from there, eventually into the Rappahannock River.

Bacon’s bottom line: Environmental groups are adamant that fracking represents a danger to the aquifer and water supply. The oil and gas industry is equally insistent that fracking poses minimal risk. Each side cites seemingly authoritative studies. Who knows?

The Taylorsville Basin contains maybe one-fortieth the volume of gas contained in the famed Marcellus Basin, which has transformed energy economics in the United States, but it’s nothing to sneeze at. The gas has an economic value of $2 billion to $4 billion, maybe more, depending upon the current price of natural gas. That represents a lot of economic activity for five economically depressed rural counties.

Admittedly, a billion dollars or so in local payroll and royalties won’t be much consolation if fracking ruins the water supply. But more than 8,000 wells have been hydraulically fractured in Southwest Virginia with no documented instances of surface or groundwater contamination, according to state geologist David Spears.

The McAuliffe administration made a prudent decision, it seems to me, to establish a baseline of data on Potomac Aquifer water quality and to require gas companies to disclose the chemicals they use in fracking. If chemicals used in fracking are not found in the aquifer but suddenly appear after drilling begins, it is not unreasonable to conclude that fracking created the problem. Conversely, if none of the chemicals show up in the aquifer, no harm is likely being done.

Regardless, the American Rivers report signals that the Taylorsville Basin is on the radar screen of national environmental groups. I expect they will pour considerable resources into fighting development of the basin. Linking that fight to the conservation of the treasured Rappahannock River is shrewd public relations.

What’s Next for the Pipeline Controversies?

DEQ will tighten erosion regulations on steep slopes like this for construction of the proposed Atlantic Coast Pipeline and Mountain Valley Pipeline in Virginia.

Virginia’s DEQ will pay close attention to construction on steep slopes like this for the proposed Atlantic Coast Pipeline and Mountain Valley Pipeline.

With the announcement last week that Virginia’s Department of Environmental Quality (DEQ) would provide closer scrutiny of water-quality standards than legally required, battles over the Atlantic Coast Pipeline and Mountain Valley Pipeline shift from the federal level to the states.

Foes of the natural gas pipelines have failed so far to block the projects in the federal permitting process. The Federal Energy Regulatory Commission, which approves or denies interstate pipeline projects, found in separate draft environmental impact statements that, with appropriate mitigation, the ACP and MVP projects can be reduced to “less than significant levels.” DEQ’s announcement throws environmental and citizen groups a lifeline by giving them another shot at blocking the pipelines.

“We are confident that a full-fledged review of the projects will show that there is no way they can be built and operated without harming water quality, said Mike Tidwell with the Chesapeake Climate Action Network in a press release. “Allowing public input will further highlight the enormous public opposition to the MVP and ACP.”

“It’s a big announcement, and we’re very happy about it,” David Sligh, regulatory system investigator with the Dominion Pipeline Monitoring Coalition (DPMC), told Bacon’s Rebellion. “DEQ cannot issue a certification for the ACP as a whole without accounting for all the water bodies affected. .. It’s a huge chore. … I do not think it’s possible for either ACP or MVP to do what they propose to do and meet water quality standards.”

The ACP and MVP response to the DEQ announcement has been muted. “Throughout this process, we’ve worked with state and federal agencies to ensure the project receives a thorough environmental review with robust public participation,” said ACP spokesman Aaron Ruby. “We stand ready to work cooperatively with DEQ on an efficient review and timely process.”

In the Byzantine regulatory process governing interstate pipelines, FERC relies upon the U.S. Army Corps of Engineers (COE) to review water crossings for impact on water quality. DEQ had the options of deferring to the COE, of issuing a general permit that calls for basic protections to be met, or of undertaking its own in-depth review. In choosing the in-depth analysis, DEQ will hold additional public hearings and provide more time for citizens to provide input.

The main issue, according to the DPMC and other activist groups, is that general permits do not adequately address the challenges of massive pipeline projects that cross hundreds of water bodies. Construction, which entails the digging of trenches, is particularly problematic where steep mountain slopes elevate the risk of landslides and erosion that release sediment into rivers and streams, and in sinkhole-ridden karst terrain, where polluted water can travel undetected before surfacing miles away. Steep slopes and karst are characteristic of the mountains of western Virginia where both pipelines would cross.

Sligh told of a colleague who walked a section of the proposed Mountain Valley Pipeline route with a local resident and found three or four springs that state and federal agencies were unaware of. It is imperative, he says, that citizens with in-depth local knowledge of the terrain be given a chance to provide input on how the pipelines propose to deal with each specific stream crossing.

