Get ready for last-minute filings on EPA Clean Power Plan

dominion ELP

Dominion (NYSE:D) has become the latest company to weigh in on the Environmental Protection Agency (EPA) Clean Power Plan.

Groups like the Electric Reliability Council of Texas (ERCOT), the North American Electric Reliability Corp. (NERC), the Regional Greenhouse Gas Initiative (RGGI) and Midcontinent ISO (MISO) have already filed either comments or public assessments on the EPA policy to have states cut carbon dioxide (CO2) emissions from the power sector 30% by 2030.

The head of the National Mining Association on Nov. 26 called for EPA to withdraw the proposed rule.

Some groups including the American Public Power Association (APPA), Nuclear Energy Institute (NEI) and Natural Resources Defense Council (NRDC) are expected to announce the filing of their comments on Monday, Dec. 1.

Dominion said Nov. 26 that some states, such as Virginia and North Carolina, are treated unfairly in the proposal because of the "greater and unreasonable" reductions required in emission rates relative to other nearby states. The proposed regulations could penalize states that already have reduced their carbon intensity, the company said.

"We are supportive of policies and programs that will achieve meaningful emission reductions and environmental benefits while maintaining electricity reliability, minimizing effects on customer rates, and recognizing and appropriately accounting for measures states and affected entities have already undertaken to reduce carbon emissions," the company wrote in comments signed by Pamela F. Faggert, Dominion vice president and Chief Environmental Officer. "However, we are concerned the (Clean Power Plan) proposal falls short of these principles in many respects."

Dominion said it has reduced its average carbon dioxide emissions rate - or carbon intensity - for all the company's owned generation by about 39% from 2000 to 2013. The carbon intensity for the power stations serving affiliates Dominion Virginia Power and Dominion North Carolina Power fell by about 19% during the same period.

While EPA's efforts to avoid a "one-size-fits-all" approach are laudable, the Clean Power Plan must do better to provide consistency, reasonableness and equity among the states. For example, Virginia already is a low-carbon state, but would have to reduce its emissions intensity by 38%, yielding a state goal for Virginia that is significantly stricter than all of its neighboring states and at least twice as strict as two of its neighboring states. "This dichotomy creates an economic and competitive advantage to those states that have done the least and a disadvantage to those who have done the most," Dominion said.

Robert M. Blue, president of Dominion Virginia Power, testified earlier this month before a joint meeting of the Virginia House and Senate Commerce and Labor committees that customers would see a significant increase in their electricity rates and in their bills by 2025 under the EPA proposal. Blue also said that despite the company's concerns, it must begin preparing immediately for the new targets because of the short lead time for compliance, which begins in 2020 under the draft rule.

Dominion spells out a number of potential changes

Some of the arguments raised by Dominion had also been mentioned earlier in the process by staff of the Virginia State Corporation Commission (SCC).

Dominion made the follow recommendations:

  • Consider a more-representative baseline for states by using an average of multiple years and allow compliance through multi-year averaging.
  • Adjust state goals to recognize emissions improvements, efficiencies and uprates accomplished in recent years. Also adjust state goals to reflect state-specific renewable potential and state-specific energy efficiency potential.
  • Recognize the value of all existing nuclear generation, including Dominion's four nuclear units located in Virginia. Last year, Dominion's carbon-free nuclear units generated 41% of its power to service its customers in Virginia and North Carolina.
  • Nuclear plants whose licenses are extended beyond 60 years should be counted as new sources of carbon-free generation.
  • Do not count emissions from natural gas combined cycle generating facilities now under construction in the state reduction targets. Dominion has two large, modern natural gas power stations under construction in Warren and Brunswick counties in Virginia. These clean, modern units should count for compliance, not to make compliance more difficult.
  • Eliminate the interim reduction target and allow states more flexibility in reaching the ultimate reduction goal. This includes the addition of a compliance mechanism that accommodates longer installation times for low- and non-emitting generation.
  • Clarify rules regarding waste wood products as a carbon-neutral generation and for supply-side efficiency programs. Dominion is the nation's leading utility operator of renewable biomass, having converted three coal plants to biomass and designed the Virginia City Hybrid Energy Center to co-fire with up to 20% biomass.
  • Allow states to seek adjustments in their targets based on changing circumstances and include a safety valve, or "off ramp," to address both unexpected scenarios and to address situations where implementation of the rule threatens service reliability or leads to rate shocks for customers.

The 68 pages of EPA comments were filed by Dominion on Docket ID No.EPA-HQ-OAR-2013-0602.

This article was republished with permission from





2014 Articles

Harvard Law School professor pays Clean Power Plan is unconstitutional


Laurence H. Tribe, professor of constitutional law at Harvard University and former mentor to Barack Obama, said in an article last week that the EPA’s Clean Power Plan is unconstitutional.

