When Dominion shuts down the Yorktown Power Station, Virginia’s Peninsula will need another source of electric power. Dominion says a 500 kV transmission line over the historic James River is the best option. Conservationists disagree.by James A. Bacon
Communities in the historic Virginia Peninsula face a devil’s alternative: Immediately accept a high-voltage transmission line that foes say could mar views of a historic stretch of the James River or face the prospect of rolling blackouts that Dominion Virginia Power says could disrupt the economy for 500,000 people.
The State Corporation Commission (SCC) and the PJM Interconnection regional transmission organization have given the go-ahead to build the 500 kV Surry-Skiffes Creek transmission line to balance electricity lost when Dominion Virginia Power shuts down two antiquated coal-fired units at the Yorktown Power Station. But many residents in and around the history-rich region are up in arms, and Dominion cannot begin construction on the line until it obtains necessary switching-station zoning approval from James City County and a nod from the U.S. Army Corps of Engineers.
If a decision isn’t made immediately, contends Dominion, the power company will be unable to complete construction of the transmission line before it shuts down the Yorktown power plants in April 2017 at the latest.
At that point, reliance upon four existing 230 kV transmission lines will put the electric grid only one or two “contingencies” — unplanned transmission-line outages — away from a meltdown that could send uncontrolled blackouts cascading to the Richmond region and beyond. Rather than risk such a catastrophe, federal regulations would require Dominion to take customers offline on a rotating basis. Depending upon weather conditions and other events, the Virginia Peninsula will be at risk of rolling blackouts 50 to 80 times a year.
“If there’s a one in million chance of a breakdown, PJM tells us to shed load,” says Kevin Curtis, Dominion’s director of transmission planning, referring to the regional transmission organization that would issue the command to pull the trigger. If Dominion failed to follow through, it could face fines of $1 million per day for violating North American Electric Reliability Corporation standards.
But foes of the transmission line are still fighting back. In early August, the James City County Planning Commission recommended denial of a rezoning request that would allow Dominion to construct a sub-station critical to the project. Meanwhile, the USACE says, “Due to the many variables yet to be addressed, we are unable to provide a discrete timeline” for when it might decide whether or not the project requires a full-fledged Environmental Impact Statement, which could delay it yet another year.
Margaret Nelson Fowler, founding member of the Save the James Alliance, isn’t buying Dominion’s warning of rolling blackouts. Dominion is making a business decision to shut down the Yorktown power plant, she says. Dominion can continue operating the coal-fired units in a non-compliant status. It will have to pay fines, but fines are Dominion’s problem, not the community’s, she says. “We’ve been told by people who know that blackouts would never be permitted. … This is all scare tactics.”
Surry-Skiffes Creek is perhaps the most controversial of some three dozen transmission line projects that Virginia’s major power companies are planning or implementing as they undertake a sweeping re-engineering of Virginia’s electric grid. Under heavy regulatory pressure, power companies are shifting from coal-fired generating plants to gas, wind and solar energy sources; transmission lines must be built or upgraded to accommodate the re-routed flow of electricity. Dominion lists 27 Virginia projects at some stage of approval or construction; Appalachian Power lists seven approved and pending projects.
The problem is that no one likes looking at power lines, and proposals often encounter local resistance. The Surry-Skiffes Creek proposal arises from a set of circumstances that is particularly complex and intractable. The engineering logic that dictates building a 500 kV Economic transmission line across the James River is persuasive. But so are objections by conservationists and property owners, who say Dominion’s cost-benefit analysis fails to take important non-monetary values into account. The result is institutional gridlock as the proposal works its way through federal, state and local oversight. In this case, the economic consequences of a failure to reach a timely resolution could be highly debilitating to the Peninsula economy.
Decommissioning the Yorktown Power Station.
The Yorktown Power Station is one of the oldest plants in the Dominion system. Two coal-fired units and one oil-fired unit generate as much as 1,141 megawatts of electricity, or about 6% of Dominion’s total energy. Because the coal-fired units were aging, Dominion was planning to phase them out by 2019. Then came the new EPA mercury and air-toxic standards, which, according to Dominion, gave it little choice but to accelerate the planned shutdown to December 2014. Unable to obtain the required authorizations to get the transmission line built, Dominion has continued to operate the plant based on one-year extensions lasting into 2016. The company plans to apply for another extension to April 2017 but maintains operating the plant past that date would be illegal.