Pipeline foes have had little luck in either North Carolina or West Virginia, the other two states impacted by the pipelines. The West Virginia Department of Environmental Protection has granted a water-quality permit for the 195-mile segment of the Mountain Valley Pipeline that runs through the Mountaineer state. Little opposition to the pipelines has surfaced in North Carolina. That leaves Virginia as the stopgap.

If DEQ sides with the pipelines, the battle still is not necessarily over. In West Virginia, Mountain Valley Advocates, an anti-pipeline group, seeks a hearing with West Virginia regulators to dispute the department’s issuance in March of MVP’s water-quality certification. If that bid fails, environmental groups have the right to sue. But the odds of stopping the pipelines seem to get longer with each passing day.

A Good Year for Retail Solar in Virginia

It's not everything environmentalists wanted, but a new law will create new retail solar options for consumers.

It’s not everything environmentalists wanted, but a new law will create new retail solar options for consumers. Photo credit: VA SUN

  • A collaborative process involving utilities, solar developers and environmentalists broke the legislative logjam thwarting the growth of retail solar in Virginia.
  • A new law will enable electric customers to subscribe to green electricity built by independent developers.
  • The same process will be used to tackle tough issues like net metering.

So, you want to help save the world from global warming but you’re stymied from installing solar panels atop your house. Maybe you rent the place. Maybe trees are shading the roof. Maybe you’re planning to move soon. Or maybe you just don’t have the money.

There are many reasons why even the most zealous green power advocates are stuck buying the same regular, garden-variety electricity as everyone else. But now, thanks to legislation passed in the 2017 General Assembly session, Virginia energy consumers soon will have a new option — subscribing to solar power rather than owning it outright.

SB 1393 requires Dominion Virginia Power and Appalachian Power to create solar programs in which the utilities bundle electricity from community solar projects — typically small solar farms or large rooftop arrays — and resell it to customers. Under the new plans, customers pay monthly knowing that their dollars are supporting development of solar facilities near where they live. If more customers subscribe, more solar farms will be built.

The scheme benefits small-scale solar developers as well. They don’t have to worry about signing up subscribers and the hassle that goes with billing and collections. It’s up to us to develop a program that’s attractive to subscribers,” says Katharine Bond, senior policy advisor for Dominion. The arrangement even works for rate payers who have no interest in going green. Says Bond: “The only people who bear the cost are those who elect to participate.”

The legislation represents a genuine step forward for retail solar in Virginia. “At the end of the day, I think it’s a really good policy that will benefit Virginians,” says Mike Town, executive director of the Virginia League of Conservation Voters. Equally important is the way in which utilities, solar developers and environmental groups sat down to work it out. “It’s precedent setting. It will lay the groundwork for progress down the road.”

While Virginia’s utilities are building large, utility-scale solar projects, state laws and regulations have made it all but impossible for independent developers to create smaller projects and sell electricity to individual businesses and households. Every year solar backers have submitted bills in the General Assembly to open up the market, and every year the legislation has been beaten back. Utilities have opposed measures that would cut into their monopoly in retail electricity sales.

In the 2016 General Assembly session, legislators submitted several retail solar bills that failed to pass. This time, lawmakers asked the utilities and solar industry to work on a compromise and come back with a proposal that would fare better in 2017. Dominion Virginia Power, Appalachian Power, and Virginia’s electric co-ops sat down with representatives of the solar energy to negotiate legislation that would let independent solar developers into the game.

Mark E. Rubin, director of the Virginia Center for Consensus Building at Virginia Commonwealth University, was hired to facilitate the dialogue. As the industry groups approached agreement, Rubin invited environmentalist groups to join the conversation. They injected important perspectives that would win the support of the environmental lobby.

“I think the general view was that this process turned out to be a helpful way to get together and work through issues,” Rubin says. “Just the idea that you had different stakeholders siting around the table having very candid, very productive discussions was a big deal in and of itself.”

The legislation doesn’t make everyone happy. In theory, existing Virginia law allows independent companies to sell renewable electricity to customers if neither Dominion nor Apco have tariffs to do so. Delaware-based Direct Energy filed a petition last year for declaratory judgment with the State Corporation Commission, asking the regulatory body to clarify the company’s rights under Virginia law to sell electricity to Dominion and Apco customers. The SCC ruled earlier this year that it could, but only as long as the utilities weren’t doing it. If utilities entered the market, Direct Energy could continue serving existing customers but couldn’t sign up new ones.

“It can take months or years of marketing for a third-party supplier to build up enough of a customer base to make the whole effort worthwhile, so the SCC’s ruling makes the Virginia residential market much less attractive,” writes Ivy Main, editor of the Virginia chapter of the Sierra Club’s “Power for the People” blog. Continue reading

Property Tax Assessments Could Sabotage Virginia’s Solar Industry

Outlook murky.

