Getting gas out of buildings is critical for climate action, but the recipe isn’t easy

I grew up with brothers, so I knew from an early age that the surest way to make friends with guys was to feed them homemade cookies. I took this strategy with me to college, commandeering the tiny kitchenette tucked into the hallway of my coed dorm. The aroma of chocolate chip cookies hot out of the oven reliably drew a crowd.

One fan was so enthusiastic that he wanted to learn to make cookies himself. So the next time, he showed up at the start of the process. He watched me combine sugar and butter, eggs and flour.

Instead of being appreciative, he was appalled. It had never occurred to him that anything as terrific as a cookie could be made of stuff so unhealthy. It’s not that he thought they were created from sunshine and elf magic; he just hadn’t thought about it at all. He left before the cookies even came out of the oven.

I felt so bad about it, I ate the whole batch.

Cookies are practically health food compared to other things we consume without really understanding the dangers. 

It’s not just food. Plastic packaging, chemical additives, PFASphthalates and numerous other chemicals enter our homes and bodies without our conscious acquiescence, causing havoc for ourselves, our children and the rest of life on earth. It’s hard to know the risks, harder still to avoid them. So maybe you carry reusable bags and water bottles, buy organic if you can, and otherwise, try not to think too hard about it.

Where ignorance is bliss—or at any rate, a state of mind sufficient to keep you from a complete mental breakdown — you could be excused for feeling ‘tis folly to be wise. Why not just eat the cookies?

Well, because sometimes reading the ingredients can make a difference. Public pressure has been the major driver of government action on climate, particularly in decarbonizing the electric sector. People saw the recipe for their power supply and recoiled at all that fossil fuel. Short of installing solar panels on their rooftops, individuals in most states have little control over their source of electricity. It was a collective outcry that led to nearly half of all states setting carbon-free electricity targets. 

It seems odd, then, that we have not seen the same outcry when it comes to fossil fuel use in buildings, including natural gas in homes. As our electricity gets cleaner, buildings must become all-electric on the way to a fully decarbonized energy economy.  

Turns out, that’s a tall order. About 48 percent of American homes use natural gas for heating, and many also have gas appliances like stoves and hot water heaters. Starting in 2019, a few cities started banning new gas connections in an effort to speed the transition to all-electric homes. But in response, the gas industry persuaded legislatures in 20 states to prohibit localities from enacting such bans. (An industry effort to “ban the bans” in Virginia failed mainly because no localities have tried to go that route.)

For now at least, the industry seems to have public sentiment on its side. Natural gas is truly the chocolate-chip cookie of fossil fuels: it heats the air reliably, chefs love it and it’s lower in calories—I mean, carbon—than coal. Even the name sounds benign. What can be wrong with something “natural?” 

Disillusionment sets in only when you read the recipe. (“First, frack one well…”) Understanding the harmfulness of the ingredients is the key to getting people to insist on all-electric homes and businesses. The primary component of natural gas is methane, a greenhouse gas far more potent than CO2. Methane leaking from wellheads, pipelines, compressor stations and storage facilities contributes alarmingly to climate change. Older cities are riddled with leaking distribution pipelines running through neighborhoods, especially those housing low-income and non-White residents. Occasionally, they explode. 

Those beloved gas stoves leak methane even when turned off, and burning gas in buildings causes high levels of indoor air pollution. Cooking with gas releases respiratory irritants, including nitrogen dioxide, ultrafine particulate matter (PM 2.5), carbon monoxide and formaldehyde. The effect is particularly harmful to children, with studies showing children living in homes with gas stoves are 42 percent more likely to suffer from symptoms of asthma.

It used to be that gas outperformed electricity in buildings, but no longer. Recent advances in technology mean electric heat pumps provide heating and air conditioning efficiently and effectively even in very cold climates. Every gas appliance has an electric counterpart. Even for cooking, gas has met its match in electric induction stoves, which have been winning over chefs nationwide. In a few years, we will wonder why we ever allowed open flames in our kitchens.  

Cost and convenience also favor all-electric buildings. An electric heat pump instead of both a gas burner and electric air conditioning means only one system to maintain and one utility bill instead of two. 

The question isn’t why homeowners would give up gas, but why builders still include it. Clearly, no one is reading the recipe.

With so much gas infrastructure already in place, and so little public awareness of the dangers, getting the gas out of buildings will be a slow process. In Virginia, gas companies continue to propose pipeline projects that would actually increase supply, in the hopes of locking in new customers. This is, to use the technical term, nuts. Those pipelines will have to be abandoned within a couple of decades, not “just” because the climate crisis demands it, but because consumers won’t keep buying.

Certainly, it will take time for most people to grasp how harmful methane is and how superior the alternative is. Once consumers begin insisting on all-electric buildings, however, gas utilities will enter a death spiral as they are forced to raise prices for remaining customers, who will then switch to electricity, too. 

At that point, electrification of the building sector will be complete, and we will begin to close the (cook)book on gas.

This article originally appeared in the Virginia Mercury on July 7, 2022.

Dear readers: Many of you know that although I write independently of any organization, I also volunteer for the Sierra Club and serve on its legislative committee. The Sierra Club’s Virginia Chapter urgently needs funds to support its legislative and political work towards a clean energy transition. So this summer I’m passing the hat and asking you to make a donation to our “Ten Wild Weekends” fundraising campaign. Thanks!

What new Virginia laws reveal about how the natural gas industry sees its future 

Natural gas is having a moment. The war in Ukraine spotlighted Europe’s heavy reliance on Russian gas and the challenge of replacing it with new supplies from elsewhere. Suddenly the Biden administration, after talking so much about the need to get off fossil fuels, wants to expand oil and gas production and boost exports of liquified natural gas. 

The president still intends to address the climate crisis, just not right now. The sudden shift brings to mind St. Augustine’s prayer: “Lord, make me virtuous, but not yet!”

Don’t be fooled, though. In fact, natural gas is facing an existential crisis. Back when it was cheap, it wasn’t profitable; now that prices are high, U.S. consumers have better alternatives. Europeans will want to import our expensive LNG only until they have other options. Today’s tight supplies obscure the big-picture reality that the gas industry is in the fight for its life. 

The fracking industry likes to bill its product as the cleaner and cheaper alternative to coal in generating electricity. And indeed, advances in fracking technology produced a years-long glut of gas, driving prices so low that gas overtook coal as the top fuel in U.S. power generation beginning in 2015. Gas made up 38.3 percent of electricity in 2021 compared to coal’s 21.8 percent. 

But competition from ever-cheaper wind and solar have stalled the gas industry’s growth in the power sector. Today utilities are more interested in building renewable energy and battery storage than new gas plants. Natural gas was projected to make up only 16 percent of new U.S. electricity generating capacity in 2021, compared to 39 percent for solar and 31 percent for wind. 

High prices will exacerbate this trend. Natural gas prices today are higher than at any time since 2008, having more than trebled in just the past two years. The rise began well before the war in Ukraine, and now international market demand has pushed it higher. This is good for fracking companies that spent the last 10 years losing money, but from a utility’s perspective, price-stable renewables just look better and better. 

