William D. Stewart, Jr.: Public Comment on Dominion Energy Virginia's Integrated Resource Plan (PUR-2020-00035: Virginia Clean Economy Act)

Virginia’s State Corporation Commission (SCC) invited comment from the public on the Integrated Resource Plan (IRP) filed by Dominion Energy Virginia on May 1, 2020. 

William D. Stewart, Jr., ScB and AB in Electrical Engineering and Member CO2 Coalition, of Fredericksburg, Virginia, submitted the following comment.

The Plan is a fantasy based on old science, apocalyptic religious hysteria, magical thinking about a system that is known not to work, while ignoring systems that do work.  It must be rejected, the science updated, and rewritten.

  1. Carbon Dioxide, CO2, is not pollution; it is plant food,
  2. Global Warming/Climate Change, the Scientific Method,
  3. The Virginia Clean Economy Act (VCEA),
  4. Renewables and storage,
  5. The correct plan

1. CARBON DIOXIDE, CO2, is not pollution

In the present discussions, we are considering it a man-made product of the combustion of carbon and hydrocarbons with oxygen.  CO2 combines with H2O plus energy from sunlight via photosynthesis by plants to form plant food, without which life on earth would not exist.  Impurities in coal and petroleum fuels do cause pollution, which has to be mitigated.  Natural gas, is non-polluting, making only plant food.  The increase of man-made CO2 since the industrial revolution has caused the re-greening of the earth, with vast areas returned to vegetation, having been destroyed by CO2 starvation.  More CO2, combined with slight warming, whether man-made or natural, has been completely beneficial, such that the “social cost of carbon” negative, i.e., the more the better, and will be for the foreseeable future.

The “Greenhouse Effect”:  The earth is a ball of rock, hurtling through the cold of outer space.  The earth has a radius of about 4000 miles.  The atmosphere above it is made of about 80% nitrogen, 20% oxygen, 1% water vapor and trace gases including carbon dioxide, at 0.04%.  It is held in by the force of gravity, is densest at the surface, and quickly peters out with altitude, so that it is less than 1% of the radius of the earth.  This thin blanket protects us from the frigid cold of night; the average temperature without its greenhouse effect would be -18C or 0F.  Both CO2 and H2O vapor absorb infra-red radiation, and keep heat in this blanket, but the dispute is how much, and is the subject of ongoing bitter debate. 

The earth was formed about 4.5 billion years ago, and the atmosphere is believed to have been almost 100% pure CO2, with that gradually changing over the eons to what it is at present.  Single celled living things appeared about 4.0 billion years ago, and things stayed primitive until about 500 million years ago, when over a burst of fewer than ten million years, multi-cellular plants appeared that we would recognize today.  Similarly, a few million years after that, in another period of fewer than ten million years, multi-cellular animals appeared, again, many that we would recognize today.  Next is a graph of CO2 and temperature from that time onward to the present that is widely agreed to:

There is no correlation between global temperature and CO2.  And, of course, all changes have only natural causes, having occurred long before humans burned fossil fuels.  Temperature has varied between 10C to 25C.  Absolute zero is -273.15C (-459.67F), zero degrees Kelvin.  The band is about 283K to 298K, an average of 290.5K.  The temperature has varied only about 2.5% above and below the average—over 600 million years, a very stable atmosphere.  Of course, temperatures have fluctuated on far shorter time frames; lately we have seen fluctuations over forty-year periods.  Actual temperatures were taken by thermometers in England starting in 1659 show the overall temperature has risen by all of one Celsius degree, while fluctuating around that line.  There simply is no case for runaway catastrophic heating.


Fears were brought about by a 22 page report issued in 1979, “Carbon Dioxide and Climate: A Scientific Assessment,” the “Charney Report,” named after its author, Jule Charney.  He said that infra-red heating of CO2 had a positive feedback effect, causing the main greenhouse gas, H2O, to heat much more than it would alone.  This proposal, forty years old, has been challenged by other researchers who have identified natural causes which explain temperature rises since then.  Dozens of models based on Charney’s theory have all produced outcomes far above actual observations.  Below is a recent graph from John Christy, the eminent PhD climate scientist.  The predicted temperatures in the models are about 2.5 times what has actually occurred.  So, what does it mean that 102 models based on it are way off, 2.5 times way off?  And what about the 97% of scientists (and 100% of activists and politicians) who believe that “the science is settled” on the question of Global Warming/Climate Change, and that increasing amounts of man-made atmospheric CO2 will bring about the apocalypse? 