A quirk in the way the state treats the value of solar energy projects for tax purposes could throttle Virginia’s solar industry in its infancy, according to an analysis prepared by SolUnesco, a Reston-based developer of solar energy projects.

In theory, a major investment in solar energy should benefit the jurisdiction where the project is located by generating significant new property tax revenues. But under current practice, any gain in revenue for a locality would be more than offset by cuts in state support for public schools. If local governments calculate that solar projects will cost them revenue rather than boost their tax base, they will have a strong incentive to deny necessary permits rather than approve them.

“Bureaucratic bookkeeping might grind solar development to a halt,” states a SolUnesco white paper, “The Composite Index and How It Relates to Solar Development in Virginia.”

SolUnesco has proposed building an 11-megawatt solar facility in Albemarle County, but the county zoning code prohibits solar farms. The Board of Supervisors has asked the county planning commission to study the issue. A repeal of the restriction might encounter opposition from NIMBYs intent upon protecting the rural character of the county, as I blogged here. Albemarle’s decision could well hinge on its calculus of whether the project will benefit or hurt the county fiscally.

Under state law, solar energy projects are assessed for property tax purposes as “certified pollution control equipment.” That qualifies solar farms for an 80% reduction in property taxes. That exemption improves the economics of solar projects but it reduces the tax benefits to local governments.

By contrast, the state Department of Taxation counts the full market value of solar farms when calculating the Composite Index (CI), which is used to measure local governments’ relative fiscal health and ability to support public K-12 education. The state distributes state support for education on a sliding scale that gives a higher share to localities with a low CI (a smaller real estate tax base per capita) and a smaller share to wealthier jurisdictions. As SolUnesco summarizes: “Increased taxable property increases the Composite Index, which reduces the share paid by the state.”

So, how does that work out in practice? SolUnesco provides the hypothetical example of a solar project that creates taxable value of $100 million. Here’s how the numbers work out for a “representative county.” The county generates $80,000 in new tax revenue on $20 million of assessed value. But the county would lose $147,597 in state funding for schools based on the full $100 million added to the Composite Index. The net loss: $67,597.

If the Department of Taxation used the same value as the local government in calculating the Composite Index, our hypothetical county would experience a $52,083 revenue gain.

“Counties that have permitted utility-scale projects may regret their decision if they believe these projects will result in a net revenue loss,” states the white paper “Many projects have received their county [conditional use] permit, but many have yet to file for their building, electrical and other construction permits.”

“The state is aware of this inconsistency in their treatment of tax exemptions,” says SolUnesco. The Department of Taxation, Department of Education, and the State Corporation Commission “are all working together on a resolution.”

Will NIMBYs Thwart SolUnesco Solar Plan?

SolUnesco CEO Francis Hodsoll addresses the Albemarle County Board of Supervisors

SolUnesco CEO Francis Hodsoll addresses the Albemarle County Board of Supervisors. Photo credit: Charlottesville Tomorrow.

Not all barriers to solar energy emanate from Richmond. Take Albemarle County, for example. The county zoning code outlaws solar farms, we learn from Charlottesville Tomorrow.

“The current zoning ordinance allows for the transmission and distribution of energy, but not the generation of energy,” said county planner Margaret Maliszewski at Wednesday’s Board of Supervisors meeting.

The issue arose because Reston-based SolUnesco wants to submit an application to develop an 11-megawatt photovoltaic solar energy generation system in southern Albemarle. “Our project is for the wholesale supply of energy that goes onto a wholesale network of transmission and distribution lines and that allows people to buy energy from our project or for a utility to buy energy directly from us,” said SolUnesco CEO Francis Hodsoll.

Albemarle Supervisors directed the planning department to study the issue. But, while the Charlottesville-Albemarle area may be home to many solar-loving greenies, don’t take it for granted that county planners will roll over for SolUnesco.

“As a member of a rural neighborhood, the first thing that comes to mind is protection of the rural areas,” said Phillip Fassieux at the board meeting. “We all love solar power, but at what cost? … “How will residents of Albemarle benefit specifically from turning over part of our rural county to its use? Will we see reductions in electricity rates?”

Everyone loves solar in theory, but opposition frequently surfaces locally when someone proposes building a solar farm near them. Others object to the idea of vast solar farms displacing agricultural uses of the land. SolUnesco’s proposed 11-megawatt solar farm, big enough to supply demand for about 2,000 households, would require between 70 and 80 acres of land. Typically, solar farms include vegetated buffer zones to screen the solar panels from view.

(Another potential objection to solar is that, given the state formula for distributing school aid, a big capital investment in solar could actually hurt a county financially. I’ll deal with that issue in a separate post.)