Knowing that Dominion had to shut down the two coal-fired units (retaining an oil-fired unit as a rarely used back-up power source), the company, the SCC and independent consultants reviewed multiple options to keep units 1 and 2 open, says Daisy Pridgen, a Dominion spokesperson. “The evaluation concluded that the costs required to extend the life of these facilities (vintage 1950s) was not appropriate to include in customer rates. Costs were over $650 million to achieve EPA compliance, which far exceeded other … options.”
It was impossible to convert the facilities to gas-fired boilers because the natural gas pipeline system on the Peninsula does not have enough capacity to supply a large gas-fired facility. There are no practical locations for wind power nearby, nor are there any parcels of vacant land suitable for solar — at six acres of solar panels per megawatt, 3,600 acres would be needed, says Curtis, the transmission planning director. Moreover, wind and solar are inherently variable, which means the company would need a backup energy source in case they weren’t generating power, which poses the question of where that electricity would come from.
Transmission line foes have suggested investing in energy efficiency and demand-response programs, but history has shown it takes years to change people’s behavior enough to shave 8% to 10% from demand, says Curtis. The Peninsula would need to slash more like 30% to 50% to avoid building the transmission line. “I’m not aware of anyone doing that anywhere in the United States.”
Another transmission line. Dominion concluded that the most economical option was to bring in electricity from outside the Peninsula, and that meant building another transmission line. Currently, the region is served by four 230 kV transmission lines, two crossing the James River from the south and two from the northwest. Under ideal circumstances, those four lines by themselves could accommodate the region’s electricity demand. But in hot days when demand is highest, the lines would lack the capacity to meet power demand and handle multiple contingencies.
It is electric utility dogma, now enshrined in North American Reliability Council regulations, to maintain enough redundancy in the electric grid to be able to survive two simultaneous adverse events. Some events are caused by nature, such as tornadoes, high winds and ice storms. Others involve all-too-human screw-ups, such as a tree-cutter knocking a tree onto a power line or a ditch digger ripping up an underground line. Yet others are flukes, such as a barge damaging a river transmission-line tower or a large bird knocking out a substation. On any given day, the chances of any one of these events occurring is remote. But events of one kind or another occur with some frequency. Any section of the transmission grid must be able to survive not just one incident but two simultaneously.
The consequences of overload could be catastrophic: transmission lines could melt down, causing electricity to reroute through other lines, knocking them out in turn, and setting off a chain of dominoes that could spread like the infamous 2003 blackout that cut power to 50 million people in Canada and the United States.
Dominion is part of PJM Interconnection, an organization that, among other things, safeguards the reliability of the regional electric grid. The company continually monitors Dominion’s transmission lines, as it does for all of its other members, and is empowered to order Dominion to cut power sufficient to drive demand below the two-adverse-event standard. If PJM says to shed load, says Curtis, Dominion complies. “Nobody’s going to fine us for shedding load. We’ll get fined for not shedding load.”
Controlled, rolling blackouts through the Peninsula would be less disruptive economically than an uncontrolled chain reaction that knocked out power for millions of people. Still, the blackouts would be a significant burden to the region’s economy. Curtis says there would be 50 to 80 “high risk” days of blackouts in a typical year, although the randomness of weather makes it impossible to predict the number with any certainty.
Dominion’s engineers determined that the Peninsula needed a 500 kV line, for which it explored two broad alternatives and innumerable variations of those alternatives: (1) extending from the Chickahominy substation (midway between Williamsburg and Richmond) along an overland route into the Peninsula and (2) running the line from a substation tied to the Surry Power Station across the river. Dominion focused on the Chickahominy and Surry substations because both are served by 500 kV lines that draw from multiple power sources.
The problem with the Chickahominy route, says Curtis, is that the high-voltage line would cross a river, the Chickahominy, that is far more pristine environmentally than the James, and would run through Chickahominy Indian tribal lands and other culturally sensitive sites. Early public hearings generated a buzz saw of resistance. Indeed, that route is so unacceptable that Fowler with the Save the James Alliance argues that Dominion floated it to make the Surry alternative look good by comparison.
The Surry route would start at the Surry substation, run 1.5 miles on Dominion land, stretch four miles across the James, and then another 2.3 miles in James City County to a switching station at Skiffes Creek. There the voltage would be stepped down from 500 kV to 230 kV in a line that would be extended to the Whealton sub-station. The river crossing would require 17 towers, which would rise to a height of 275 to 295 feet on each side of two active shipping channels. The average height of the other towers would be 160 feet.