Aristotle (384 BC-322 BC) was an advocate of experiment and observation, and those led him to propose that a body was naturally at rest, and to remain in motion it had to be continually acted on by a force.  In the real world around us, that seems correct, and Aristotelian physics was “settled science” for about 2000 years, not by 97% but by 100% of scientists (called “natural philosophers” in those days).  Along came Isaac Newton who published in 1687 his Principia Mathematica, upsetting the Aristotelian applecart, with his three Laws of Motion,

and the invention of calculus to describe them.  Aristotelians at Oxford fought a rearguard action to keep out the radical ideas of the “denier” Newton, but Newton won, as he was right and all 100% of Aristotelians were wrong.  With Newton, motion could be described accurately, and the Industrial Revolution became into being.

Newton was right: and working invention after working invention over more than two centuries seemed to prove him right, as the devices using his laws of motion all worked.  But that isn’t the way that scientific knowledge progresses.  You don’t prove something to be correct; it is just the latest good idea.  Knowledge advances by showing the old explanation to be wrong and by proposing a new, alternative explanation that does work.  This is the Scientific Method, and the twentieth century philosopher of science, Karl Popper, expounded that in his book (out of print), Conjectures and Refutations, The Growth of Scientific Knowledge, 1963,  of which the money chapter, Chapter 1, is entitled, unsurprisingly, “Science: Conjectures and Refutations,” which is the text of a lecture he had given in 1953 in Cambridge, UK. Bottom line is that if a theory makes predictions that turn out to be incorrect, the theory is wrong.  In other words, the old saying that “something is the exception that proves the rule” is simply false in science; it is an exception that disproves the rule and says that it is false.

All agree that climate has always been changing for 4.5 billion year.  In 1979, when the world was still fretting over the prospect of global cooling and an impending new ice age, the Charney Report stated that over not too long a time period runaway heating would cause catastrophic changes to the planet;  rising sea levels would inundate the land, ferocious storms, hurricanes, tornadoes and the like, heat that would kill people by the millions, causing species extinction on a wide scale.  However, as you can see with your own eyes in the graph above, it simply isn’t happening.  The temperatures aren’t going up, and the catastrophes aren’t happening, no matter what the doomsayers continue to say, year after year, in ever more strident terms.


3. The Virginia Clean Economy Act, VCEA

Since the subject case is intimately entwined with the new Virginia Clean Economy Act, VCEA, I submitted a FOIA request with the Office of the Governor, requesting any and all scientific and engineering reports pursuant to the enactment of the subject legislation.  In response I was sent the public version of the VEPCO 2019 Update to 2018 Integrated Resource Plan, with the comment that there was a second document, but it was being withheld pursuant to Virginia Code 2.2-3705.7(2) and they stated “We are not required to give any of that information since the document is protected pursuant to Virginia Code 2.2-3705.7(2).”  It no doubt is “Working papers and correspondence of the Office of the Governor… [and] the General Assembly….”  

The government enacted sweeping legislation that will cause profound changes to the electricity generation, transmission and distribution system within the Commonwealth at the cost of many tens of billions of dollars to ratepayers, and taxpayers.  It will, following European experience, cause huge environmental damage, double electricity prices, and wreak devastating economic damage to society.  And the Legislature and Governor didn’t even bother to get any scientific or engineering studies made prior to enactment.  Unbelievable. 


4. Renewables and storage, environmental and economic disasters

The plan envisions both PV solar and offshore wind, and lots of it.  Both make no sense.  It takes 10,000 acres of land, destroying either farmland or forest,  land that is destroyed for wildlife habitat, to make a solar production facility of 1000 megawatts.  You build a fossil or nuclear plant on more like 20 acres.  Dominion is permitted for another nuclear plant at North Anna, and it will take 22 acres for a 1500 megawatt facility. 