Bacon’s bottom line: Call me a Neanderthal, but I support private property rights. I see no justification for Albemarle County — or any county — to impose zoning restrictions prohibiting solar farms. If a property owner decides that installing solar panels represents a use of land preferable to agriculture or timber, that should be his decision to make. Counties have no business intervening unless the land use creates a nuisance to neighbors. Unlike wind turbines, solar panels create no noise, are easily hidden from view, and don’t harm wildlife. NIMBYs need to get a life.

And one more thing… The SolUnesco pitch to landowners asserts that its 25-year leases will generate above-market returns for landowners with an inflation escalator. The company assumes all costs and risks associated with developing the project — the landowner just collects checks for 25 years.

Rural Virginia is hurting. It has few resources of value in the knowledge economy. One thing it does have is land. Solar energy represents a rare opportunity for Virginia’s rural economy. There are many complex issues surrounding the integration of solar into the electric grid that need to be resolved before we see widespread deployment, but land use should not be one of them.

The Right Way to Test for Coal Ash Contaminants

A North Carolina riverkeeper inspects testing samples of coal ash taken from the Dan River.

A North Carolina riverkeeper inspects testing samples of coal ash taken from the Dan River. Photo credit: WRAL.

So, it looks like the there will be a pause in the solid-waste permitting process for Virginia coal ash. Governor Terry McAuliffe had submitted an amendment to legislation that, if approved, would require Dominion Virginia Power to compile more information on contamination around its coal ash sites and study alternative closure methods before the state issues the permits. Now Dominion has decided to go along, which means political opposition to the idea could evaporate.

“We concur that it is a prudent course of action to seek and consider an evaluation of the assessments on the appropriate closure methods based on the individual features of each site before seeking necessary solid-waste permits,” wrote Dominion CEO Thomas F. Farrell II. “Dominion finds the proposed amendments to Senate Bill 1398 to be workable, and is committed to completing the site assessments before pursuing solid waste permits regardless of the outcome of the legislation.”

McAuliffe’s amendment would restore key provisions to a bill co-sponsored by Sens. Scott A. Surovell-D-Fairfax, and Amanda F. Chase, R-Chesterfield, whose legislative districts include Dominion’s Possum Point Power Station and Chesterfield Power Station, each of which has millions of tons of coal ash to dispose of. (See the Richmond Times-Dispatch story here.)

Dominion had originally opposed the testing and study provisions, which were stripped out by the House of Delegates. But if the power company drops its opposition to McAuliffe’s amendment, as Farrell’s letter indicates, Surovell and Chase likely will get their way.

According to the bill summary, HB 1398 will require owners of coal ash ponds (1) to identify water pollution emanating from the ponds and address corrective measures, and (2) evaluate the feasibility of “clean closure.” Clean closure would entail removing the coal ash from ponds where it has been stored to lined landfills. Dominion has estimated that the cost of landfilling could amount to $3 billion, but environmental groups have argued that the cost would be much lower if the utility recycled the material as an additive to cement and other products.

Bacon’s bottom line: Pausing the permitting process to get a better handle on what’s happening at the coal ash ponds is a good idea. Frankly, despite considerable testing by both Dominion, environmental groups and even Duke University, little can be said with certainty about the process at each of Dominion’s four sites by which groundwater migrates through the coal ash and contaminates either well water or nearby rivers and streams.

Any testing regime must be rigorous enough to provide definitive answers. The last thing we need is set of ambiguous results that Dominion and environmental groups try to spin to their advantage in another contest of P.R. and political clout. Any credible testing program should outside experts, perhaps from Duke or perhaps from a Virginia university, who can identify the questions that to be answered and what protocols will provide definitive answers.

Dominion has conducted tests on its property and found little evidence of contamination at Possum Point, Chesterfield and the Bremo Power Station, but a federal judge recently used Dominion data to conclude that coal ash its closed Chesapeake plant was contaminating groundwater. Testing by riverkeeper groups of groundwater and surface waters just outside of Dominion property show elevated levels of heavy metals which, at sufficient concentrations, can be toxic to aquatic life and human health. Additionally, Duke University has conducted extensive testing in North Carolina and Virginia using “forensic tracers” that have found elevated levels of heavy metals in groundwater near Bremo and Chesapeake. But other Duke tests have found that elevated levels of the carcinogen hexavalent chromium, also associated with coal ash, is endemic in piedmont groundwater and in many cases cannot be attributed to the coal combustion residue.

Complicating any analysis is the fact that trace levels of heavy metals and carcinogens are frequently found in groundwater and surface water as the result of natural processes. Levels vary depending upon local geology. The existence of trace elements of heavy metals in groundwater near coal ash ponds is not in itself proof that the heavy metals came from the coal ash. The trace elements could be ubiquitous in the area, but no one knows unless tests are conducted some distance from the power plants. Ideally, any testing regime for Dominion’s coal ash ponds would adjust for background levels of contaminants.