Dominion characterizes the affected stretch of the James as a working river, with numerous commercial vessels, a waste-water treatment plant, the Surry nuclear power station, residential development, the former BASF manufacturing plant, the Fort Eustis Army Base and the so-called “ghost fleet” of mothballed military vessels. Moreover, the transmission line would be far in the distance and barely visible on the horizon. That stretch of the James may be historical, says David Botkins, director of media relations for Dominion, but “it’s not pristine.”
Resistance builds. Resistance quickly surfaced in opposition to the Surry-Skiffes Creek route. The Peninsula is home to the so-called Historic Triangle of Colonial Williamsburg, Jamestown Island and the Yorktown battlefield. History buffs represent a large and vocal constituency in the region. The power lines, foes say, will be intrusively visible from the east side of Jamestown Island (the archaeological digs are on the west side), from the Colonial Parkway, from Kings Mills Resort, from Carter’s Grove plantation and by boaters on the river.
The towers will destroy the vista of “America’s founding river,” a designation granted by a resolution of the U.S. House of Representatives, says Fowler. “We’re not arguing that the river is as pristine as when John Smith was here. We’ve never said that.” But this stretch of river is relatively undeveloped and worth preserving from further degradation, she says. Adding to the intrusion of 295-foot towers, the power lines will be studded with metal balls to make them visible to airplanes, and the towers will flash strobe lights at night.
The Colonial Williamsburg Foundation has opposed the project since 2012, says Joe Straw, manager-public relations, citing “the project’s potential negative impact on the region’s tourism economy, which is based on authentic, inspiring experiences.” Other prominent groups to register their disapproval include Preservation Virginia, the Chesapeake Conservancy and the National Park Service, among others.
Tourism is an economic pillar of the Historic Triangle. The Colonial National Historic Park attracted 3.3 million visitors in 2014. National Park Service economists estimated these guests spent $187 million that year, supporting more than 3,100 jobs in communities surrounding the parks.
But the significance of the area transcends jobs and dollar signs. As Stephanie S. Toothman, keeper of the National Register of Historic Places, wrote in a recent letter to the U.S. Army Corps of Engineers:
The English colonization of North America was an extraordinary undertaking which had a profound impact on the Old World and the New and much of what was to come had its origins here along the James River: the establishment and growth of the first permanent English settlement in the New World; some of the earliest and most sustained interactions (both cooperative and antagonistic) between the original inhabitants of the area — the American Indians — and the Europeans; the initial European voyages of discovery which took them throughout the Chesapeake Bay and into the interiors following the numerous rivers and led to expanding contact with the American Indians and the spread of English settlement; the foundation and development of the tobacco economy which would dominate the Chesapeake Bay world; the introduction and firm establishment of chattel slavery; the architectural evolution of buildings in the James River area from the first crude huts built by the English to the flowering of the dominant Georgian architectural style; and the growth of the unique political and social institutions which would lead to the development of representative democracy and the growing impulse of the colonists to gain independence and self-rule.
Focusing more specifically on the James River itself, Toothman noted that the Captain John Smith Chesapeake National Historic Trail, which encompasses the area to be traversed by the power line, is associated with important historical events. Along this trail, Smith surveyed the Bay, explored for gold and made contact with Indian tribes. “This segment of the [trail],’ she wrote, “is among the most historically significant portions of the overall National Historic Trail’s 3,000 plus miles of waterways. Jamestown was the starting and ending point for all of Smith’s voyages and was Smith’s base of operations.”
Says Fowler: “If this place isn’t sacred to you as a historical treasure, then tell me which place in America would be.”
Regulatory quicksand. Dominion has painted itself into a corner, says Fowler. The company bungled the job of getting the Surry-Skiffes Creek project approved by starting the regulatory process too late — a project this complex takes years to review — and then it has refused to agree to let the Army Corps of Engineers conduct a full-fledged Environmental Impact Statement (EIS) instead of a much more preliminary finding of an Environmental Assessment. As a result, the Army Corps is conducting the Environmental Assessment and may well conclude that a more thorough EIS is needed as well, adding another year to the timeline. “Dominion was very late in applying for a permit,” says Fowler, “and now it’s an emergency. They have no one to blame but themselves.”