Graph of 5 years of natural gas prices in US dollars.
Natural gas (USD/MMBtu) https://tradingeconomics.com/commodity/natural-gas

Fortunately for the gas industry, making electricity is just one use for its product. Methane remains the dominant fuel for heating buildings, with about half of U.S. homes and businesses using it for space heating, water heating, cooking and other appliances. It is also a feedstock for many industrial operations, including fertilizer and plastics manufacturing. Protecting the first use, and expanding the second, are critical to staving off obsolescence. 

That explains three pieces of legislation passed in Virginia in the past two years, all modeled on bills enacted in other states. One, which I’ll discuss in a minute, originally would have prohibited local governments from banning new gas connections within their jurisdiction, protecting the industry’s access to new retail customers. Another sets up a way for gas companies to include methane from pig waste lagoons and other non-fossil sources in their pipelines, allowing them to claim green credit — and subsidies — for marketing what they call renewable natural gas. 

Finally, 2021 legislation promotes “advanced recycling” of waste plastics — using a process called chemical conversion to turn plastic into other plastic or into fuel and then burning it — in part to forestall efforts to phase out single-use plastics like Styrofoam food containers and plastic bags. As a technology, chemical conversion is inelegant, being energy-intensive and highly polluting. As a business, the economics are questionable (and the main company benefiting from the law canceled plans for a facility in Virginia). But as PR, the reframing is brilliant. Why not expand plastics production forever if we can turn the waste into fuel or new plastic?

Indeed, the success of the law can be seen in Gov. Glen Youngkin’s new executive order ostensibly promoting recycling while overturning a previous order from Ralph Northam that required executive agencies to give up single-use plastics by 2025. General Assembly members are also falling for the propaganda, proposing via the state budget to delay the ban on polystyrene food containers that was to have taken effect beginning next year. 

Banning the bans: the gas industry fights building electrification

RNG and plastics are important for the gas industry, but protecting its market share in the building sector is central to its future. Ultimately it is doomed to failure. All-electric buildings are a requirement for a fully decarbonized economy, and their health and safety advantages make a compelling case for localities that want to help meet climate targets by preventing new homes from being connected to gas lines. Some cities in solidly blue states have banned new gas hook-ups; elsewhere, red state legislatures are passing laws to ban the bans.

Public support for these bans will grow as people learn more about the hazards of using gas in their homes. Read enough stories about methane leaking from underground pipes and in homes (and occasionally exploding and setting fire to buildings), or about the health impacts of indoor air pollution from gas heaters and stoves, and you may wonder why we ever thought it a good idea to have open flames in our homes. Yet once a house is built with a gas furnace and appliances, it is much harder for a homeowner to go all-electric. 

To be clear, though, no Virginia jurisdiction has sought to ban gas connections, and it’s not clear whether they could do so in a Dillon Rule state like Virginia. Right now, a law to keep them from doing so sounds a little on the hysterical side, like prohibiting people from walking tigers off-leash. 

Indeed, the proponents of HB1257 could cite only a much narrower threat. The City of Richmond recently committed itself to achieving net zero greenhouse gas emissions by 2050. Unlike almost any other city in Virginia, Richmond owns a gas utility that serves its residents and businesses. Sometime in the next 28 years, if the city is serious, it will have to sell the utility or shut down gas service, forcing customers to look elsewhere if they want gas. 

The gas industry and its industrial customers used this far-off threat as a pretext for a Virginia ban-the-ban bill. In its original form, HB1257 (Kilgore) declared it the right of every person to access natural gas, calling this “energy justice,” and explicitly forbidding any public entity from doing anything to interfere with this sacred right. (Oh, except that gas utilities don’t have to supply gas even to willing customers if they can’t make money doing so, and they are free to cut off service to anyone who can’t pay their bills. Justice stretches only so far as profit permits.) 

The Republican-led House passed the whole bill, but the Democratic-led Senate pared it back to deal just with a locality that gets out of the gas utility business, requiring that it give three years’ notice and try to sell or auction off the utility. The final version omits the “energy justice” language that was such an inspiring tribute to George Orwell, but it solves the “immediate” problem in Richmond. 

But it’s not likely that we have seen the end of legislative efforts in Virginia to ban local restrictions on natural gas connections. The gas industry needs to lock in new customers now, because its future is looking very bleak indeed. 

This column originally appeared in the Virginia Mercury on April 21, 2022.

Ignoring state climate rules, Dominion decides what carbon regulations should look like

woman in dinosaur costume holding sign reading clean energy now

Four out of five dinosaurs agree. The fifth, that would be Dominion. Photo courtesy of Sierra Club Virginia Chapter.

For several years now, Dominion Energy Virginia has factored into its plans an assumption that electricity from carbon-emitting power plants will eventually include a cost reflecting CO2’s role as the primary driver of global warming. Dominion says it has even integrated this into its corporate goals, targeting an 80 percent reduction in CO2 emissions by 2050.

That promise may be more propaganda than corporate lodestar, but in any case the utility’s Integrated Resource Plans regularly point to the probability of future carbon regulations as a reason to build new renewable energy facilities and close old coal plants.

Planning for constraints on CO2 emissions proved wise this spring when Virginia’s Department of Environmental Quality finalized a state carbon cap-and-trade program. The DEQ regulations call for Virginia power plant owners to trade carbon allowances with those in the member states of the Regional Greenhouse Gas Initiative (RGGI). A Republican budget maneuver has delayed implementation of the new rules, but once they take effect they are expected to hasten the retirement of expensive old coal plants and support investments in new renewable energy projects.

But it’s not the DEQ regulations that Dominion is planning around. The utility’s 2019 update to its 2018 IRP, filed with the State Corporation Commission on Aug. 29, treats the DEQ regulations as hypothetical. Instead, it posits some unspecified future federal carbon regulations that, apparently, it would like much better.

The update describes three alternative scenarios, down from five in the 2018 IRP. The first is a “base case” that assumes no carbon emission constraints. The second assumes the state carbon limits take effect as well as some future federal regulations, and the third assumes federal (but not state) limits. However, the cover letter makes it clear that only the third scenario actually describes what Dominion intends to do. As it happens, that is the most expensive— and most profitable —plan.

The primary feature of the base case is that it keeps some old coal units running that will be closed in the other scenarios. According to Dominion, this makes it the least-cost approach to meeting electricity demand. Whether that’s true is a matter of dispute; these units hardly run at all any more, and experts for environmental organizations in the IRP hearing testified that retiring them will save money for customers.

It suits Dominion’s political strategy, however, to pretend that coal remains a low-cost option. This fiction makes coalfield legislators happy, and it allows Dominion to blame rising electricity rates on environmental regulations instead of on its own profligate spending and excess profits.

But Dominion Energy made a big bet on fracked gas, not coal. It won’t fight to keep outdated coal plants online and spewing out CO2 if it’s cheaper to close them. Gas plants are another matter. Dominion Energy’s massive investments in gas transmission and storage make the company keen to keep Virginia gas plants running full-tilt, and to build as much new gas generation as possible.

For that reason, Dominion hates the DEQ regulations. It warns the regional cap and trade plan will result in power from outside the state replacing electricity from Dominion’s combined-cycle gas plants, which provide baseload power. Dominion argues this will lead to higher, rather than lower, carbon emissions as well as higher consumer costs.

