SCC Comments on the Clean Power Plan in Virginia

The Virginia State Corporation Commission (SCC) released their comments on the EPA’s new Clean Power Plan (CPP) this past month, 45 days ahead of the EPA’s comment deadline. The EPA’s Clean Energy Act, proposed in June of 2014, calls for cutting carbon emissions from existing power plants 30% below 2005 levels by 2030, in “an effort to fight climate change, improve public health, and provide affordable energy,” according to Daily Press writer, Travis Fain. The SCC bluntly opposes the CPP due to supposed economic and financial hardships that would be caused by the passage of this plan. Environmental organizations, such as the Sierra Club, believe the SCC misread the CPP, as the cuts to dangerous carbon emissions are very attainable by 2030, without economic or financial burden. Virginia can achieve the goals of the CPP at a low cost, while lowering Virginians’ energy bills. The staff of the Virginia State Corporation Commission should have spent their extra 45 days to understand the rule and get their analysis right, instead of rushing to turn in their ill-informed comments to the EPA.

The SCC claims that the CPP will cost Dominion customers an extra 5.5 to 6 billion dollars in order to comply with the plan. “Contrary to [the EPA’s] claim that ‘rates will go up, but bills will go down,’ experience and costs in Virginia make it extremely unlikely that either electric rates or bills in Virginia will go down,” staff said. However, an independent analysis of the actual Clean Power Plan itself shows that Virginia can achieve its goals at a fraction of the cost while lowering Virginians’ bills by 8%. In addition, the Virginia Energy Plan and Virginia’s existing energy efficiency and renewable energy goals set the stage for Virginia to become a leader in clean energy jobs. Many environmentalists and the majority of small business owners agree that Virginia needs to develop clean energy if it wants to remain competitive in the modern business environment.

The SCC claims that even if Virginia swapped all coal for gas, Virginia still couldn’t comply based on CPP targets (Virginia would be required to reduce its generating plants’ emissions to 884 lbs./MWh by 2020 and to 810 lbs./MWh by 2030), which would raise concerns over the reliability and cost. While this general statement is flat out inaccurate and misleading, proper compliance will  supplement some fuel switching with investments in renewables and efficiency. The SCC says that even with proper supplementation of renewables, there is no guarantee that enough renewable power can be generated in time to meet the interim goal in 2020. Therefore, the SCC claims the only way to solve this problem is to build North Anna 3 (NA3), a new nuclear unit, which can not be built in time to meet the emission target. “SCC staff seems to suggest that in order to comply with the Clean Power Plan, Virginia needs to invest in a third nuclear reactor at North Anna, and that simply isn’t the case,” Dawone Robinson, the Chesapeake Climate Action Network’s Virginia policy director said. “Additionally, many of the coal plant retirements and natural gas conversions that the SCC staff suggests will hamper the state … were proposed by the utility before the Clean Power Plan was even released.” In addition, the CPP target goal assumes an unrealistic level of renewables, according to the SCC. The staff says the CPP assumes Virignia will have a mandatory Renewable Portfolio Standard (RPS) and Energy Efficiency (EE) standard, neither of which we currently have. SCC analysts say the agency’s plan calls for “unsupported expectations of levels of renewable generation and energy efficiency that, when applied to Virginia, are extremely ambitious, almost certainly unachievable and uneconomic under traditional standards.” The SCC is very against these mandatory targets, which are thought to be ignorant of the realities of Virginia as an independent state, not in comparison to other states.

The Staff of the Virginia State Corporation Commission (SCC) has broken with its practice by issuing deeply flawed and factually-incorrect comments to the Environmental Protection Agency on the possible impact of limiting carbon pollution in Virginia, according to the Southern Environmental Law Center (SELC) and NextGen Climate America. “SCC staffers rushed to get these ill-informed comments out 45 days ahead of EPA’s comment deadline.  Instead, they should have taken the time to understand the rule and get the analysis right. Virginia is 80% of the way toward achieving its carbon reduction target under the Clean Power Plan, and low-cost, job-creating technologies in efficiency, solar, and wind stand ready to not only meet the rest of target, but will position Virginia to become a leader in creating clean energy jobs” said David Weiskopf, with NextGen Climate America. The SCC claims that emission targets should be reduced

The comments released by the State Corporation Commission are 49 pages in length, but do not have one positive thing to say about the proposed Clean Power Plan. “The SCC staff analysis is just plain wrong,” said Glen Besa, director of the Sierra Club’s Virginia Chapter. “They’re playing politics with climate change science and they have no business doing that, and they’re bringing discredit on the commission.” The comments are 100% anti-CPP, and use very strong, snarky, and disparaging language. The EPA, which will be accepting comments on the proposed rule through Dec. 1, will issue the final rule in June 2015.

image by commdiginews

Interested in direct action on this subject? Join the Sierra Club and other environmental groups as we pack the room of the Virginia General Assembly Joint Legislative Hearing on the Environmental Protection Agency’s Clean Power Plan next Wednesday, November 14! Afterwards, we will rally for clean power. Be there to show the strength of the people to our state legislators and let them know that, from the Appalachians to NOVA to the Tidewater, Virginians support the Environmental Protection Agency! For more information, see the Facebook event (!


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