The approval process has been complex, involving the State Corporation Commission, PJM Interconnection, a legal appeal to the Virginia Supreme Court and James City County in addition to the Army Corps of Engineers. Dominion executives contend that the company initiated regulatory reviews with reasonable advance notice. They find it ironic that foes delayed the project with every means at their disposal and then turned around and accused Dominion of not giving the regulatory process enough time.
According to a timeline that Dominion prepared for Bacon’s Rebellion:
September 2011: Dominion first publicly identified the problem when it filed an Integrated Resource plan with the SCC, announcing the planned retirement of Yorktown Power Station Unit 1 and the need for a new 500 kV line.
January 2012: Dominion officials met with the Corps for preliminary discussions. At this time the company was leaning toward the Chickahominy route.
March 2012: Retreating from the Chickahominy route, Dominion officially filed with the Corps for a permit for the Surry-Skiffes Creek transmission line.
September 2012: Dominion filed with the SCC for approval of the complete project, including not only the Surry-Skiffes Creek 500 kV line but a switching station at Skiffes Creek and a 230kv extension from Skiffes Creek to the Whealton substation.
August 2013: Dominion modified its application to the Corps to include the Skiffes Creek-Whealton extension, completing the package of proposals for which it was seeking approval. The Corps initiated a review process that included extensive public notices, multiple public comment periods and meetings of consulting parties.
November 2013: The SCC issued a final order approving the Surry-Skiffes Creek 500 kV line, the Skiffes switching station and the Skiffes-Whealton 230 kV line.
February 2014: Routing complications of the 500 kV line led to a reexamination of the case. The SCC issued another order authorizing Dominion’s preferred route.
April 2015: The Virginia Supreme Court unanimously upheld the SCC order approving construction of the transmission line, but also ruled that only James City County had the right to grant zoning for the switching station. On June 4, the Supreme Court remanded the case back to the SCC.
June 2015. Stating that the need for the transmission line is “severe and fast approaching, and the reliability risks are far reaching,” the SCC ordered Dominion to file regular updates on the project, including the status of the Army Corps permit, county approval of the switching station, and Dominion’s proactive reliability efforts.
August 2015: Although James City County Planning Department staff recommended approval of the Surry-Skiffes Creek switching station, the appointed Planning Commission denied a recommendation to approve the project. The Board of Supervisors is expected to make a final decision later this fall.
Addressing the charge that Dominion did not file with the Army Corps of Engineers in a timely manner, Media and Community Relations Manager Bonita Billingsley Harris says the company held preliminary discussions with Corps officials in January 2012, submitted its application for the Chickahominy-Skiffes route in September 2012, and then when it switched to the Surry-Skiffes route, filed revised plans for that route in August 2013. “The bottom line,” says Harris, “is that Dominion began discussions with Corps officials more than three years ago in January 2012, submitting additions and revisions as soon as possible every step of the way.”
It has been two years since the final update was filed, Harris says. If an Environmental Impact Statement is commonly said to take a year to complete, she asks, how long should it take to finish a less exhaustive Environmental Assessment?
A hard deadline? This fall Dominion plans to ask the EPA to give another one-year extension to operate the Yorktown Power Station until April 2017. After that, the company says, it will have no choice but to shut down. Harris says the company is not engaged in scare-mongering.
There are no legal provisions in the [Mercury and Air Toxics Standard] rule for extensions beyond April 16, 2017 – that’s if we get a one year extension from the EPA, which we sincerely hope is approved. Under the Clean Air Act, the EPA can bring civil judicial enforcement actions against sources that violate Clean Air Act requirements. This includes seeking injunctive relief and civil penalties up to $37,500 per day for each violation. In addition, any person who knowingly violates a requirement of the Clean Air Act may be subject to criminal enforcement. Dominion will not break the law — and we don’t know of any other uncontrolled power companies deliberately operating out of compliance. Both coal units will retire no later than April 0f 2017 — for legal and environmental reasons.
Fowler disputes Dominion’s understanding of the Clean Air Act, stating that other power companies have operated power plants when out of compliance and out of extensions, although they paid fines when they did so. Dominion’s decision to shut down Yorktown units One and Two instead of operating it out of compliance and paying fines until a better remedy can be found, she says, is a business decision. That business decision may be cheaper for rate payers, at least in the short run, but will create an aesthetic monstrosity that will diminish property values and create incalculable harm to a historic treasure.