DEQ and others disagree on both counts, though the SCC takes Dominion’s view. So although Dominion labels its second scenario RGGI-compliant, it treats the DEQ regulations as hypothetical, as if Gov. Ralph Northam might change his mind any day now and order them scrapped.

Instead, Dominion offers its third scenario, positing only unspecified and (with Trump as president) truly hypothetical future federal carbon regulations. In Dominion’s fantasy, a federal plan will be strong enough to support Dominion building profitable new renewable energy and storage projects, but not so strong that it can’t also build a bunch of new gas plants.

Ergo, that’s what Dominion is shooting for. The cover letter accompanying the IRP update makes it clear that Dominion is already pursuing projects that appear only in the third plan. These include a 300 MW pumped hydro storage project that will take a decade to develop and cost upwards of $1.5 billion (if indeed it pans out), and an 852 MW offshore wind project slated for 2025, a year later than what Dominion told investors in March.

The third scenario also includes more than 3,000 MW of solar between now and the end of 2034, but that’s actually a whole lot less solar than under the RGGI scenario. Even the base case has more solar. Go figure.

Still missing is the rest of the 2,000 MW of offshore wind that the Virginia lease area can support. Also still missing are thousands more megawatts of wind and solar that Virginia would need if, instead of a gas-friendly plan, the federal government were to enact regulations actually sufficient to the climate crisis.

Dominion has not even modeled that possibility. The update’s third scenario still includes 10 new fracked-gas combustion turbines, a total of 2,425 MW, with two units coming online every year from 2022 through 2026.

Maybe the Dominion executive team thinks it knows more than the rest of us do about the federal climate plan we’ll see once Donald Trump is sent packing in 2020. More likely, Dominion is simply using its IRP carbon assumptions to bolster its case for more spending and higher profits.

In which case, the more things get updated, the more they stay the same.

 

This article originally appeared in the Virginia Mercury on September 13, 2019.

Why Trump won’t stop the clean energy revolution

A protest in Manhattan against the presidency of Donald Trump, held the day after the election. Photo credit Rhododendrites - Own work, CC BY-SA 4.0, https://commons.wikimedia.org/w/index.php?curid=53011447

A protest in Manhattan against the presidency of Donald Trump, held the day after the election. Photo credit Rhododendrites – Own work, CC BY-SA 4.0, https://commons.wikimedia.org/w/index.php?curid=53011447

It is not an overstatement to say that Donald Trump’s win over Hillary Clinton horrified everyone who is worried about climate change. Reading the news Wednesday morning was like waking up from a nightmare to discover that there really is a guy coming after you with a meat cleaver.

You might not be done for, though. You could just end up maimed and bloodied before you wrest the cleaver away. So with that comforting thought, let’s talk about what a Trump presidency means for energy policy over the next four years.

I’ve had a lot of time to think about this. As a career pessimist, I’ve been worried about the possibility of a Trump win since last spring. I can fairly say I was panicking before panic became mainstream. But even with the worst-case scenario starting to play out, I’m convinced we will continue making progress on clean energy.

There is no getting around how much harder a Trump presidency makes it for those of us who want the U.S. to meet its obligations under the Paris climate accord. It’s not clear that Trump can actually “cancel” the accord, as he has promised to do. On the other hand, a man who puts fossil fuel lobbyists and climate skeptics in charge of energy policy is hardly likely to ask Congress for a carbon tax.

Nothing good can come of it when the people in charge relish chaos and embrace ignorance. Destroying the EPA will not stop glaciers melting and sea levels rising.

But just as politicians can’t repeal the laws of physics driving global warming, so there are other forces largely beyond their control. Laws and regulations currently in place; state-level initiatives; market competition; technological innovation; and popular attitudes towards clean energy have all driven changes that will withstand a fair amount of monkeying with. It’s worth a quick review of these realities.

Coal is still dead

Donald Trump’s promise to bring back coal jobs is about as solid as his promise to force American companies to bring jobs back from China. Even if he’s sincere, he can’t actually do it.

The economic case for coal no longer exists, and that remains true even if Trump and anti-regulation forces in Congress gut EPA rules protecting air and water. Fracking technology did more than the Obama administration to drive coal use down by making shale gas cheap. A glut of natural gas pushed prices down to unsustainable levels and kept them there so long that utilities chose to close coal plants or convert them to gas rather than wait.

What gas started, renewables are finishing. Today, coal can’t compete on price with wind or solar, either. That leaves coal with no path back to profitability. Not many utilities want to pollute when not polluting is cheaper.

Nor will the export market recover. China doesn’t want our coal, and a president who pursues protectionist trade policies will find it hard to get other countries to take our products.

It’s also hard to find serious political support for coal outside of a handful of coal states. Politicians say they care about out-of-work coal miners, but they care more about attracting industry to their states with cheap energy. That is certainly the case in Virginia, where Governor McAuliffe didn’t even include coal mining or burning anywhere in his energy plan.

If there is a silver lining for coal miners, it’s that without an Obama bogeyman to blame for everything, coal-state Republicans will have to seek real solutions to unemployment in Appalachia.

Solar and wind are still going to beat out conventional fuels

Analysts predict renewable energy, especially solar, will become the dominant source of electricity worldwide in the coming decades. Already wind and solar out-compete coal and gas on price in many places across the U.S. As these technologies mature, prices will continue to fall, driving a virtuous cycle of escalating installations and further price reductions.

While federal policies helped make the clean energy revolution possible, changes in federal policy now won’t stop it. Today the main drivers of wind and solar are declining costs, improvements in technology, corporate sustainability goals, and state-level renewable energy targets.

As the revolution unfolds over the next decade, the folly of investing in new fossil fuel and nuclear infrastructure will become increasingly clear. Natural gas itself is cheap right now, but new gas infrastructure built today will become worthless before it can recover its costs and return a profit. Corporations like Dominion Resources and Duke Energy are investing in gas transmission pipelines and gas generating plants only because they think they can profit from them now, and force captive utility customers to bear the cost of paying off the worthless assets later.

Advocates fighting new gas infrastructure have mostly had to work at the state level, since they’ve received little help from the Feds. That much won’t change. The cavalry isn’t coming to save us? Well, we are no worse off than we were before. We just have to do the job ourselves.

Dominion’s gas build-out is still a bad idea

Dominion Power is enthusiastic about natural gas, but we’ve seen this movie before. Environmentalists and their allies tried, and failed, to stop Dominion’s newest coal plant in Wise County from being built. Regulators approved it in spite of Dominion’s cost projections showing a levelized cost of energy of 9.3 cents per kilowatt-hour. That’s about twice the wholesale price of energy today, and well above where wind and solar would be even without subsidies.

Approval to construct the plant came in the fall of 2008. A mere eight years later, that looks like a terrible decision. Dominion Virginia Power shows no further interest in building coal plants. Instead, it has since built two huge natural gas plants and received approval to build a third. Its sister company is building the Atlantic Coast Pipeline to lock ratepayers into even more gas.

Eight years from now, those will look like equally bad decisions.

