Virginia Electric and Power (Dominion Energy Virginia) and Virginia State Corporation Commission (SCC) staff on May 26 filed comments in response to a report by a hearing examiner regarding the company’s proposed 500-kV rebuild project in Virginia.
As noted in the company’s May 26 comments, the company in December 2016 filed an application with the SCC for a certificate of public convenience and necessity (CPCN) authorizing it to rebuild four structures, entirely within existing right of way (ROW), of the approximately 44.4 miles of existing 500-kV Chickahominy-Surry Line #567, located in Charles City, Prince George County and Surry County, Va.
Specifically, the company said that it proposes to rebuild four structures on its existing Line #567 where it crosses the James River between Windmill Point in Prince George County and Wilcox Wharf in Charles City County. The company said that it proposes to remove the two existing “COR-TEN” anchor structures on land and the two lattice “COR-TEN” river structures in the river, as well as to install two new galvanized anchor structures (on land) and two new galvanized lattice river structures (in river).
The company said that there is an immediate and current need for the rebuild project to assure that the company can continue to provide reliable electric transmission service consistent with its obligation under Virginia law to serve retail electric customers in its exclusive service territory.
Dominion Energy Virginia also noted that SCC staff, in a March report, concluded that it does not oppose the company’s request for the issuance of a CPCN for the rebuild project.
The company said that it submitted pre-filed rebuttal testimony of four witnesses in late March, explaining why the company’s original $10.9m conceptual cost estimate increased and presenting a revised conceptual cost estimate of $37.6m for the rebuild project. According to one witness, the company does not support using a post-treatment chemical process to dull the galvanized finish of the transmission towers because doing so poses a risk of shortening the service life of the galvanized coating on the steel, and creates a risk of costly increased maintenance requirements for the towers during their service life.
A hearing examiner convened a public evidentiary hearing on May 3, during which staff reaffirmed its position that the company has demonstrated the need for the rebuild project and that it does not oppose the issuance of a CPCN for the project, the company added. Staff also said that it neither recommends nor opposes chemical dulling for the rebuild project but identifies the benefits and drawbacks of dulling, the company noted.
Dominion Energy Virginia said that the hearing examiner’s report, issued on May 22, included such findings as that the proposed rebuild project is needed so that the company can replace aging transmission line infrastructure and continue providing reasonably adequate electric service to its customers.
The company said that it supports the findings and recommendations contained in the hearing examiner’s report. The company also said that the SCC should adopt the hearing examiner’s finding that chemical dulling is inappropriate for the rebuild project, adding, “There is no dispute between the company and staff that galvanized steel towers will noticeably dull in a relatively short period of time compared to the average service life of 40 to 60 years for those galvanized steel towers in the company’s service territory.”
The company and staff have provided evidence that full natural dulling will occur within a couple to a few years in the company’s service territory. The only issue in the proceeding, Dominion Energy Virginia added, is whether the galvanized steel towers and anchor structures should be chemically dulled to mitigate their visual impact.
“Upon consideration of this issue, the hearing examiner found that ‘the transmission line structures should not be chemically dulled as a visual mitigation measure under the particular facts developed in this case,’” the company said. “As the hearing examiner’s analysis made clear, the question of whether the commission should direct the company to chemically dull transmission line towers should be determined on a case-by-case basis.”
Among other things, the company said that it agrees with the hearing examiner’s finding that the commission should not direct the company to chemically dull the structures in this case, noting that the transmission towers for the rebuild project will be in the middle of the James River with the sky as the background. As the hearing examiner said, “the transmission towers in the middle of the James River will be clearly visible whether they are dulled or not,” the company said.
In its May 26 comments, staff said that it supports most of the findings and recommendations of the hearing examiner’s report, including that the project is needed and should be approved.
Staff said that it submits its comments on the narrow issue of whether, prior to their construction, the two galvanized steel towers in the James River and/or the two galvanized steel anchor structures on the shoreline that comprise the proposed replacement structures for the project should be chemically dulled to mitigate their visual impact.
Staff said that in its opinion, whether or not to chemically dull transmission line structures requires a balancing of cost and visual impacts. Based on an investigation directed in an SCC case involving another electric transmission project, staff concluded that industry accepted measures can ensure that chemically dulled structures are fabricated and used without negative impacts to service life or maintenance requirements. Nothing in the record of the instant case has caused staff to doubt those conclusions, staff added.
While the hearing examiner’s report correctly recognizes that the visibility of any given transmission structure depends in part on its color and backdrop, consideration of chemical dulling involves another significant aspect of visibility that is not explicitly identified in the report – glare or reflectivity, staff said. If not dulled, galvanized steel transmission structures are reflective for a period of time after initial construction, staff noted.
To be clear, staff said, chemical dulling does not make transmission line structures invisible, but chemical dulling mitigates, at a cost, the visual impact caused by the sun reflecting off new galvanized steel for the period between its initial installation and when the same dulled state would otherwise occur naturally.
For the instant project, the company estimates the cost to chemically dull all four replacement structures would total $78,400, staff said, adding that that incremental cost – about 0.2% of the total project cost of $36.7m – is comparable to what staff has observed for other projects.
On the visual impact side of the equation, considerations for this particular project include that it would replace two “COR-TEN” lattice towers in the James River that are about 414 feet tall with galvanized steel lattice towers of about the same height and in the same locations as the existing towers, staff said.
Staff said that in its opinion, the record in this case could support an SCC decision to direct chemical dulling for all, some, or none of the project’s replacement structures, depending on how the SCC weighs the record evidence. Based on the specific facts of the case, staff said that it neither opposes nor supports chemical dulling for the project.