Bacon’s Rebellion contacted the EPA for a definitive explanation of what would be the consequences should Dominion continue operating the Yorktown units out of compliance. The written answer was non-responsive, essentially stating that Dominion could seek up to two one-year extensions, one from the state regulator and then one from EPA.
Bacon’s Rebellion also asked what would happen if Dominion fell out of compliance. EPA’s response: “We cannot comment on whether companies are out of compliance.”
Dominion considers itself to be up against a hard deadline for building the transmission line. Even if the company gains zoning approvals for James City County and regulatory approval from the Army Corps, it will take at least 18 months to build the transmission line, which would take completion well past April 2017 when its hoped-for extension would expire.
“It takes a good year-and-a-half to build the line, with no room for contingencies,” says Curtis, the transmission planning director. “There’s stuff you run into — weather issues, equipment issues, barge problems. We’ve used up all the slack. It’s critical path all the way.”
The economic consequences could be highly disruptive until construction was complete, especially during hot summer months. Manufacturing operations are particularly distressed by the prospect of rolling blackouts. Newport News Shipbuilding, the region’s largest private employer, sent the Army Corps a letter in support of the Skiffes Creek project. Spokesperson Christie Miller cited the fact that “the shipyard depends on reliable electrical power to support employment and build warships for the U.S. Navy.”
A “wicked” problem. Fowler concedes that from an engineering perspective the Surry-Skiffes Creek route might be the least expensive solution for rate payers, but says that calculation doesn’t factor in the impact of the despoiled viewshed in a prime historical location to property owners or the tourism industry. “Surry-Skiffes Creek may be cheapest and fastest, but that’s not our interest,” she says. “We seek to find a workable criteria where the river expanse is saved, at a reasonable cost in a reasonable time frame. It’s called compromise, a word DVP doesn’t understand.”
There is an approach vetted by PJM, Fowler says, that would cost more than the Surry-Skiffes Creek proposal but would preserve the scenic vistas of the James: Continue running the Yorktown 2 coal-fired plant and run a submerged 230 kV line, not a buried 500 kV line, from the Surry substation across the river to the Peninsula. “We’re suggesting this would give [Dominion] time to find replacement generation for the Peninsula.”
Fowler acknowledges that the solution would cost more than Dominion’s proposal, but it would minimize disruption to James River vistas. At least her solution does not sacrifice a “400-year-old national treasure,” she says.
Dominion maintains that it investigated five generation alternatives and 10 transmission alternatives. The SCC approved the Surry-Skiffes Creek option in a ruling that was affirmed by the Virginia Supreme Court. Fowler’s compromise approach was discussed but only in the context of retrofitting Yorktown with gas, which proved not to be viable.
Dominion also looked at the scenario of burying the 500 kV line and rejected it as expensive and vulnerable. A 500 kV line must be buried under the riverbed, which would create an environmental problem of moving 36,000 cubic yards of kepone-laced dredge spoil, and splicing 18 cables at four different points. If something went wrong with any of the splices, it could take literally months to repair, says Curtis. No project with such a high voltage and capacity running such a long distance underwater has ever been attempted before. Is the marginal harm created by viewing a transmission line four or five miles away really worth spending hundreds of millions of dollars to prevent?
Rob Marmet, a senior policy analyst for the Piedmont Environmental Council who filed SCC testimony in support of the conservationists, concedes that the situation may have reached the point now where there is no practical choice but yield to Dominion or suffer major disruption to the Peninsula economy. “We could have avoided the situation,” he says. “Now that we have the situation, we have to mitigate it.”
That doesn’t change the fact that Dominion is socializing much of the cost, Marmet says. The project will make the power cheaper than it would be otherwise, but it imposes a cost on the tourist sector, which will suffer a diminution of the visitor experience, and cost individual property owners who paid for river views that will be taken from them.
The question now is how to avoid these brutal tradeoffs in the future, Marmet says. “How can we plan our system so these things can be avoided?” For instance, could Virginia put into place a more aggressive demand-response program that would shed electric load under extreme conditions in a way that is less disruptive than a rolling blackout? Surely it would be possible, he says, to take water heaters offline when the system is overloaded, or to cut off air conditioners in a controlled and reasonable way.
“This was a tough issue,” Marmet says. “I wish that there had been planning many years in advance. I’m certain given all the smart people at Dominion, the environmental community and the commonwealth that you could have had a situation that made fewer people unhappy.”
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