The solar farm makes electricity only when the sun is far enough above the horizon to put enough energy onto the solar panels, in Virginia only about 40% of the time on average, year-round.  40% of the time it is either raining or cloudy, so the maximum percentage of time producing electricity is about 25%, the “capacity factor.”  Because of technical and operational problems, the actual performance in Virginia is 15%-20%, and they are calling it 19%.  This is probably optimistic, because you need to account for the wasted gas when the sun is shining.  And what are the losses going from low voltage DC panels, wired in series and parallel, inverted and transformed?  The true capacity factor is probably only between 10 and 15%.   This is versus over 92% for nuclear base load plants running flat out 24/7, or between 50-60% for natural gas peaking plants.  And you must have a gas plant of the same “label plate wattage” as the solar facility, running 24/7.  Dominion acknowledges this in the Plan, noting that after they destroy their system that works, they will have to import fossil power from out of state.  Basically, renewables don’t work, they cause massive environmental damage, don’t save CO2, and produce millions of cubic yards of highly toxic waste with no place to go when they are decommissioned; they are Potemkin power plants with fossil or nuclear plants really making the electricity.  The Big Lie is that they are now cheaper than nuclear or fossil; maybe with the sun is brightly shining in the summer; but without backups running, you don’t have electricity.

Do the math: 10,000 acres per 1000 MW solar generator, and at a .19 capacity factor, that is 8760 hours per year x .19 = 1,664,000 MWh per annum, or 166.4 MWh per acre per year.  Assuming Dominion buys and installs two of the new load following Small Modular [nuclear] Reactors (each puts out 720 MW), and we put two of them in the 22 acres inside the existing North Anna campus already licensed by the NRC for that megawattage, at, say, .75 capacity factor.  That gives us 1420 MW x 8760 hours x .75/22 acres, equals 424,000 MWh per acre per year.  Nuclear delivers 2500 times the energy per unit of land as solar. 

Offshore wind is stupid.  The capacity factor at 25% is only a bit better than that of solar, the capital costs are enormous, and it makes very expensive unreliable and intermittent electricity.  And maintenance costs are far higher than predicted,  as electricity and salt water don’t mix.  And the idea of building a massive field of wind turbines offshore of the world’s largest naval base, and one of the world’s largest commercial shipping ports in a hurricane prone area, is foolish. A major accident will occur, sooner rather than later, guaranteed.

Backup power.  The plan envisions batteries and pumped hydro, neither of which can supply electricity over any period more than a few minutes or hours, even with new technology that will be developed.  Dominion has more experience than anyone in pumped hydro, and the capacity factor for the proposed installation is 11%.  Absurd.  It works for peak shaving with a reliable supply of cheap energy from coal or nuclear; it does not work when the supply is intermittent—no water gets pumped up when the sun isn’t shining.  Batteries.  2700 MW are proposed.  In the winter, when electricity demand is very high, we go days on end with no sun; batteries won’t work past the first day, and the only thing that then works is the fossil backup.  Batteries and pumped hydro are a fantasy of the innumerate. 

Many major environmentalists now realize that “renewables” do not work, the most notable of whom is Michael Shellenberger whose new book, “Apocalypse Never, Why Environmental Alarmism Hurts Us All” is a must.  He says that we need to go nuclear to avoid CO2.


5. The correct plan, environmentally and economically: natural gas and nuclear.

Renewables make no sense other than to please activists who are not trained in the sciences, and those who feast off renewables: manufacturers, contractors. Installers, financiers, Big Green, and the politicians (usually uneducated in the sciences) who get votes and money.  Society at large is the victim: a waste of vast amounts of capital, and destructive high electricity prices.  Low electricity prices are good for everybody, especially for the poor and marginalized.  And if you want to be “woke,” social justice is advanced by cheap electricity.

Scrap the fantasies, stick with what would be correct were there no climate alarmism.  Look only at economics for now, as long as any given facility isn’t an emitter of “real” pollution.

Our descendants will run out of fossil fuels long before there is any “climate crisis.”   A valuable short (20 page) paper to read is “The Positive Impact of Human CO2 Emissions on the Survival of Life on Earth,” by PhD Ecologist, Patrick Moore, a co-founder of Greenpeace and chair of CO2 Coalition.  CO2 has been slowly moving out of the carbon cycle and down into shells of marine animals, and into calcium carbonate rock when they die.  In the last 150 million years, CO2 dropped from about 2000 parts per million, ppm, to the present 400 ppm.  At one point 18,000 years ago, it dropped to 180 ppm, just 30 ppm above the 150 ppm when plant life starts to be extinguished.   The plants are no doubt thanking us every day for putting CO2 back in the air!

In the meantime, we do need to start ramping up the use of nuclear power, with new technologies side by side with the old, which do work well.  To move a new technology into widespread use requires retraining the workforce, and entirely new production facilities.  We are still in the process of rolling out electricity around the world, about 135 years after Thomas Edison built the Pearl Street generating station and started to light the world.


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