Fate of Dominion Gas Plant Depends On Which Experts, Models the SCC Believes 

The State Corporation Commission’s (SCC) decision on whether Dominion Energy can build a new natural gas-fired power plant will depend on which expert or set of experts it believes, and which of the many computer models that dominate the testimony it judges best predict Virginia’s energy future.

Dominion has filed testimony to the SCC from its outside expert backed by computer modeling that concludes there is a risk to the reliability of our electric grid unless additional “dispatchable” generation resources are built. “Dispatchable” means that they are under operator control, can be turned on or off as needed, and are not dependent on the weather.

The wind, solar and battery resources that are demanded under the Virginia Clean Economy Act are not considered “dispatchable,” at least not as dispatchable as a natural gas plant that starts on ten minutes notice. But opponents of the gas plant application have hired several experts of their own, armed with their own models, who assure the SCC those generation assets coupled with heightened efforts to limit demand will be adequate to keep the lights on in the next decade and beyond.

On behalf of Attorney General Jason Miyares, who participates in utility regulation as the state’s consumer counsel, an expert witness that office often uses endorsed the Dominion application. Scott Norwood did not dive into the reliability debate, however, and noted Dominion only expects the plant to run about 16% of the time. It is designed to be a “peaker” plant, running only at times of constrained electricity supply. 

The first round of expert testimony was filed in late July, with the SCC’s own staff still having to weigh in with its own analysis. Then there will be a round of rebuttal filings, all leading to a public hearing starting on September 23.  Dominion is seeking to have the 944-megawatt Chesterfield County plant, slated to cost about $1.5 billion, in operation by 2029. 

The case file is also filling up with public comments from individuals and organizations, a process still open for a few more weeks and available through a portal on the SCC website.

The Virginia Chamber of Commerce, the Virginia Economic Developers Association  and a few other business organizations have expressed support. So far – and this is different than the past – few elected officials are on the record with a yea or nay statement. There are also several outside comments opposed to the plant, with this one typical.  Both candidates for Governor of Virginia have talked about the gas plant application, but neither has entered the SCC record. 

The issue of future system reliability is key because of the wording of the Virginia Clean Economy Act (VCEA). It prohibits Dominion from adding any generation which would emit carbon dioxide gas into the atmosphere unless “there is a threat to the reliability or security of electric service to the utility’s customers.”   Hence the utility’s choice of name for the project, the Chesterfield Energy Reliability Center (CERC).

The law also requires Dominion to meet several energy conservation goals before such a plant can be approved, goals which it has failed to meet. But the SCC can waive that mandate if the gas plant is judged “more cost-effective than demand-side or energy storage resources.” (Code of Virginia § 56-585.1(A)(5)(c)).  The key question is whether compliance with the VCEA threatens the reliability of the electricity network.

Dominion makes its case, among other ways, with the testimony of Arkash Sheilendranath of the Brattle Group, who models the impact of a future severe cold spell on Dominion and the rest of the PJM regional energy marketplace in 2030, by which time the projected data center industry buildout will greatly increase pressure on PJM, the regional grid operator that serves Virginia.

The opponents challenge that conclusion with their own experts offering different future energy scenarios than the one Dominion envisioned, with more additions of solar, and other non-hydrocarbon energy sources. Sierra Club witness Devi Glick testified he developed two scenarios.

Given the simulated load growth of the…(Dominion) Zone, PJM’s resource adequacy requirements for (load serving entities), and the future resource development that is necessary across PJM for maintaining resource adequacy, the analysis I conducted confirms that such a reliability threat exists, particularly during extreme weather events, if the proposed new dispatchable generation resources, including the (Chesterfield) Project, are not developed within DOM LSE area.

The opponents challenge that conclusion with their own experts offering different future energy scenarios than the one Dominion envisioned, with more additions of solar, and other non-hydrocarbon energy sources. Sierra Club witness Devi Glick testified he developed two scenarios.

The Company did not evaluate an alternative portfolio; instead, it modeled one scenario with CERC and one without CERC. The finding that the system is less reliable when a resource is removed and not replaced with anything is not helpful or meaningful. In my reliability modeling, I tested both of my alternative portfolios. I found that the portfolios without CERC had similar, if not better, reliability performance relative to a system with the CERC project.

Dominion’s testimony, including the Brattle Group report, was filed first, so much of the response is focused on dissecting it. The common complaint is that Dominion started with the assumption that it wanted to build a gas-fired plant and worked to reach that conclusion. It began an approval process to have the plant accepted by PJM back in 2019. 

Other witnesses, including two retained by the Chesapeake Bay Foundation, complain that the plant’s emission of particulate matter and other pollutants pose a major health risk. It is replacing a retired coal-burning facility at the same location, and other, larger natural gas turbines are already operating there, but they argue the incremental emissions amounts are still dangerous. From the testimony of Chris Lim from Arizona:

…the analysis evaluates impacts on 1,290,729 residents within a 100- kilometer modeling domain. The assessment reveals substantial annual health consequences, including 6.71 premature deaths (with estimates ranging from 1.83 to 16.18 depending on the epidemiological study used) and 14,641 cases of illness. These morbidity impacts encompass 14.05 myocardial infarctions, 38.59 new childhood asthma cases, 5.16 new Alzheimer’s disease cases, 3,600 lost workdays, and 10,948 minor restricted activity days.

Some will find the specificity to two decimal points adds credibility and some will not. Nobody introduced any evidence of the health impacts of a winter grid collapse, but 246 people did die in Texas in 2021.

Frankly, supporters or opponents of using natural gas can find whatever they need to make their preferred case from the reams of documents and charts. The educational and work credentials of the various hired witnesses are impressive all around. So probably are their fees.  How will the SCC’s three judges plow through to a conclusion that complies with the VCEA? Good question. 

Steve Haner is a Senior Fellow for Environment and Energy Policy. He can be reached at Steve@thomasjeffersoninst.org.