3 SKorea workers die at nuke plant construction site


SEOUL, South Korea (AP) — Three South Korean workers died Friday after apparently inhaling toxic gas at a construction site for a nuclear plant being built by South Korea's monopoly nuclear power company, which has come un...

UMaine in business of certifying turbine blades


ORONO, Maine (AP) — The University of Maine has tested its largest wind turbine blade to date. UMaine's Advanced Structures and Composites Center completed static strength testing this month of a 184-foot-long wind turbine...

Mergers, EPA carbon plan generated much attention during 2014


Mergers, the Environmental Protection Agency (EPA) Clean Power Plan, cheap natural gas and the polar vortex were among the most noteworthy generation stories of 2014.

Developer opens Ohio review for 800-MW, gas-fired project


Clean Energy Future-Lordstown LLC plans an 800-MW, gas-fired power project, and on Dec. 24 applied with the Ohio Power Siting Board for certain routine waivers it needs before filing a full siting application for this proj...

New England utility exec named to Vermont PSB


A woman who worked for Vermont's Department of Public Service for 17 years is going to become the next member of the utility-regulating Public Service Board. The appointment of Sarah Hofmann was announced Monday by Gov. Pe...

Brown picks aide to lead troubled California utility board


Gov. Jerry Brown named a former adviser on Tuesday to be the next head of California's troubled utilities commission, replacing a regulatory chief accused of back-channel dealings with utilities. Michael Picker, a former a...

Washington state carbon emissions dropped in 2011


Greenhouse gas emissions in Washington state dropped by about 4.6 percent between 2010 and 2011, led by reductions in emissions from the electricity sector, according to the latest figures released by the state. The latest...

Group wants state regulators recused from PNM case


State regulators in less than two weeks are to begin deliberating a proposal that calls for shutting down part of an aging coal-fired power plant in northwestern New Mexico that serves more than 2 million customers in the ...

Vermont Yankee plant prepares to shut down


The Vermont Yankee nuclear plant is getting ready to shut down. Its owner, Entergy Corp., says it is closing the plant for economic reasons. The plant in Vernon is expected to disconnect from the regional power grid Monday.

PSEG Solar to acquire Maryland solar project from juwi


PSEG Solar Source will acquire a 12.9-MW solar energy facility near Waldorf, Maryland from juwi solar (JSI). The PSEG Waldorf Solar Energy Center will increase the capacity of PSEG Solar Source's portfolio to 123-MW.

PG&E discloses more emails with state regulators


California's largest power utility released a dozen more emails Monday that it said showed improper back-channel discussions between the utility and top state regulators.

Indianapolis airport solar farm expansion completed


Contractors have finished bringing online dozens of acres of solar panels at Indianapolis International Airport, solidifying its status as the home of the nation's largest airport-based solar farm.

French power company to pay $772M in bribery case


A French power and transportation company has agreed to pay $772 million to resolve allegations that it bribed high-ranking foreign government officials for lucrative projects, the Justice Department said Monday.

Nebraska nuclear plant back online after short outage


The Fort Calhoun nuclear power plant is back online less than a week after its main generator unexpectedly shut down as a precaution.

Ameren Missouri plans $135M in energy efficiency


Missouri's largest electric company said Monday that it plans to invest $135 million in energy efficiency programs for customers over a three-year period.

TEPCO completes nuclear fuel assemblies removal from Fukushima 4


Tokyo Electric Power Co. (TEPCO) said it has safely removed the fuel assemblies from the most damaged nuclear reactor at the Fukushima Daiichi nuclear power plant.

B&W Vølund to build waste-to-energy power plant in Scotland


In a consortium with Interserve, Babcock & Wilcox Co.’s (B&W, NYSE:BWC) subsidiary, Babcock & Wilcox Vølund A/S (B&W Vølund), will engineer, procure and construct (EPC) a waste-to-energy (WTE) power plant f...

SKorea holds N-plant drills against cyber threats


South Korea's monopoly nuclear power company said it began drills Monday against possible cyberattacks after online threats of attack against its plants.

PSC approves solar power project


The Public Service Commission has approved solar power project planned by Kentucky Utilities and Louisville Gas and Electric in Mercer County.

Did You Like this Article? Get All the Energy Industry News Delivered to Your Inbox

Subscribe to an email newsletter today at no cost and receive the latest news and information.

 Subscribe Now


Logistics Risk Management in the Transformer Industry

Transformers often are shipped thousands of miles, involving multiple handoffs,and more than a do...

Secrets of Barco UniSee Mount Revealed

Last year Barco introduced UniSee, a revolutionary large-scale visualization platform designed to...

The Time is Right for Optimum Reliability: Capital-Intensive Industries and Asset Performance Management

Imagine a plant that is no longer at risk of a random shutdown. Imagine not worrying about losing...

Going Digital: The New Normal in Oil & Gas

In this whitepaper you will learn how Keystone Engineering, ONGC, and Saipem are using software t...