The Virginia State Corporation Commission found deficiencies in the breadth of some of Virginia Electric and Power Co.‘s modeling used for its 2011 integrated resource plan (IRP), but generally in an Oct. 5 approval order found that the plan met statutory requirements.
Virginia Electric, a unit of Dominion Resources (NYSE: D), does business as Dominion Virginia Power. The 2011 IRP had been filed with the commission in September of last year and was argued out since then by various intervening parties.
As an example of the modeling shortfalls, the models forced the addition of the planned North Anna Unit 3 nuclear facility into each plan scenario, the commission noted. Dominion suggested, in part, that this restriction was designed to address fuel diversity.
“Dominion is not precluded from submitting its preferred models in the IRP, and the Commission is aware of arguments regarding diversity of fuel mix,” the Oct. 5 order added. “Such considerations, however, do not warrant limiting the IRP as presented by Dominion. Thus, Dominion’s future IRP filings also shall include models where North Anna 3 (if included in subsequent IRPs) competes against other resource options.”
Notable is that Dominion recently filed with the Virginia commission its 2012 IRP and that plan also features North Anna Unit 3 as a preferred option for the future.
Dominion in its 2011 plan also excluded new coal-based alternatives due to uncertainties surrounding future CO2 legislation. As noted by commission staff, non-carbon capture sequestration capable coal technologies were not considered for analysis in the company’s busbar screening model.
“Again, while Dominion may submit its preferred models, we find that future IRP filings should not be so limited,” the commission chided. “A decision to prohibit the construction of any type of power plant, coal-fired or otherwise, in Virginia is a policy decision for the General Assembly. Accordingly, Dominion’s future IRP filings shall include consideration of non-carbon capture sequestration capable coal resources (as new construction and through the purchase of existing facilities) relative to other technologies included in its busbar screening process. In sum, both coal and nuclear options should be considered against the full panoply of conventional, renewable, and other resource alternatives.”
The commission also said in the Oct. 5 order that it believes that Dominion should adequately consider third-party market alternatives as capacity resources. Independent power groups had complained in this proceeding that the utility was favoring its own generation for future capacity additions. Wrote the commission in response: “We do not conclude, however, that Dominion should be required to perform independent market tests as part of the IRP because, as noted by Consumer Counsel, ‘the IRP is a planning document, and is not a commitment to pursue any particular investment.’ Rather, we find that market alternatives are appropriate for consideration in cases where Dominion seeks a certificate of public convenience and necessity for specific investments.”
Dominion’s 2012 IRP features coal retirements, North Anna addition
Retirements of coal-fired generation at the Yorktown and Chesapeake power plants are among the many elements of the 2012 IRP that Dominion filed Aug. 31 at the commission. Dominion said that while the Preferred Plan in the Aug. 31 IRP is, under current planning assumptions, higher cost than the Base Plan, the Preferred Plan will provide fuel-price stability for customers over the long-term by reducing an over-reliance on any one fuel source or generation technology.
The Preferred Plan also provides the most reliable baseload, emissions-free energy over the long-term by incorporating an additional nuclear unit at North Anna, as well as 248 MW (nameplate) of onshore wind, 10 MW (nameplate) of brownfield solar and 24 MW (nameplate) of solar capacity (30 MW direct current) from the Community Solar Power Program, Dominion said. Also included is a renewable 15 MW municipal solid waste (MSW) non-utility generator (NUG) in 2014.
“Nuclear power, despite its high upfront capital costs, has very low long-term operating costs, no air emissions, and a long track record of delivering reliable baseload energy,” the 2012 IRP said. “The Company’s customers today benefit substantially from the Company’s historic investments in four nuclear units.”
The Preferred Plan (Plan B) is, under current planning assumptions, higher cost than the Base Plan (Plan A), which for new build generation relies exclusively on natural gas-fired generation over the Study Period. “While natural gas is a critical component of the Company’s fuel mix, nuclear, and renewable generation are also central components to achieve the Company’s objective of long-term fuel diversity and therefore price stability and system reliability in an environmentally responsible manner,” Dominion argued.
The Preferred Plan includes:
- the repowering of Bremo Power Station Units 3 and 4 totaling 227 MW from coal to natural gas by 2014;
- three ongoing coal-to-biomass conversions at the Altavista, Hopewell and Southampton units, totaling 153 MW.
Firm and prospective new generating options in the plan include:
- Warren County Power Station, representing 1,337 MW of natural gas-fired combined-cycle capacity;
- Brunswick County Power Station (natural gas) and North Anna Unit 3 (nuclear) which total approximately 2,828 MW;
- the Community Solar Power Program, which includes up to 7 MW of firm capacity (24 MW nameplate, 30 MW DC) of company-owned photovoltaic solar distributed generation;
- a mix of potential conventional generation resources including combined-cycle (CC) and combustion turbine (CT) plants totaling about 2,175 MW;
- NUG capacity and energy under contract including a new renewable MSW NUG of 15 MW in 2014; and
- PJM market purchases which average around 316 MW of capacity and 12% of energy annually.