Dear Virginia Elected Officials and Regulators,
We ask for your assistance in protecting the interests of the ratepayers, local governments and landowners of Virginia. Typically, utility projects in Virginia are reviewed by the State Corporation Commission with frequent input by the Attorney General’s Office of Consumer Protection. These state agencies serve as advocates for the ratepayer’s interest as well as setting a fair return to utility shareholders. With the approval of the Atlantic Coast Pipeline (ACP) determined by the Federal Energy Regulatory Commission (FERC) no one is speaking for the overall well-being of Virginia ratepayers and citizens. We respectfully ask that someone fulfill that role. Below are several issues which affect ratepayers and citizens of Virginia.
1. FERC sets rates for transporting natural gas primarily using incremental costs. This means that transporting gas in new pipelines is more expensive than using existing pipelines which are partially paid for. The transport fee becomes part of the fuel cost which is automatically passed on to utility customers. The ACP will cause Virginia ratepayers to pay more than necessary for their electricity compared to using existing pipelines. Who will speak for Virginia ratepayers?
2. A new pipeline spur is being completed to serve the Brunswick and eventually the Greensville power plants that Dominion is developing in Southside Virginia. This $490 million new spur from the Transco mainline can access supply from both the Marcellus and the Texas/Gulf Coast production regions to assure a reliable supply of natural gas. Dominion states in their application to FERC that they plan to serve these two plants with the ACP when it is completed. They are planning to spend over $3 billion to construct nearly 300 miles of new pipeline to provide a third source of supply to these same power plants. Dominion will make the investment in the Atlantic pipeline, but it is the ratepayers who will pay for it. Who will speak for Virginia ratepayers?
3. When Dominion backs out of their 20-year Long Term Supply contract with Transco, which was the basis for FERC approving the project, to switch to the ACP – the new Transco pipeline built for Dominion will lose 96% of its business. If customer contracts serve as the basis for FERC approval, but are easily cast aside once a pipeline is built, where is the proof that the ACP is truly needed? Will the ratepayers have to pay for the more expensive ACP and the abandoned new Transco spur? Who will speak for Virginia ratepayers?
4. If the ACP is built, Dominion will want to attach the power plants proposed for 2022 and 2030 to the pipeline they own. If the new plants are approved, this either limits the locations in which those plants can be developed or requires longer than necessary spurs to be built for these new plants. The ratepayers will shoulder this added expense. Who will speak for Virginia ratepayers?
5. Dominion admits that the ACP is a wholesale pipeline intended to serve only electric and gas utilities. If the same or greater amount of natural gas flowed from the Marcellus through existing pipelines in to the Columbia Gas and Transco pipelines which already crisscross Virginia – not only will the power plants be served, but so will residential, commercial and industrial development throughout the state. Who will speak for the economic interests of the citizens of Virginia?
6. If the new natural gas supply is moved in existing pipelines it can flow through the Columbia Gas pipeline which feeds the AGL (Virginia Natural Gas) line which already supplies the Chesapeake -Norfolk area. Developers of the Atlantic Coast Pipeline propose a 77 mile 20” pipeline on new right-of-way to connect the Chesapeake area to the Atlantic Pipeline just after it enters North Carolina. Using the additional capacity in the Columbia Gas system avoids the costs and impacts from this new construction. The great savings from tapping the Marcellus gas that Dominion proclaims, if it does exist, is equally available when using existing pipelines, but at a lower cost and with far lower impacts. Who will speak for the economic and environmental interests of the citizens of Virginia?
7. Construction of a new pipeline on or near a parcel reduces the long term value of the property, limits future uses of the land and makes it unavailable for sale while construction is occurring. The turmoil of construction also reduces tourism and recreational visitors which provide valuable income to many of our rural communities. Reductions in land values will greatly reduce tax receipts to counties along the pipeline route plus the added expenses of dealing with the boom/bust of construction activities. A recent study of only four of the thirteen counties affected by construction of the ACP in Virginia showed that the economic losses related to the Atlantic pipeline in just these four counties will equal more than the $5 billion that the developers will invest in the entire pipeline. Who will speak for the local governments and citizens of Virginia?
8. An amount of natural gas equal or greater than the capacity of the ACP can be supplied to North Carolina using existing pipelines, without the need to the construct the ACP through Virginia. Our land and communities need not be damaged to serve the energy needs of another state. Who will speak for Virginia?
9. The ACP will damage the unique habitats, the precious streams and ancient aquifers that are the source of the pure water that flows through our communities and into the James and Potomac River watersheds. We are the stewards of this land. The bounty of our ancestors’ labor was passed from generation to generation on farms that existed before our nation was formed. Who will speak for Virginia’s heritage?
We believe that you, our representatives in Virginia, are uniquely qualified to be the voice for Virginia. To speak for the people’s many interests. We need not be forced choose between having an adequate supply of natural gas and preserving Virginia. Using existing pipelines saves money, promotes future prosperity and preserves our communities, our water and our land. We need your help to make it so. Please be involved in the FERC proceeding to represent the interests of Virginians by promoting the use of existing pipelines rather than building new pipelines in Virginia.
Your Constituents and Virginia Citizens