Renewable energy is popular with everyone

One of the most remarkable pieces of legislation passed during the last few years was the extension of the Investment Tax Credit and the Production Tax Credit, subsidies that have underpinned the rapid spread of solar and wind power. It turns out that Republicans don’t actually hate subsidies; they only hate the ones that benefit other people.

Wind energy is one of the bright spots in the red states of the heartland. Farmers facing volatile markets for agricultural products appreciate the stable income they get from hosting wind turbines among the cornfields, and they aren’t going to give that up.

And everybody, it turns out, loves solar energy. There’s a simple, populist appeal to generating free, clean energy on your own roof. The failure on Tuesday of a utility-sponsored ballot measure in Florida is especially notable: the constitutional amendment would have ended net metering and led to steep declines in solar installations in the Sunshine State. Voters said no. The lesson will resonate across the South: people want solar.

Indeed, public polling for years has shown overwhelming support for wind and solar energy, across the political spectrum. Even people who don’t understand climate change think it’s a good idea to pollute less. And the energy security benefits of having wind and solar farms dotting the landscape are simple and intuitive. So while the fossil fuel industry may use a friendly Trump administration to launch attacks on renewable energy, no populist army will back them.

The Clean Power Plan was important, but not transformative

Congressional Republicans have talked smack about the EPA for years, and the Clean Power Plan raised the needle on the right wing’s outrage meter to new levels. Most EPA rules have a layer of insulation from Congressional meddling as long as Senate Democrats retain the ability to filibuster legislation that would repeal bedrock environmental laws like the Clean Air Act. And laws protecting the air and water have such broad public backing that it is hard to imagine even the Chaos Caucus going there.

The Clean Power Plan could be different. Trump’s choice of a new Supreme Court justice will produce a conservative majority that might well strike down Obama’s most important carbon rule. For a handful of states that rely heavily on electricity from aging coal plants and aren’t compelled to close them under other air pollution rules, this will buy them a few years. (But see “Coal is still dead,” above.)

For most states, though, the Clean Power Plan was never going to be a game-changer. Many states were given targets that are easy to meet, or that they have already met. As I’ve pointed out before, Virginia’s target is so modest that the state could meet it simply by adopting a few efficiency measures and supplying new demand with wind and solar. That’s if the state decided to include newly-built generating sources in its implementation plan, which it doesn’t have to do.

By its terms, the Clean Power Plan applies only to carbon pollution from power plants in existence as of 2012. Newer generating plants are regulated under a different section of the Clean Air Act, under standards that new combined-cycle gas plants can easily meet. That’s a gigantic loophole that Dominion Virginia Power, for one, intends to exploit to the fullest, and it’s the reason the company supported the Clean Power Plan in court.

Regardless of whether it is upheld in the courts, however, the Clean Power Plan has already had a significant effect nationwide by forcing utilities and state regulators to do better planning. It led to a raft of analyses by consulting firms showing how states could comply and actually save money for ratepayers by deploying cost-effective energy efficiency measures. If the Clean Power Plan doesn’t become law, states can ignore those reports, but their residents should be asking why.

For Virginia, nothing has changed at the state level. Or has it?

Virginia has off-year elections at the state level, so Trump’s election has no immediate effect on state law or policy. Most significantly, Terry McAuliffe is still governor of Virginia for another year, he still knows climate change is real, and his Executive Order 57, directing his senior staff to pursue a strategy for CO2 reductions, is still in effect. McAuliffe has disappointed activists who hoped he would become a climate champion, but Trump’s win could light a fire under his feet. He has an opportunity to put sound policies in place, if he chooses to do so.

Offshore drilling in Virginia probably isn’t back on the table

Trump has promised to re-open federal lands for private exploitation, reversing moves by the Obama administration. His website says that includes offshore federal waters. However, the decision by the Bureau of Ocean Energy Management to take Virginia out of consideration for offshore drilling isn’t scheduled to be revisited for five years. Trump’s people could change the process, perhaps, but there’s not much demand for him to do so. With oil prices low, companies aren’t clamoring for more places to drill.

Environmental protection begins at home . . . and the grassroots will just get stronger

I would hate for anyone to mistake this stock-taking for optimism. The mere fact that the clean energy revolution is underway does not mean it will proceed apace. Opportunities abound for Trump to do mischief, and nothing we have heard or seen from him during the campaign suggests he will rule wisely and with restraint.

But advancing environmental protection has always been the job of the people. Left by itself, government succumbs to moneyed interests, and regulators are taken captive by the industries they are supposed to regulate. Americans who want clean air and water and a climate that supports civilization as we know it have to demand it. It will not be given to us.

Sound economics, common sense, and technological innovation are on our side. Most important, though, is the groundswell of public support for clean energy and action on climate. That never depended on the election, and it won’t stop now.

Virginia, meet Paris. Things will never be the same.

By Tristan Nitot - standblog.org, CC BY-SA 3.0, https://commons.wikimedia.org/w/index.php?curid=41689

By Tristan Nitot – standblog.org, CC BY-SA 3.0, https://commons.wikimedia.org/w/index.php?curid=41689

After Republicans in Virginia’s General Assembly shut down the McAuliffe administration’s work on implementing the EPA Clean Power Plan last winter, Governor McAuliffe decided on an end run. He issued Executive Order 57, directing administration officials to recommend ways to reduce carbon pollution from the state’s power plants. The workgroup led by Secretary of Natural Resources Molly Ward is holding meetings this fall to gather information and advice.

This puts Ward in something of a pickle. Meeting the climate challenge requires Virginia to commit to a future with less fossil fuel, while McAuliffe is championing Dominion Power’s plans to radically expand fossil fuel investments in the Commonwealth.

Last week the European Union joined the United States, China, India, Canada, Mexico and dozens of other countries in ratifying the Paris climate accord, putting it over the threshold needed for it to take effect. The goal of the accord is to limit the increase in world temperatures to “well below” 2 degrees Celsius, 3.6 degrees Fahrenheit, a level beyond which climate effects are projected to be catastrophic. Given mounting concerns that 2 degrees isn’t sufficiently protective, the 197 signatory nations also agreed to a stretch goal of 1.5 degrees Celsius.

The U.S. is the world’s second highest emitter of CO2 after China, and our average emissions per person are two-and-a-half times that of the Chinese. No other country has contributed more to the problem. American leadership was key to bringing other countries on board, and it will be key to implementing solutions.

A few niggling details remain, like how we are actually going to do this. The EPA’s Clean Power Plan is a first step, but its scope is narrow. It addresses only carbon emissions from electric generating plants in use as of 2012, not new sources (though states can choose to do that). It doesn’t address emissions outside the electric sector. It also doesn’t address methane emissions from natural gas infrastructure, a climate threat that seriously undercuts the climate benefit of utilities switching from coal to gas. Its goal of reducing electric-sector carbon pollution by 30% by 2030 is nowhere near what’s needed.

To meet its Paris commitment, the U.S. will have to dramatically reduce fossil fuel use in everything from electricity and heating to manufacturing and transportation. The good news is that the technologies to do this exist, and they are getting better and cheaper by the day. The bad news is that even an all-hands-on-deck approach would need time to work, and there are still way too many hands sitting idle in their bunks below deck.