Another complication is ascertaining the movement of groundwater. For example, the water from several wells near Possum Point have shown elevated levels of heavy metals. It is easy to deduce from the proximity of the wells to coal ash ponds that the contaminants come from the ponds. But to demonstrate the point conclusively, one must show that the groundwater migrates from the coal ash ponds toward the wells, and not in some other direction. To make that proof, it is necessary to conduct extensive drilling and create detailed maps that mark the geographic scope and elevation (in feet above sea level) of the underground water and determine the direction of the water flow. Only if it can be documented that underground water is migrating from the coal ash pond toward the wells can one reasonably conclude that the coal ash is to blame for elevated levels of well-water contaminants. If the water is migrating away from the wells, the well-water contaminants probably have another source.

Adding another layer of complexity to the analysis is estimating how much contamination the groundwater picks up while migrating through coal ash. Dominion maintains that its coal ash pits do not come into contact with the water table; the deepest part of the ponds have a higher elevation than the underground water table. However, using Dominion’s own maps, the Southern Environmental Law Center (SELC) contends that the bottom reaches of the coal ash ponds at Bremo and Chesterfield intersect with the water table. If the SELC is right, groundwater that migrates through a portion of the coal ash could pick up contaminants along the way.

The question then arises, how long must the water be in contact with the coal ash in order to pick up trace metals? That is a function of the chemistry of the coal ash, how tightly or loosely the metals are bound to inert materials, and the speed of water migration, which depends upon the permeability of the clays and rocks. If the groundwater comes into contact with only a small percentage of the coal ash for a short time, the leeching of heavy metals could well be minimal.

If it can be demonstrated that measurable levels of metals leach into the groundwater, another question must be answered: What volume of contaminants, and how rapidly, does the groundwater feed into surrounding rivers and streams? While U.S. District Court Judge John A. Gibney Jr. found that Dominion’s Chesapeake Coal ash ponds did contaminate the groundwater and that the groundwater did reach the Elizabeth River in violation of the Clean Water Act, he also found no damages because the contaminants were so diluted by the massive water volume of the river that aquatic and human health were unaffected. Continue reading

Electric Reliability and Energy Mix

 Portfolios with high mixes of coal, nuclear and natural gas have the greatest electric reliability.

The purple line shows the Composite Reliability Index (CRI) of different energy-mix portfolios. Portfolios with high mixes of coal, nuclear and natural gas have the greatest electric reliability. Portfolios with large wind components tend to be more reliable than those with solar.

Electric utilities in the 13-state PJM Interconnection regional transmission territory have a balanced resource mix — coal, nuclear, gas and renewables — that is “well equipped” to support reliable operation of the regional grid, PJM has found in a new report, “PJM’s Evolving Resource Mix and System Reliability.”

But continued evolution of the resource mix — particularly the decommissioning of coal and nuclear plants and increasing reliance upon natural gas and renewables — could create reliability issues in the future.

PJM is in charge of maintaining the integrity of the electric grid within its territory, which includes all of Virginia. The study analyzed a spectrum of “portfolios” with different fuel mixes to see how they would affect a variety of electric reliability attributes such as voltage control, frequency response, and the ability to ramp production up and down as needed.

Of particular relevance to the ongoing energy debate in Virginia, PJM found that portfolios with 20% or greater of solar energy in the fuel mix would be “infeasible” because they would be unable to reliably meet night-time requirements. There don’t appear to be any upper bounds for natural gas, but excessive dependence upon gas could create vulnerabilities under a “polar vortex” scenario of sustained, bitterly cold temperatures.

In Virginia, Dominion Virginia Power has emphasized the importance of fuel source diversity, including coal and nuclear. Dominion’s plans for nuclear, which include extending the longevity of its Surry and North Anna nuclear units by an extra 20 years and possibly building a third nuclear unit at tremendous expense at North Anna, have proven particularly contentious. Solar constitutes a small percentage of Virginia’s fuel mix but is fast growing, and environmentalists are pushing for a much bigger role.

Across the PJM region, notes the study, the fuel mix has become more evenly balanced over time. In 2005, coal and nuclear generated 91% of the energy on the PJM system. But between 2010 and 2016, extensive coal capacity was retired and replaced mainly with gas and renewables. PJM’s installed capacity in 2016 consisted of 33% coal, 33% natural gas, 18% nuclear and 6% renewables and hydro. PJM has said in the past that the transmission grid was flexible enough that it could accommodate up to 30% renewables.

Each fuel source has advantages and disadvantages in helping electric utilities balance electricity supply and demand while sticking to tight parameters for frequency and voltage. Coal and nuclear are less responsive to changes in demand, taking far longer to ramp production up and down. Wind and solar are easy to turn off but, due to the variability of the wind and sun, cannot be turned on at will. Natural gas tends to be the most flexible, and PJM’s most reliable portfolios include large contributions from gas. Electric batteries also would provide considerable flexibility, but PJM does not foresee them being deployed on a large scale within the time-frame of the study.

