Wind and solar are wholly inadequate for Virginia’s energy needs.  CFACT makes plain the hard math that explains Virginia’s need to generate abundant, efficient electricity.

To: Virginia State Corporation Commission
Re: PUR-2023-00066
From: Craig Rucker, President
CFACT
1717 Pennsylvania Ave, NW
Suite 1025
Washington, D.C. 20006
202-559-9036
Via SCC comment portal

Comments of CFACT regarding Dominion Energy’s 2023 IRP and their need for additional gas fired generating capacity during the 15 year planning period

Introduction

In their latest IRP, Dominion Energy argues that they will need to add some gas-fired generating capacity during their 15-year planning period. We support this expansion. Several lengthy comments have been filed in opposition to their proposal. We believe they are misguided. In actuality, Dominion must not just add what they propose, but add considerably more gas-fired capacity to their operations. This is because the amount of battery storage the company will need to reliably make their proposed renewable energy expansion possible is far greater than they currently have planned.

The economics are clear. The required storage is prohibitively expensive. Thus, gas-fired backup is a better alternative as it is far less costly. Moreover, given the much higher capacity factor and low cost of gas-fired capacity, it would be more cost effective to use fewer renewables. This is especially true of the offshore wind capacity, which is a serious threat to whales and other marine life. Offshore wind should not be built.

These issues are discussed briefly below. Additional analysis by Dominion is called for to address them properly.

Grossly inadequate storage

Dominion’s preferred option, Option B, calls for 2,370 MW of battery storage in the planning period. MW are the battery discharge rate, not the storage capacity. Assuming these are standard 4-hour batteries, the storage capacity is 9,480 Mwh.

This is an extremely small amount of storage, nowhere near enough to back up the proposed increase in renewables. A simple analysis makes this clear. Figure 1.1.1 projects an increase in DOM Zone summer peak of over 10,000 MW.

Dominion will likely see load increases of 5,000 or more, possibly often. This load is supposed to be met using renewables and batteries. This isn’t likely to happen. Consider the simple case of a 12-hour night with low wind fulfilling that load. The storage requirement is 60,000 MWh, over six times the proposed storage capacity. Even if the batteries had a 10-hour capacity, they would not come close to meeting the need.

Even worse, this simple case is far from worst likely to occur. Multiple cloudy, hot and cold days with low wind are common in Virginia. Detailed historical analysis will be needed to correctly estimate the likely maximum required storage capacity, and it will certainly be in the hundreds of thousands of MWh.

Even assuming huge battery price reductions, this much storage would be prohibitively expensive. Gas-fired backup power is a better option.

Dominion has indicated it plans to meet some of this need with imported energy. But, all the neighboring utilities are pursuing a similar dependence on renewables. The spatial extent of protracted low wind cloudiness with high load is often very large, including all the states near Virginia. Therefore, it is very likely that energy will not be available to import during these episodes. In fact, Dominion made this very point in its 2022 IRP Update. A much better path than relying on out-of-state electricity will be for the company to expand its gas-fired generating capacity.

Low projections of load growth

Dominion says the large projected load growth in the IRP is mostly due to new data centers rather than the electrification of other energy uses. However, the load growth from electrification will also be very large under present policies. A great deal of gas-fired generation will be required to meet this additional load.

The reality is complex, but if we keep it simple enough, one can readily see the stark general picture.

To begin with, consider electrification of gasoline usage, most of which is for cars and light trucks. According to EIA, Virginia’s estimated 2021 gasoline consumption is around 440 trillion Btu. The conversion is 3,412,000 btu = 1 MWh. So that is about 130 million MWh in gasoline energy. Also, in 2021 Virginia’s electric power generation is 93.5 million MWh. Thus, the gasoline energy is 1.4 times the total power generation. If it takes this much energy to power cars and light trucks in the Old Dominion, then it becomes necessary to build a new generation capacity that is almost one and a half times the Commonwealth’s present generation to make the transition. We have seen no plan that even begins to address this issue seriously.

Of course, a real analysis, which Dominion should do, would get very technical. For example, car engines are only around 40% efficient. One might argue that only 40% of that 130 million MWh, or 52 million, is needed to run the electric version. That is still well over half of the present generation. But the electric power and electric car system is also far from 100% efficient. There are line losses, storage losses, motor losses, etc. But the bottom line holds true: if 52 million MWh has to be used, then a lot more has to be generated. And this is just with respect to gasoline. The present policy goal is to electrify as much fossil fuel use as possible. Natural gas use is huge. EIA says Virginia’s 2021 consumption was about 700 trillion Btu or almost twice as much as gasoline, and many gas uses are efficient. Distillate oil, including diesel and heating oil, is roughly another 200 trillion Btu. Even coal is around 70 trillion Btu.

Therefore, widespread electrification could easily double the load increase from that projected for the planning period in the IRP. Many new gas-fired generation will be needed to meet that load. Dominion needs to include this case in its IRP.

Offshore wind is expensive, redundant, and environmentally destructive

Instead of building new gas-fired generating capacity to backup renewables, it will be far more cost-effective to use gas as a primary energy source. Having gas capacity sit idle simply because the wind is blowing or the sun is shining for part of the day is redundant and expensive. Dominion should analyze this issue.

The case of offshore wind is particularly extreme. Dominion projects 3040 MW of new wind in all five options, mostly offshore, on top of the 2,600 or so MW already in process. The total cost is projected to exceed $8 billion per 1,000 MW or over $45 billion. This for a technology that seldom produces full power and sometimes produces none at all, including during periods of peak load.

Moreover, the projected cost of offshore wind projects has increased dramatically in recent months, on the order of 50% at this point. It is likely that the IRP needs to be redone to take such huge increases into account.

In addition to this exorbitant cost, offshore wind has been implicated in numerous whale deaths — including the extremely endangered North Atlantic Right Whale. Strangely, the IRP does not include this issue.

IRP Appendix 5L is a five-page list of the many Environmental Regulations that Dominion is scrutinized under. On page 194, in a section called “Wildlife”, there are just three entries. These entries are all about the endangered Atlantic Sturgeon, threatened by hot water from nuclear power plants. There is no mention of the Marine Mammals Protection Act harassment authorizations, even though the present offshore wind construction and operation is waiting for one. They cannot start the offshore portion of the project without it. Also not mentioned are the crucial Environmental Impact Statement and BOEM approval of the project.

This is preposterous, as the threat to whales is clear. The project creates an intense noise wall that forces the whales to go around, either to the East or the West.

Immediately to the East lies the westernmost lane of the very busy coastal ship traffic. To the West lies the equally busy coastal barge traffic. Both are deadly to the species.

It seems the project was deliberately located where there is the least shipping traffic. This would make sense if it were not for the whales and other marine mammals. As it is the project closes  the low shipping corridor, which the whales undoubtedly use. Being hit by ships is the leading cause of death for whales, and the placement of wind turbines in these waters will facilitate more such collisions.

In summary

CFACT supports Dominion’s construction of new gas-fired power plants. The company will need a great deal of new gas-fired generating capacity to meet its vastly increased base load that is projected over the planning period. Many factors and drivers involved are not included in the present IRP, and Dominion needs to address them properly. In the meantime, however, given all these factors, it would seem building more gas-fired capacity is both a proper and responsible course to set.

AUTHOR

CFACT Ed

CFACT — We’re freedom people.

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