Future federal regulation that goes well beyond the Clean Power Plan is inevitable. Through whatever means—a carbon tax, removal of fossil fuel subsidies, new incentives, or simple mandates—renewable energy has to take over the power sector, with fossil fuels limited to a supporting role before being phased out altogether. Building codes must be dramatically strengthened to minimize energy consumption, and transportation must be electrified so vehicles run on wind and solar, not gasoline or diesel. And all this has to happen starting now.

With the U.S. committed to this path, it makes no sense for any state to pursue a fossil fuel-heavy strategy simply because federal mandates aren’t in place yet. The ratification of the Paris accord means all new fossil fuel investments—drilling machinery, fracking wells, pipelines, generating plants—must be evaluated against the likelihood that they will have to be abandoned well before the end of their useful life.

In Virginia this includes proposed new fracked-gas transmission pipelines; a new natural gas generating station that Dominion Power just received approval to build; as much as 9,000 megawatts more of natural gas generating plants that Dominion wants to build; and at least two new natural gas generating plants proposed by other developers, who would use the new gas pipelines to supply them. Altogether, these projects represent tens of billions of dollars in investments in infrastructure that would have to be shut down and left to decay within a decade or two.

All this could happen without violating the Clean Power Plan, if Virginia takes advantage of a loophole allowing it to exclude new gas plants from its implementation plan. Dominion’s gas plants alone would increase carbon emissions from Virginia by as much as 83%. That won’t get us to Paris.

It seems obvious that these investments would be better channeled into carbon-free renewable energy and reducing energy use through efficiency and building improvements. These are the “no regrets” investments that make sense for human health and economic development reasons anyway. With the Paris accord, the decision has gone from no-regrets to no-brainer.

But Dominion clearly thinks a pipelines-and-gas-plants approach will make more money for its shareholders. Dominion is betting that regulators will allow it to bill customers for the costs of new fossil fuel infrastructure even if it turns out that using it means paying a high carbon tax, or not using it at all. Dominion counts on the prevalence of climate doubt and magical thinking within the Virginia legislature and the staff of the SCC to muffle the wake-up call from Paris.

This is a deeply irresponsible and immoral calculus.

To date, Governor McAuliffe has backed Dominion at every turn. With only a year and a half left in his term, the “jobs governor” wants to lure businesses to Virginia quickly with the promise of cheap natural gas. It’s a strategy that might backfire in the short run, as savvy businesses go to states better preparing for life after Paris. Surely, it will backfire in the long run, when Virginia is left paying off unwanted fossil fuel infrastructure. The Paris accord marks a good point for McAuliffe to change his allegiance.

Indeed, after Paris, nothing will ever be the same. The days of natural gas as a bridge fuel are rapidly ending, and the U.S. has committed itself to breaking from its fossil fuel past. Executive Order 57 offers Virginia an opportunity to map out a carbon-free strategy. Time is short. Allons-y!

The “fuel” that’s helping America fight climate change isn’t natural gas

You’ve heard the good news on climate: after a century or more of continuous rise, U.S. CO2 emissions have finally begun to decline, due largely to changes in the energy sector. According to the Energy Information Agency (EIA), energy-related CO2 emissions in 2015 were 12% below their 2005 levels. The EIA says this is “because of the decreased use of coal and the increased use of natural gas for electricity generation.”

Is the EIA right in making natural gas the hero of the CO2 story? Hardly. Sure, coal-to-gas switching is real. But take a look at this graph showing the contributors to declining carbon emissions. Natural gas displacement of coal accounts for only about a third of the decrease in CO2 emissions.

Courtesy of the Sierra Club Beyond Coal Campaign, using data from the Energy Information Agency.

Courtesy of the Sierra Club Beyond Coal Campaign, using data from the Energy Information Agency.

By far the biggest driver of the declining emissions is energy efficiency. Americans are using less energy overall, even as our population grows and our economy expands

Energy efficiency is sometimes called the “first fuel” because cutting waste is a cheaper and faster way to meet energy demand than building new power plants. Improvements in energy performance cut across all sectors of the economy, from industrial machines to home electronics to innovations like LED bulbs replacing famously wasteful incandescent light bulbs.

Energy efficiency’s stunning success in lowering carbon emissions should get more attention, and not just because it is cheaper than building new natural gas-fired power plants. Efficiency has no downsides. Natural gas has plenty. Indeed, when methane leakage from drilling and infrastructure is factored in, natural gas doesn’t look much like a climate hero at all.

And that’s not the full story. A growing share of the credit for carbon reductions also goes to non-carbon-emitting sources, primarily wind, and solar. Both sources exhibit double-digit growth rates. Wind power in the U.S. has grown from a little over 9,000 megawatts (MW) in 2005 to more than 74,000 MW by the end of 2015. In 2005, the solar market scarcely existed. By early this year, we had 29,000 MW installed.

The solar trend is particularly exciting because we are just starting to see the big numbers that result from solar’s exponential growth. In the first quarter of 2016, more solar came online in the U.S. than all other power sources combined. Analysts like Bloomberg New Energy Finance see solar becoming the world’s dominant energy source over the next 25 years, driving out not just coal but also a lot of gas generation as solar becomes the cheapest way to make energy.

For an inspiring look at how this will happen, check out this presentation by author Tony Seba. As Seba argues, solar isn’t a commodity like fossil fuels; it is a technology like computers and cell phones. When technologies like these take off, they take over. Seba refers to solar technology, battery storage, electric vehicles and self-driving vehicles as “disruptive” technologies that are advancing together to upend our energy and transportation sectors.

Another graph shows us how critical these advancements will be. The U.S. is on track to achieve President Obama’s goal announced last year of lowering carbon emissions 17% below 2005 levels by 2020, but we will need more aggressive measures to meet our Paris Agreement target of 26-28% below 2005 levels by 2025. After 2025, of course, we will have to cut greenhouse emissions even further and faster.

Slide4Given the urgency of the climate crisis, we don’t have the option of waiting around for the solar revolution to bankrupt the oil and gas industry and fossil-bound electric utilities. These companies will not go quietly; already they are maneuvering to lock customers into fossil fuels. Power producers are engaged in a mad rush to build natural gas plants, and wherever possible, to stick utility customers with the costs.

For Virginians who have felt especially under attack from fracked gas projects recently, this final graph shows it’s not your imagination: Virginia is second only to Texas in new gas plant development underway. And this graph captures only a fraction of the new gas that Virginia’s major utility, Dominion Virginia Power, wants to build. In presentations to state officials, it revealed plans for more than 9,000 megawatts of additional gas generating capacity.

Based on Energy Information Agency data. Chart excludes natural gas generating units already under construction as well as those scheduled to come online after 2020.

Based on Energy Information Agency data. Chart excludes natural gas generating units already under construction as well as those scheduled to come online after 2020.

Dominion and other gas-happy utilities are betting that once plants are built and consumers are on the hook, regulators won’t want to see them idled ten years from now just because renewable energy has made them obsolete.

Indeed, Dominion and other utilities, including Duke Energy, Southern Company, and NextEra in the Southeast and DTE Energy in the Midwest, even plan to use electricity customers to make money for the gas pipelines they are building, locking Americans further into gas.