States the study:

  • Portfolios with the lowest unforced capacity shares of wind and solar tend to have the lowest composite reliability indices. (Note: “unforced capacity” refers to capacity in normal operating conditions as opposed to maximum “nameplate” capacity.)
  • Composite reliability indices generally improve as capacity shares of nuclear, coal and natural gas increase.
  • When coal and nuclear units are retired and replaced, portfolios with the highest composite reliability indices tend to be ones in which natural gas is the predominant replacement resource.

Bacon’s bottom line: PJM makes no judgment about the “best” fuel source mix, and it does not say that the most reliable fuel mixes are necessarily more desirable. If the goal is to increase renewables for reasons of reducing CO2 emissions, it is possible that some fuel mixes are reliable enough to accomplish both reliability and sustainability objectives.

Still, the PJM analysis suggests that high-renewable fuel mixes are “at risk for underperformance” and likely will need “additional technology requirements and/or new market rules” to ensure electric reliability.”

Avoiding Blackouts with a Remedial Action Scheme

Under its "Remedial Action Scheme" Dominion may not have to implement rolling blackouts in the Peninsula on high-risk days.

Under its Remedial Action Scheme Dominion may not have to implement rolling blackouts in the Peninsula on high-risk days.

Two years ago Dominion Virginia Power warned of dire consequences to the Virginia Peninsula if the company could not build a 500 kV transmission line across the James River. An analysis prepared by engineering consulting firm Stantec and submitted to the U.S. Corps of Engineers left little to the imagination:

Dominion will be required to implement pre-contingency load shedding (i.e. rolling blackouts) in the [North Hampton Roads Load Area] to prevent the possibility of cascading outages impacting the reliability of the interconnected transmission system. … It is estimated that rolling blackouts would initially occur 80 days a year and would continue to increase in number as load continues to grow in the area. …

The potential exists that up to 50% of the customers in this load area could be without electricity for days or even weeks until the event which caused the failure could be fixed.

Yesterday I posted an article based on an interview with Steve Chafin, Dominion director of transmission planning and strategic initiatives, that seemed to tell a different story. While the utility still said the Peninsula will be at risk for 50 to 80 days a year after shutting down the Yorktown Power Station’s No. 1 and No. 2 generators April 15, the ability to continue running the No. 3 generator up to 29 days a year will reduce that threat to about 50 days. Only if an unplanned event knocked out a transmission line — something that has happened only six times the past ten years — on one of those days would Dominion have to shed load. While there are no guarantees, Chafin told me, “We think we can get through the summer without any rotating blackouts.”

After publishing the article, I got to thinking about the marked difference in tone. Two years ago, when Dominion was trying to push the Surry-Skiffes project through regulatory approval in the face of intense opposition by preservationists, the company was stressing how disastrous things would be if the project wasn’t built. Now that the permit review by the Army Corps of Engineers is reaching its final stages and a mitigation settlement seems imminent, Dominion is downplaying the risk.

Yesterday I asked Chafin and Le-Ha Anderson, a Dominion spokesperson, to explain the change in rhetoric. They stand by what Dominion said then, and they stand by what Dominion says now, and they say there’s a legitimate explanation.

The difference between then and now is that Dominion has set up a Remedial Action Scheme (RAS).

Dominion worries about an uncontrolled, cascading blackout emanating from the Peninsula, the most vulnerable zone in the Dominion electric system and one of the most fragile in the 13-state PJM Interconnection territory. If blackouts erupted there, Dominion’s grid models can’t predict where they would stop. The United States conceivably could experience an outage as widespread as the infamous 2003 Northeastern blackout that knocked out power to millions.

With approval from the Southeastern Electric Reliability Council and PJM Interconnection, Dominion has set up an RAS to isolate the Peninsula if an unplanned outage occurs. “We put in an automatic, specialized relay scheme,” says Chafin. “If it senses certain conditions, it will immediately drop load to 150,000 customers.” The draconian action will prevent a cascading shut-down of transmission lines emanating from the Peninsula to points beyond.

Before the Remedial Action Scheme, Dominion would have had to implement rotating blackouts on high-load days before a component failure or other disruption occurred. Because the RAS responds immediately when needed, it allows Dominion to implement blackouts after the disruption.

While implementation of the RAS under a worst-case scenario would cause a massive outage on the Peninsula, it would nip in the bud an uncontrolled blackout that could rip through the nation’s electric grid. The chances of it occurring are remote, however, and it reduces the necessity of initiating precautionary, controlled blackouts when the Peninsula region reaches peak electric load some 50 or so times a year.

