Virginia Electric and Power d/b/a Dominion Virginia Power in Aug. 30 comments, urged the Virginia State Corporation Commission (SCC) to approve its proposed 8-mile, 500-kV Surry-Skiffes Creek transmission line and other facilities, but others, like James City County, Va., remain steadfastly opposed to the project.
The entities recently submitted comments in response to the Aug. 2 report on the project by Alexander Skirpan Jr., senior hearing examiner with the SCC.
Dominion Virginia Power
In its Aug. 30 comments Dominion Virginia Power said that it strongly supports the report’s recommendation that the company’s application be approved, subject to certain conditions.
The company urged the SCC to adopt the report with several clarifications and exceptions, and to issue a final order approving and certificating the project, as proposed. The need for the new facilities to be completed by June 1, 2015 requires that construction begin by Oct. 1, and the company requested that the final order be issued by that date.
Dominion Virginia Power seeks approval and a certificate of public convenience and necessity to build by the summer of 2015 a new approximately 8-mile, 500-kV overhead transmission line from the existing Surry switching station in Surry County, Va., across the James River to a new 500-kV-230-kV-115-kV Skiffes Creek switching station in James City County, Va.; the proposed Skiffes station to be built on a 51-acre parcel of land owned by the company since the 1970s; about 20.2 miles of new 230-kV transmission line from the proposed Skiffes station through the counties of James City and York and the cities of Hampton and Newport News to the company’s existing Whealton substation located in Hampton; and additional facilities at the existing Surry station and Whealton substation.
The company requested that the SCC rule, as part of its final order approving the project, that Skiffes station constitutes a “transmission line,” noting that the issue has been fully heard.
The report correctly concludes that the station “is necessary to or inseparable from the proposed project, and will best serve the public interest and satisfy the requirements of controlling statutes,” the company said.
An affirmative decision in this proceeding on the “transmission line” issue is critical to the effective exercise of the SCC’s jurisdiction over the construction of the proposed project, and other transmission lines, and to the timely completion of the project, the company said.
The company also said it requested clarification with regard to several statements made in the report in consideration of the 230-kV transmission, transmission plus generation and stand-alone generation alternatives.
The company agrees with the report’s findings that those alternatives resolve the identified need, but do so at a significantly higher price and at a greater risk of failing to meet the need date.
However, the company does not agree with the report that the Mercury and Air Toxics Standards (MATS) compliance date of April 1, 2015 is a “soft” deadline, that the company did not provide “convincing” construction estimates of the underground 230-kV alternatives and that any ranking of the 230-kV transmission and generation alternatives as viable solutions for approval by the SCC is appropriate.
The company also urged the SCC to approve the “updated proposed route (with James River Crossing Variation 1)” for the 500-kV line to Skiffes station as the route that most reasonably minimizes adverse impacts. Similarly, the company urged the SCC to reject the report’s “problematic recommendation” that the SCC approve “James River Crossing Variation 4” if, within three weeks after the final order is issued, the James City County Economic Development Authority (EDA) were to reverse its current position and execute an easement granting the company a right-of-way through EDA property crossed by the variation.
Furthermore, the company requested that the SCC clarify the report’s last two recommended conditions, which apply to the company’s construction practices and right-of-way maintenance policies, to expressly confirm that those conditions apply only to its activities on BASF Corporation property.
Old Dominion Electric Cooperative
In its Aug. 30 comments, Old Dominion Electric Cooperative (ODEC) said it has a unique interest in the proceeding because, as a PJM Interconnection network transmission customer for service over Dominion Virginia Power-owned facilities, ODEC and its members will bear a share of the cost of building and operating the proposed project by way of Dominion Virginia Power’s formula transmission rate as filed with FERC.
ODEC said it supports the proposed project as modified in the course of the proceeding and generally supports Skirpan’s findings and recommendations.
All things considered, it is clear that the proposed project best resolves the NERC 2015 and 2021 compliance requirements, ODEC said, adding that the proposed project also accomplishes that result in a timely manner and at a reasonable cost.