This is madness. The only sound energy plan today is one that looks forward to an era of minimal fossil fuel use. It puts efficiency and renewables front and center, shifting natural gas and other fuels to supporting roles that will shrink over time.

The shift is inevitable. Delaying it means allowing the climate crisis to worsen, while sticking customers with higher bills for decades to come. That may suit some utilities just fine, but the cost is too high for the rest of us.

 

Why does Dominion Power support EPA’s Clean Power Plan?

DominionLogoWhen utility giant Dominion Resources Inc. filed a brief in support of the federal Clean Power Plan last week, a lot of people were caught off guard. Hadn’t Dominion CEO Tom Farrell said as recently as January that it would cost consumers billions of dollars? Why, then, is the utility perfectly okay with it now?

Well, first, because the mere threat of the plan has already cost Virginia consumers a cool billion, but it’s all going straight into Dominion’s pockets. What’s not to like? Otherwise, as applied to the Commonwealth, the Clean Power Plan itself is a creampuff that could even save money for ratepayers. Farrell’s claim that it will cost billions, made at a Virginia Chamber of Commerce-sponsored conference, seems to have been a case either of pandering to his conservative audience, or of wishful thinking. (Looking at you, North Anna 3!)

And second, Dominion’s amicus brief indicates its satisfaction with the way it thinks Virginia will implement the Clean Power Plan. Dominion has been lobbying the Department of Environmental Quality to adopt a state implementation plan allowing for unlimited construction of new natural gas plants (and perhaps that new nuclear plant), which happens to be Dominion’s business plan.

If you can get everything you want and still look like a green, progressive company, why wouldn’t you support the Clean Power Plan?

The only risk here is that it makes Virginia Republicans look like idiots. Their number one priority this legislative session was stopping the Clean Power Plan, largely on the grounds of cost. They ignored the hard numbers showing the plan essentially gives Virginia a pass, and instead relied on propaganda from fossil fuel-backed organizations like Americans for Prosperity and, crucially, the word of Dominion Power lobbyists.

Sure, it wasn’t just Republicans; a lot of Virginia Democrats swallowed Dominion’s argument during the 2015 legislative session that the Clean Power Plan would be so expensive for consumers that the General Assembly had to pass a bill—the notorious SB 1349—freezing electricity rates through the end of the decade so they would not skyrocket.

SB 1349 suspended the ability of regulators at the State Corporation Commission to review Dominion’s earnings. One outraged commissioner, Judge Dimitri, calculated that the effect of this “rate freeze” would be to allow Dominion to pocket as much as a billion dollars in excess earnings, money that ratepayers would otherwise have received in refunds or credits.

Nor has SB 1349 even prevented rates from going up, since the State Corporation Commission’s approval of Dominion’s latest mammoth gas plant[1] will tack on 75 cents to the average customer’s monthly bill.

Environmental groups had opposed the gas plant, arguing approval is premature since we don’t know what Virginia’s Clean Power Plan will look like, and that Dominion hadn’t properly considered other options.

It gets worse. Building more of its own gas plants allows Dominion to terminate contracts to buy power from other generators. In theory, this should represent an offsetting savings for consumers. But as Judge Dimitri explained in a concurrence, SB 1349 means Dominion doesn’t have to subtract this savings from the bill it hands those ratepayers.[2]

As Sierra Club Virginia Chapter Director Glen Besa noted, “The State Corporation Commission decision today proves that there really is no electricity rate freeze. The SCC just allowed Dominion to raise our electricity rates and increase carbon pollution for a power plant we don’t need.”

Now, let’s have a look at what is actually in Dominion’s Clean Power Plan brief. In part, it is a defense of EPA’s holistic approach to regulating generation and a rejection of the conservative claim that the agency should not be allowed to regulate “outside the fence line” of individual plants. Adopting the conservative view, argues Dominion, could lead to widespread, expensive coal plant closures.

But mostly, Dominion likes the Clean Power Plan because the company feels well positioned to take advantage of it. The brief makes this argument with classic corporate understatement:

Dominion believes that, if key compliance flexibilities are maintained in the Rule, states adopt reasonable implementation plans, and government permitting and regulatory authorities efficiently process permit applications and perform regulatory oversight required to facilitate the timely development of needed gas pipeline and electric transmission infrastructure, then compliance is feasible for power plants subject to the Rule.

What Dominion means by “reasonable implementation plans” requires no guesswork. Virginia clean energy advocates want a mass-based state implementation plan that includes new sources, so power plant CO2 emissions from Virginia don’t actually increase under the Clean Power Plan. You or I might think that reasonable, given the climate crisis and EPA’s carbon-cutting goals. But that’s not what Dominion means by “reasonable.”

Dominion’s business plan, calling for over 9,000 megawatts of new natural gas generation, would increase CO2 emissions by 60%. To Dominion, a 60% increase in CO2 must therefore be reasonable. Anything that hinders Dominion’s plans is not reasonable. QED.

“Needed gas pipeline . . . infrastructure” is no puzzle either. Dominion wants approval of its massive Atlantic Coast Pipeline. That pipeline, and more, will be needed to feed the gaping maws of all those gas plants. Conversely, Dominion, having gone big into the natural gas transmission business, needs to build gas generating plants to ensure demand for its pipelines.

Dominion is not the only electric utility betting big on natural gas. Southern Company and Duke Energy have also recently spent billions to acquire natural gas transmission and distribution companies. Moody’s is criticizing these moves because of the debt incurred. From a climate perspective, though, the bigger problem is that this commitment to natural gas comes right at the time when scientists and regulators are sounding the alarm about methane leakage.

There is surely some irony that Dominion, while defending the EPA’s plan to address climate change, is doing its level best to increase the greenhouse gas emissions that drive it.

Indeed, anyone reading Dominion’s brief and looking for an indication that Dominion supports the Clean Power Plan because it believes the utility sector needs to respond to the climate crisis would be sadly disappointed.

On the other hand, the brief positively sings the praises of “market-based measures” for producing the lowest possible costs. This is a little hard to take, coming from a monopoly that uses its political and economic clout to keep out competition and reap excessive profits through legislation like SB 1349, and which intends to use its captive ratepayers to hedge the risks of its big move into natural gas transmission.


[1] SCC case PUE-2015-00075 Final Order, March 29, 2016.

[2] Commissioner Dimitri, in a concurring opinion:

“I would find that SB 1349 cannot impact the Commission’s authority in this matter because it violates the plain language of Article IX, Section 2, of the Constitution of Virginia, for the reasons set forth in my separate opinion in Case No. PUE-2015-00027.

“Indeed, the instant case further illustrates how SB 1349 fixes base rates as discussed in that separate opinion. The evidence in this case shows that Dominion plans to allow certain NUG contracts, currently providing power to customers, to expire while base rates are frozen by SB 1349. The capacity costs associated with these contracts, however, are currently included in those base rates. Thus, as explained by Consumer Counsel, this means that “the Company’s base rates will remain inflated” because Dominion (i) will no longer be paying these NUG capacity costs, but (ii) will continue to recover such costs from its customers since base rates are frozen under SB 1349. Based on Dominion’s cost estimates, between now and the end of 2019, it will have recovered over $243 million from its customers for NUG capacity costs that the Company no longer incurs. While other costs and revenues are likely to change up and down during this period and would not be reflected in base rate changes precluded by SB 1349, these NUG costs are known, major cost reductions that will not be passed along to customers.” [Footnotes omitted.]