“We have a responsibility to provide reliability to our customers. We have an equally important responsibility to protect the safety and integrity of the grid,” Chafin says. “The automation will help to reduce the risk on a short-term and temporary basis.”

The Remedial Action Scheme will be available until the Surry-Skiffes transmission line receives regulatory approval and construction is complete, a process that will take at least another 18 months.

“We’ve been working on a Peninsula solution for a long time,” says Anderson. “We filed in 2013, and have worked with the Corps for almost four years. This is a serious situation. … We’ve had to look at what other things we can do in the meantime. This is a temporary, short-term tool that will help get us through the most critical period.”

Time to Panic Over the Closing of Yorktown Units? In a Word… No

Yorktown Power Station.

Yorktown Power Station. Photo credit: Daily Press

The day, April 15, is fast approaching when Dominion Virginia Power will be compelled by federal regulations to shut down two coal-fired generating units at the Yorktown Power Station, exposing the Virginia Peninsula to the risk of blackouts.

When the Yorktown units are shuttered, the utility will have enough electric power to supply the half million-person region from the outside most of the time. But during periods of peak demand, usually during the summer, an accident knocking one of those lines out of commission will put the region only one more incident away from uncontrolled, cascading blackouts that could spread to Norfolk, Richmond and beyond. Rather than incur any chance of disaster, PJM Interconnection, the organization that controls the transmission grid for a 12-state region that includes Virginia, would “shed load” — in other words, cut off electric power to some residents and businesses on the Peninsula.

Dominion’s proposed backup, the Surry-Skiffes transmission line, remains in a state of regulatory limbo while the U.S. Army Corps of Engineers negotiates ways to mitigate the line’s impact on a near-pristine stretch of the James River near Jamestown. Even if the Corps gave Dominion a permit tomorrow, it will take 18 months — and two summers — before the line can be built.

If I were a Peninsula business or resident, I’d be wondering, is it time to panic yet? I put the questions to Dominion: How frequent will the blackouts be and how bad will they be?

The answer: The threat is real but small in any given year, and a blackout, if it occurs, is likely to be limited in scope and duration. However, while the Peninsula might skate through the next year or two without a blackout, the situation is intolerable over the long run, Dominion warns. The Peninsula is the region most exposed to blackouts in the Dominion system and possibly the most vulnerable in the entire PJM transmission grid.

“This is a serious situation,” says Steve Chafin, Dominion director of transmission planning and strategic initiatives. When three things come together — (1) temperatures are running high, (2) the Yorktown 3 unit isn’t running, and (3) an accident knocks out a transmission line or sub-station — PJM likely will have to shed load.

Assuming normal weather conditions, the Peninsula will experience between 50 and 80 “high risk” days, Chafin says. Peak consumption is likely to occur in the summer, when temperatures are highest, although a few days may occur in the winter when temperatures are extremely low.

Although the company is closing two coal-fired units, the Environmental Protection Agency will allow it to run Yorktown 3, a oil-fired unit, 8% of the time, or up to 29 days. Using Yorktown 3 as a backup will reduce the number of vulnerable days to between 20 to 50.

Transmission lines to the Peninsula have been knocked out by accidents, component malfunctions or other causes six times in the past 10 years — an average of once every 20 months. (There have been two incidents in the past 10 years in which two simultaneous outages occurred.)

To reduce the odds of such mishaps shutting down a transmission line, the utility has been increasing its patrols of electric lines, boosting sub-station inspections and running infrared scanner. “This is not a normal mode of operation,” says Chafin. “We don’t patrol our transmission lines this frequently.”

If a once-every-twenty-months line outage occurs during one of the 20 to 50 at-risk days of heavy consumption when Yorktown 3 isn’t running, the electric grid will be at risk of an uncontrolled, cascading blackout. PJM, working in coordination with Dominion, will decide whether or not to shed load.

Should it become necessary to cut electricity consumption, the goal will be to disrupt as few people as possible and spare critical infrastructure such as hospitals and water treatment plants. PJM and Dominion would continuously run contingency models to determine the best course of action.

“Our goal is to avoid the need for temporary service interruptions, but should it become necessary, we will do all we can to limit the number of customers and duration,” Chafin says. “In the end, these are temporary measures to protect the larger grid from widespread, uncontrolled outages.”

Should blackouts occur, they likely would not last all day or affect the entire Peninsula. The company would close no more circuits than needed to drop electricity consumption to within a safe range. Giving a hypothetical example, Chafin says, “We might do two or three blocks of circuits of a few thousand customers for an hour or two.”

Dominion also would ask Peninsula customers to voluntarily conserve electricity.  “The more the conservation, the shorter the duration and the fewer people affected,” he says.