“To ODEC, the finding that the proposed project is the least-cost viable alternative for addressing the identified NERC reliability violations is the most important finding and recommendation of the proceeding,” ODEC said.
Among other things, ODEC noted that Skirpan accepted evidence that, for ratemaking purposes under FERC-approved PJM cost allocation procedures, “PJM’s Dominion Zone would receive 12.38% of the cost of a 500 kV transmission line and 99.84% of the cost of a 230 kV transmission line.”
In short, ODEC noted, the 230-kV proposals are neither physically nor economically viable.
James River Association
In its Aug. 30 comments, the James River Association (JRA) said that Skirpan “misconstrued and misapplied” the statutory standard that requires that impacts on Virginia’s historic and scenic assets be minimized in delivery of electrical service in the state.
The “great weight of the evidence on impacts” and the testimony and designations by state and federal authorities relative those impacts were either ignored or dealt with briefly and inadequately, JRA said.
JRA said it maintains that the proposed Surry-Skiffes Creek line will have a severe effect on the viewshed and on the experiences of recreational river users or visitors at historic sites in the area. “By introducing a large industrial and modern structure in the river, the transmission line project will mar a landscape that currently possesses scenic, historic, and ecological value that is uniquely significant. Despite over 400 years of European settlement and development beginning at Jamestowne Island, the landscape and forested buffers surrounding the area have remained largely intact and the views are evocative of a colonial era.”
JRA also noted that the proposed project would “without question” affect the conservation focus areas near James City County, including the Chippokes Plantation State Park and Hogg Island Wildlife Management Area, and degrade the experiences of using the John Smith Trail. “From the perspective of a boater or paddler on the river, the impacts from the proposed project would be severe and viewshed dominated by the proposed power lines,” JRA said.
Among other things, the association said that finding another alternative to the proposed project and the proposed alternative project is appropriate and important to preserving the James and Chickahominy Rivers and their viewsheds, noting that the economic, social and environmental benefits of this alternative justify substantial additional investment.
James City County, Save the James Alliance
In their Sept. 3 comments, James City County and the Save the James Alliance – collectively, the county – opposed Skirpan’s report, noting that the damage caused by the proposed project would tarnish the “irreplaceable cultural and historic value of the Historic Triangle” and have a negative impact on tourism and the community.
“The success of the local tourism industry and the ability to market the historic sites impact all the area’s citizens, whether through employment, recreation, or services funded by tax revenues,” the county said.
The federal, state and local governments have spent hundreds of millions, if not billions, of dollars to create infrastructure compatible with the cultural and scenic value of the Historic Triangle, the county said, adding that private investments to preserve historic assets are monumental. Investments in Colonial Williamsburg alone represent about $1bn, the county said.
The report identifies transmission and generation alternatives proposed that would satisfy the company’s needs, but dismisses them based on cost and the ability of Dominion to complete the proposed project within its time constraints.
“Dominion should not be exempt from the obligation to develop responsibly, as is required by all others in the Historic Triangle,” the county added. “The reality is that residents, businesses, and governments have paid, and continue to pay, higher costs to develop property in a sensitive manner. Dominion should be held to the same standard.”
Among other things, the county said Skirpan misconstrued and misapplied a statute, essentially ignoring its directive that the impacts on the state’s historic assets be minimized or else the application must be denied. The SCC must reject Skirpan’s recommendation and follow the statute’s mandate.
The statute states, in part: “Whenever the commission is required to approve the construction of any electrical utility facility, it shall give consideration to the effect of that facility on the environment and establish such conditions as may be desirable or necessary to minimize adverse environmental impact.”
The county said: “In his zeal to solve Dominion’s problems with [NERC] requirements, the hearing examiner has allowed the ‘need’ requirement to consume and negate this other, independent statutory mandate. As confirmed by the overwhelming evidence and witness testimony in the case, there is no way to minimize the impacts of this application given the project’s size, scope and construction, and the unique historic nature of the area.”
Dominion Virginia Power is a subsidiary of Dominion Resources (NYSE:D).