 

 

McAuliffe’s stark choice on the Clean Power Plan: serve Virginia, or Dominion Power

Photo by Josh Lopez, courtesy of the Sierra Club.

Photo by Josh Lopez, courtesy of the Sierra Club.

After the Supreme Court issued a stay of the EPA’s Clean Power Plan pending its review by the D.C. Circuit, many Republican governors halted compliance efforts in their states, while most Democratic governors opted to continue. Among these was Virginia Governor Terry McAuliffe, who plans to unveil a draft state implementation plan this fall.

Deciding to move forward on President Obama’s signature climate effort was an easy call. Polls show strong support for reducing carbon pollution, and the Governor wants to prove himself a team player who supports his president and his party. McAuliffe often reiterates his conviction that climate change is already producing extreme weather and increasingly severe coastal flooding in Virginia, making government action urgent.

Governor McAuliffe has another choice before him now: he can craft a compliance plan that moves Virginia firmly in the direction of clean energy and lower carbon emissions, or he can adopt one that allows unbridled growth in new power generation from natural gas. The latter could still meet the letter of the law, but it would hugely increase greenhouse gas emissions from Virginia power plants.

McAuliffe has this choice because EPA’s rules come in two parts: the Clean Power Plan addresses existing power plants under one section of the Clean Air Act, while new power plants are addressed under another section of that law. As a result of the statutory structure and EPA’s rules, states can choose to cover both under one set of rules with a total cap on utilities’ CO2 emissions, or they can address new and existing sources separately.

If a state chooses to cover both under a single cap, new generation can be added up to the cap or go beyond if the utility buys emission allowances from another utility. But if a state treats new and existing sources separately, then new sources can grow without limit as long as each new unit meets a unit-specific standard. Of course, building more fossil-fueled power plants of any type will increase carbon emissions, at a time when the U.S. desperately needs to cut back.

The carbon reduction target EPA set for Virginia under the Clean Power Plan is extremely modest. EPA’s numbers show Virginia can meet the target for existing sources simply by not increasing emissions. If the state also includes new power plants under the cap, however, it creates a real incentive to invest in clean energy.

But there’s a problem. Dominion Resources, the Richmond-based parent company of Dominion Virginia Power, is heavily invested in the natural gas sector, primarily transmission and storage. That has led Dominion to lobby for an implementation plan that covers only existing power plants.

Excluding new sources would leave the company free to build as many new natural gas-burning power plants in the state as it wants, locking in years of increased carbon pollution, and further boosting demand for fracked gas and pipeline capacity. Dominion’s plans call for more than 9,500 megawatts of new gas generation in Virginia, equivalent in carbon impact to building eight average-sized coal plants in the state.

McAuliffe can do what Dominion wants, or he can do the right thing for the climate. He can’t do both.

The stakes are high on both sides. McAuliffe has made job creation his number one priority, and he lures new industry to the state with the promise of lower-than-average electricity rates. Dominion says supporting its natural gas plans is the way to deliver on that promise. Whether that is true or not doesn’t count in this calculus; with state law limiting governors to a single term, McAuliffe is focused on the present.

But adopting a plan that allows unlimited increases in greenhouse gas emissions would run contrary to Virginia’s long-term interests. Not only is the state on the front lines of sea level rise, it needs predictable, affordable electricity prices for decades to come. And nothing can provide that better than renewable power and increased energy efficiency.

Neither Dominion nor anyone else can guarantee the price of natural gas over the life of a new power plant. Questions of price and supply bedevil even the best analysts and make forecasting risky. Moreover, the growing awareness of the climate impacts of methane from leaking wells and pipelines is already producing calls for tighter regulation of natural gas. A carbon tax or cap-and-trade legislation would also make all fossil fuels more expensive relative to carbon-free renewables.

While the cost of using natural gas can only go up, the costs of wind, solar and battery storage are expected to continue their astonishing declines. Advances in energy efficiency promise huge savings for states that pursue programs to help customers cut their energy use.

From a bill-payer’s perspective, then, investments in clean energy make more sense than building gas plants, even without taking federal regulations into consideration. Recent analyses show Virginia can cap carbon pollution from new power plants and still save money for electricity customers.

Environmental groups say their number one energy priority this year is to ensure Virginia adopts a Clean Power Plan that includes both existing and new sources, and they are counting on Governor McAuliffe to deliver. Their message is simple: if McAuliffe wants to be on the climate team, Virginia’s compliance plan must reduce CO2 emissions, not let them grow.

In reversal, Virginia AG says localities may ban fracking

fracking signVirginia Attorney General Mark Herring issued an official advisory opinion on May 5 holding that Virginia localities have the right to prohibit hydraulic fracturing (or “fracking”) as part of their power to regulate land use within their boundaries. The letter reverses a two-year-old opinion by former Attorney General Ken Cuccinelli.

Herring’s opinion cites §15.2-2280 of the Virginia Code, which grants broad zoning powers to localities. These include the power to “regulate, restrict, permit, prohibit, and determine” land uses, such as “the excavation or mining of soil or other natural resources.” Thus, writes Herring, “I conclude that the General Assembly has authorized localities to pass zoning ordinances prohibiting fracking. The plain language of the stature also authorizes localities to regulate fracking in instances where it is permitted.”

Herring’s opinion comes in a letter to Senator Richard Stuart, who had asked whether Virginia law allows localities to prohibit “unconventional gas and oil drilling,” commonly known as fracking, and whether they may use their zoning authority “to regulate aspects of fracking, such as the timing of drilling operations, traffic, or noise.”

The letter overrules a January 11, 2013 opinion by then-Attorney General Ken Cuccinelli, which held that the General Assembly had preempted localities’ right to regulate or ban drilling when it passed the Virginia Gas and Oil Act. Under §45.1-361.5, localities may not “impose any condition, or require any other local license, permit, fee, or bond to perform any gas, oil or geophysical operations which varies from or is in addition to the requirements of this chapter.”

But, Herring notes, the statute “also includes a savings clause stating that the Act does not ‘limit or supersede the jurisdiction and requirements of . . . local land-use ordinances.’” Thus, it explicitly preserves local zoning authority to prohibit or limit fracking.

Herring concludes, “To the extent that the 2013 Opinion conflicts with this conclusion, it is overruled.”

Interestingly, if localities choose to restrict fracking but not prohibit it, they may actually leave themselves more open to challenge. Herring’s opinion reaffirms that portion of Cuccinelli’s opinion that upheld the right of localities to impose some restrictions on fracking, short of outright prohibition. However, the restriction must be “reasonable in scope” and “not inconsistent with the Act or regulations properly enacted pursuant to the Act.” As a result, a fracking company might have a better shot at challenging a restriction than it would an outright ban.

Herring adds, “Determining the extent to which particular zoning restrictions on fracking may possibly be preempted by state law will be governed by the particular facts, restrictions, and regulations at issue. Consequently, I can express no opinion on whether any particular zoning restriction has been preempted.”