With a little luck the Peninsula might escape unscathed, Chafin says. “We’re running drills to make sure we’re ready. We think we can get through the summer without any rotating blackouts.”

Chesapeake Coal Ash Ruling — Advantage Dominion

Judge John A. Gibney Jr.

My initial reaction to Judge John A. Gibney Jr.’s ruling in Virginia’s first coal ash-related federal court case was to call it a draw. As I blogged yesterday, both the Sierra Club and Dominion Virginia Power found aspects of the judge’s order that supported their positions. But as I sort through the implications for the ongoing debate over coal ash in Virginia, I’m thinking that Dominion was the real winner in the long run.

True enough, the Sierra Club and its attorneys with the Southern Environmental Law Center (SELC) did win one important tactical victory: Gibney found that arsenic-tainted groundwater passing through the coal ash ponds at Dominion’s former Chesapeake Energy Center (CEC), did, in fact, reach the Elizabeth River in violation of the Clean Water Act.

Here’s how Seth Heald, chair of the Sierra Club’s Virginia chapter, framed that finding in a press release:

A federal court has found Dominion responsible for breaking the law and polluting the Elizabeth River. That is important for all Virginians who seek to hold the utility responsible for its mishandling of toxic coal ash. Now we must push Dominion to do the right thing and get this toxic ash out of the groundwater and away from the river, which is highly susceptible to disastrous flooding from sea-level rise and other climate-change effects.

But the judge also found that Dominion had been a “good corporate citizen,” had cooperated with Virginia’s Department of Environmental Quality (DEQ) “every step of the way,” and “should not suffer penalties for doing things that it, and the Commonwealth, thought complied with state and federal law.”

More importantly, Gibney applied what is, in effect, a cost-benefit test to any proposed remedy. While it is true that a tiny volume of leachate reaches the Elizabeth River, arsenic concentrations have been rendered harmless by dilution in the massive volume of river water. No threat to aquatic life and human health has been detectable so far. Unless evidence emerges that arsenic levels are reaching dangerous levels, he saw no justification to spend upwards of $600 million to excavate and remove the coal ash.

Gibney also found Dominion’s remedy of “monitored natural attenuation” — in effect, letting nature run its course — to be inadequate as well. He ordered Dominion to conduct more extensive monitoring of sediment, water and wildlife in and around the Chesapeake cite, and to report the results to the Sierra Club’s counsel and the DEQ. “In the event of a significant change in the amount of arsenic in the water or sediments,” Gibney wrote, “either party may move the Court for further relief.”

But Gibney’s cost-benefit test favors Dominion as the coal-ash controversy unfolds. Riverkeeper groups have opposed Dominion’s requests for solid-waste permits at its Bremo and Possum Point power stations. They argued, as the Sierra Club did in the CEC case, that evidence of contaminated groundwater migrating into nearby water bodies is grounds for removing the coal ash to lined landfills away from the water regardless of expense. But the application of Gibney’s logic to future cases would mean that demonstrating the leakage of small volumes of contamination into surface waters is not sufficient to seek a massively expensive remedy. The leakage must be on a scale to affect aquatic health and human safety.

Over a half century of burning coal at the Chesapeake power plant, Dominion accumulated 3.4 million tons of combustion residue and disposed of it in coal ponds. The ash contained high levels of arsenic — an estimated 150 tons. In 2014, samples of groundwater from ten wells around the ash landfill showed arsenic concentrations higher than 10 micrograms per liter, the groundwater protection standard set by DEQ. At one location, the judge noted, the arsenic concentration reached 1,287 micrograms per liter.

Gibney accepted the Sierra Club’s arguments that groundwater migrates from the coal ash to the surface waters of the Elizabeth River and its tributaries. In so doing, he rejected Dominion’s contentions that the groundwater was unconnected to the surrounding water bodies, and that arsenic traces found in the Elizabeth River originated from other industrial sources. Wrote the judge:

Dominion argues that because sediments move upstream and downstream with the tides, it is impossible to tell where the sediments used for the poor water samples originally came from. Although some tidal action may move sediments around, it defies logic to argue that an enormous amount of arsenic does not contribute to the arsenic in soil and water right next to it, especially given the evidence of groundwater movement from the mound outward.

While the evidence shows that Dominion does discharge some arsenic into nearby surface waters, Gibney reasoned, “it does not show how much.”

The Court cannot determine how much groundwater reaches the surface waters, or how much arsenic goes from the CEC to the surrounding waters. .. What the Court does know, however, is that the discharge poses no threat to health or the environment. All tests of the surface waters surrounding the CEC have been well below the water quality criteria for arsenic….. The CEC is surrounded by an enormous body of water, and even a large arsenic discharge would amount to a drop in the bucket.

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