In a comment letter filed this week, the State Corporation Commission (SCC)* cautioned that EPA’s Clean Power Plan could “substantially increase” consumer electric bills in Virginia. The Richmond-Times Dispatch reports:
Complying with the EPA’s proposed carbon emission rules would likely cost Dominion Virginia Power customers alone an extra $5.5 billion to $6 billion, the State Corporation Commission’s staff said in an unusually bluntly worded statement.
The EPA’s proposed regulations would “increase substantially” the bills that all 3.6 million Virginia electricity customers pay for their power, the commission staff said, and could significantly affect the reliability of electric service.
The SCC staff anticipates electricity bills would go up significantly because the federal rules would require much of today’s electricity production be replaced with costly generation and expensive programs to decrease energy use.
“Those higher costs will be reflected in the electric bills paid by customers,” said the commission’s staff, emphasizing that statement with italic type.
SCC staff also expressed concerns about electric supply reliability. Again, from the Times-Dispatch:
To make the carbon emission reductions called for in the proposed regulation, the EPA’s own model predicts that Virginia utilities will have to shut down fossil-fuel power plants reliably producing 2,851 megawatts of electricity, and replace that generation with just 351 megawatts of unreliable land-based wind power. “This raises alarming regional reliability concerns,” the staff said.
The power plants involved today ensure reliable service to Virginia customers, have years of useful life remaining, and cannot be replaced overnight or without regard for impacts on the electric system, the commission experts said. “It will be a challenge to meet federal reliability requirements during such a transition.”
Even if the operational concerns of replacing dependable fossil-fuel generation with variable, intermittent and “nondispatchable” — unreliable — wind and solar energy could be managed, the staff said, “there is still zero probability that wind and solar resources can be developed in the time and on the scale necessary to accommodate the zero-carbon generation levels needed” to meet the EPA’s mandatory carbon-reduction goal for 2020.
Consistent with analysis posted last week on this blog, SCC staff questioned the Clean Power Plan’s legality:
The prospective EPA rules also raise legal concerns, the staff said. No fossil-fueled power plant in Virginia currently meets the carbon emission rate proposed for the state, the staff said. But the SCC pointed out that the federal proposal imposes substantially more stringent emission requirements for existing power plants in Virginia than for as-yet-unbuilt new units.
Calling that effect of the rules “topsy-turvy,” the staff asked, “Would it be rational to require the current owners of automobiles or lawnmowers throughout Virginia, for example, to meet an emission standard that is 26 percent more stringent than required for the production of new cars or lawnmowers that must use the best available technology?”
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
* Established in 1903, the State Corporation Commission regulates many businesses and economic activities in Virginia, sets rates charged by large investor-owned utilities, and serves as the central filing agency for corporations in the State.