Dominion’s natural gas gamble looks risky for ratepayers

Opposition to Dominon's planned Atlantic Coast Pipeline has spurred protests from landowners and environmental advocates and led to more than 5,000 comments to the McAuliffe Administration opposing the pipeline. Photo courtesy of Linda Muller.

Opposition to Dominon’s planned Atlantic Coast Pipeline has spurred protests from landowners and environmental advocates and led to more than 5,000 comments to the McAuliffe Administration opposing the pipeline. Photo courtesy of Linda Muller.

Dominion Resources and its regulated subsidiary, Dominion Virginia Power, are gambling big on natural gas. But while the utility giant will be a winner if gas prices stay low over the next 20 years, the risk of losing this bet is very real—and the risk is being borne disproportionately by Virginia consumers.

Ever since the shale gas boom sent natural gas prices into a tailspin beginning in 2008, Dominion has increasingly been putting its chips into gas. Its Virginia subsidiary just completed a 1,329 megawatt (MW) natural gas plant in Warren County, began construction last year on a 1,358 MW gas plant in Brunswick County, and last month announced plans for a 1,600 MW plant in Greenville County, to be operational in 2019. Virginia ratepayers will foot the bill for construction costs, plus the cost of operating and fueling these mammoth plants for decades to come.

But while Virginians tend to think of Dominion as an electricity provider, its bigger business line is in natural gas transmission and storage. According to the Dominion website, its subsidiary Dominion Transmission, Inc. maintains 7,800 miles of pipeline in six states and operates what it says is one of the largest underground natural gas storage facilities. Another subsidiary operates 1,500 miles of pipeline in South Carolina and Georgia. The company is moving aggressively to add and upgrade compressor stations and build additional pipeline capacity in West Virginia and Pennsylvania.

It is also angling to add a massive 42-inch diameter, 550-mile gas pipeline to run from West Virginia through Virginia to the coast in North Carolina. Promising a vast new supply of cheap fracked gas for industrial users, Dominion has won the support of lawmakers like Virginia Governor Terry McAuliffe while galvanizing opposition from landowners and environmentalists.

Meanwhile, Dominion has another game afoot, with plans to begin exporting liquefied natural gas from its Cove Point, Maryland facility. Upgrading the facility will cost the company $3.8 billion, and running the liquefaction facility will require 240 MW of power (using more natural gas). Natural gas is so much more expensive in foreign markets that Dominion considers the gamble worthwhile, even as it cites a U.S. Energy Information Administration study for the proposition that little or no natural gas would be exported if the U.S. price “increases much above current expectations.”

All of these ventures depend on one crucial assumption: that natural gas prices will remain low for as many years as it takes to fully recover the cost of these investments, and then some. For electric generation, moreover, gas has to be able to outcompete other fuel sources. That includes not just coal and nuclear, both of which are being abandoned in droves in the face of cheap gas, but also new sources like solar and wind, which have trended steadily downward in price over the past two decades. In some regions of the country (although not yet Virginia), wind and solar prices already outcompete natural gas.

Gas does have the advantage of dispatchability—the ability to provide power according to the peaks and valleys of demand, allowing it to fill in around variable energy sources like wind and solar. That makes gas vital for backup generation, at least until power storage technologies become cheaper. But it wouldn’t justify the large-scale shift to gas for baseload generation, as Dominion’s plans envision, unless the company is right that gas prices will stay low.

If Dominion’s assessment of the market is wrong, its shareholders will take a hit. Higher natural gas prices could make the export business fizzle, and there might not be enough customers to justify the pipeline buildout. That’s why the company is moving so quickly to build the three massive new natural gas generating plants in Virginia under the ownership of its regulated subsidiary. Dominion is protecting its bet by locking Virginia electricity customers into gas for the long term, guaranteeing itself a market not just for its natural gas generating plants but also for its pipeline business. If the shale boom becomes a bust, or if prices rise to pre-boom levels, it will be Virginia ratepayers who pay through the nose or get stuck with stranded assets.

How big the risk is depends on whom you ask. The gas industry claims supplies will be sufficient to meet demand for decades to come. The U.S. Energy Information Agency, that voracious consumer of yesterday’s news, largely agrees (though it has more recently begun tempering its enthusiasm). If the optimists are right, production from the major shale gas plays will increase 40% by 2030 over today’s production levels, enough to support the mad rush to gas by Dominion and other utilities like it, without upward pressure on prices.

But a more pessimistic view is gaining adherents. As described in the December 2014 issue of the journal Nature, a team of a dozen geoscientists, petroleum engineers and economists at the University of Texas at Austin (UTA) has been analyzing assumptions behind the industry’s rosy outlook, and concludes it is wrong. Instead, the UTA study indicates production of natural gas from the “big four” shale plays will slow significantly after 2016, peak by about 2020, and then decline, dropping 20% from current levels by 2030. If so, the amount of natural gas coming to market in the U.S. will be less than half of what the optimists expect. The upward pressure on prices will be enormous.

The UTA team joins a growing chorus of doubters, whose studies suggest that the shale juggernaut can’t be maintained profitably. If these pessimists are correct, we should begin seeing evidence of it well before 2020. For now, there is at the least a very serious risk that cheap gas won’t last, and anyone who can’t afford to lose big would be well advised to wait it out.

IMG_0634There are other reasons Virginians should be wary of over-investment in natural gas infrastructure, both generating plants and pipelines. The need to fill pipelines will put pressure on the state to welcome fracking companies, both in the Marcellus shale in the western part of the state, and in the Taylorsville Basin in the east. Until 2010, Dominion itself owned gas drilling leases, and according to the Center for Media and Democracy, “Dominion is a member of several special interest groups that push for expanded drilling rights and limited or no regulation of fracking.”

With pollution of air and water a serious concern, and given the state’s tradition of lax regulation on industry, some localities are already looking for ways to exclude drilling companies from their borders. If we are going to have this fight, it shouldn’t be because one powerful corporation made a bad bet.

Finally, of course, there is the climate cost of natural gas. As we congratulate ourselves for leaving coal in the rear-view mirror, we need to recall that we have a long way to go to reach the carbon-free grid, and stalling out at the halfway point isn’t grounds for celebration.

Natural gas has a role to play in the transition period before wind, solar, and other carbon-free sources take over permanently, and it will remain useful as a back-up source when wind and solar aren’t producing power. But a wise energy policy today focuses on developing those renewable sources as fast as possible, reducing demand through investments in energy efficiency, and using natural gas as a backstop rather than as a primary source of power.

This approach reduces risk to the national economy if shale gas production declines, and it reduces risk to ratepayers stuck paying whatever the price of natural gas may be when demand outstrips supply.

Dominion Resources is an investor-owned corporation. As such, it is entitled to place risky bets in the hopes of making a killing for its shareholders. What it is not entitled to do is to shift the risk of losing the bet onto its captive ratepayers in Virginia.

With the odds so stacked against consumers, Virginia should refuse to play.

Thanks go to Richard Ball, PhD., Energy Chair of the Virginia Sierra Club, for his research and analysis of shale gas supplies.