Dominion’s Wires Are Its Only Natural Monopoly; Let Engineering Firms Build Low-Cost Solar, Wind

By Will Driscoll

Many firms have more experience than Dominion Energy in building solar and wind farms and connecting them to the grid.  And these other firms provide the lowest prices for solar and wind, as seen in Tucson’s and Austin’s recent solar costs below 3 cents per kilowatt-hour, and Lazard’s estimated 3 to 6 cents per kilowatt-hour for onshore wind.

Dominion’s relative strength is in maintaining the electrical transmission and distribution grid.  There is no sense in building a second grid, so Dominion has a natural monopoly there.

State legislation can promote low-cost renewable electricity by starting from this foundation. Let big, reliable firms that can build low-cost solar and wind for Virginia do so, competing with each other to provide the lowest cost. Let Dominion run the grid.  And to make sure we get the lowest prices for solar and wind, don’t allow Dominion to bid, so that it can’t rig the bid requirements in its favor. (A Dominion subsidiary could still bid on solar and wind farms in other electric utility territories.)

Dominion has become better qualified to run the grid, as it has recently adopted a renewables-friendly grid planning and management software called Plexos.  With this sophisticated tool, Dominion should no longer have the difficulties its executive Robert Thomas expressed in 2016 when he said a high-solar option “could create reliability issues.” Now, Dominion can use Plexos to plan a renewables-integrated grid.  And each day Dominion can take day-ahead weather forecasts and run them through Plexos to develop a round-the-clock “unit commitment” plan for the following day. With this new capability, Dominion can join the ranks of well-managed high-renewables utilities in Iowa, South Dakota, California and Europe.  Adding cost-effective storage to the grid, from the likes of Virginia’s AES, will make running the grid even easier, by helping to balance solar generation and end-use demand.

State legislators can do their part to bring low renewable electricity prices to Virginia, like those seen in Tucson and Austin.  The key is to pass laws that focus Dominion on running the grid, and that leave solar and wind farm development to firms specializing in EPC (engineering, procurement and construction) that are willing to bid in an unfettered competition.

Recover High-GWP Refrigerants, Favor Low-GWP Refrigerants to Limit Climate Damage

By Will Driscoll

To limit climate damage from refrigerants with a high global warming potential:

  • States may require leak testing and leak repair of equipment using refrigerants, as California now requires for large equipment (see section 5 below).
  • States may also have authority to require that when equipment using refrigerant will no longer be used, that its refrigerant be recovered and either destroyed or reclaimed (recycled). A financial incentive or a refundable deposit could boost voluntary compliance.
  • Environmental groups may encourage people to choose equipment with low-GWP (global warming potential) refrigerants, such as R-1234, which has a GWP of 4 to 6 (see table below). This equipment includes vehicles, heat pumps, air conditioners, refrigerators, freezers, and dehumidifiers.

The following sections first describe various refrigerants, and then review refrigerant management policy at the global, U.S., and E.U. levels, and in California.

  1. Selected Refrigerants: Phased Out, In Use, and Under Consideration
Refrigerant Global Warming Potential (GWP)*,** Status
CFCs   Phased out under the Montreal Protocol
HCFCs   Being phased out
HFCs   Widely used
HFC: R507 3300 US: Were to be phased out via EPA’s 2015 and 2016 rules.*** A three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit struck down the 2015 rule.  That ruling has been appealed to the full en banc panel of the same appeals court.
HFC: R404A 3260
HFC: R410A 1725 US: Was to be partially phased out via EPA’s 2015 and 2016 rules;*** see above.
HFC: R407 1525
HFC: (R)134a 1430 US: Was to be phased out in light-duty vehicles via EPA’s 2015 rule, which is now in the courts—see above.
HFC: 152a (R152a)   124  
HFO 1234 (R-1234)       4 Now used in some vehicle air conditioners
“Natural refrigerants”: CO2 (R744) and ammonia (NH3) CO2: 1 Daimler and Volkswagen are evaluating CO2 for vehicle air conditioners.****

Note: The “R” refrigerants are a blend of two different HFC compounds, except for R744 (CO2).





  1. Global Policy

The Montreal Protocol’s Kigali Amendment of 2016, which requires a global phasedown of HFCs, will enter into force on January 1, 2019:  “Under the amendment, developed countries will reduce HFC consumption beginning in 2019”:  The amendment apparently does not address HFC recovery and destruction:

  1. U.S. Policy

EPA issued two HFC phase-out regulations in 2015 and 2016.****  The “Final Rule Revising the Section 608 Refrigerant Management Regulations” made “changes to the existing requirements under Section 608 [including] … 1) Extends the requirements of the Refrigerant Management Program to cover substitute refrigerants, such as HFCs”:

A three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit ruled on August 8, 2017 that the U.S. EPA does not have authority under Clean Air Act Section 612 to regulate HFCs.  Refrigerant manufacturers and the NRDC have appealed for a rehearing of the case by a panel of all the appeals court judges of the DC Circuit (an “en banc” panel).

Prior EPA regulations require recovery of ozone-depleting refrigerants when existing equipment is removed, with the refrigerants sent out for destruction or reclamation (recycling):

The amounts recovered each year from 2000-2016 are shown here:

EPA-certified refrigerant reclaimers are shown on this list:

  1. E.U. Policy

The E.U. adopted a regulation in 2014 to phase out HFCs, and encourage refrigerant recovery and destruction at the end of a unit’s service life. (EU regulation 517/2014).  “Member States shall encourage the development of producer responsibility schemes for the recovery of fluorinated greenhouse gases and their recycling, reclamation or destruction.”

  1. California Policy

The California Air Resources Board (CARB) Refrigerant Management Program requires commercial and industrial facilities with a refrigeration system using more than 50 pounds of a high-GWP refrigerant (including HFCs) to register with CARB, to test for leaks, and if a leak is detected, to repair, retrofit or retire the equipment.  The program apparently does not address refrigerant recovery and destruction.