Conceptual layout of Longview II and III

LONGVIEW POWER II, LLC, and
LONGVIEW RENEWABLE POWER, LLC

Joint Application of Longview Power II, LLC and
Longview Renewable Power, LLC to Authorize the
Construction and Operation of Two Wholesale Electric
Generating Facilities and One High-Voltage
Electric Transmission Line in Monongalia County.

NOTICE OF FILING AND HEARING

On September 6,2019, Longview Power II, LLC and Longview Renewable Power, LLC (Applicants) filed a joint application pursuant to W. Va. Code $8 24-2-1 1c and 24-2-1 1a to authorize the construction and operation of two wholesale electric generating facilities and one high-voltage electric transmission line in Monongalia County, West Virginia, including all interconnection and ancillary facilities.

The Facilities proposed by the Applicants include a 1,200 MW natural gas-fired electric combined cycle gas turbine generating facility and associated high-voltage transmission line (CCGT Facility) and a 70 MW utility scale solar facility to be located in West Virginia and Pennsylvania (Solar Facility). Longview Power 11, LLC will construct and operate the CCGT Facility, and Longview Renewable Power, LLC will construct and own the Solar Facility. When combined with the existing 710 MW coal-fired facility (Coal Facility) owned by Longview Power, LLC, an affiliate of the Applicants, the CCGT and Solar Facilities will produce nearly 2,000 MW of generating capacity in north-central West Virginia and south-west Pennsylvania.

The CCGT Facility will deploy two gas turbines with a high efficiency, secondary cycle steam turbine system and will include a 500 kV transmission line extending approximately three-quarters of a mile north from the facility to the North Longview Switchyard in Pennsylvania. The Solar Facility will be a 70 MW (direct current) utility scale solar facility with 20 MW of panels in West Virginia and 50 MW of panels in Pennsylvania as presently configured. The solar array fields in West Virginia will have a 34.5 kV collection system that transmits power to the point of interconnection, where the voltage will be stepped up to 500 kV. The CCGT and Solar Facilities will be constructed adjacent to the site of the Coal Facility on reclaimed mine land owned by Longview Power, LLC and its affiliates.

The Applicants estimate that the total construction costs of the CCGT and Solar Facilities (excluding financing charges and fees in 2018 dollars) will be approximately $956 million.

The Applicants assert that they are not public utilities providing service to the public and that the construction and operation of the Facilities will not impact West Virginia ratepayers. Rates charged for electricity sold by the Facilities will be subject to regulation by the Federal Energy Regulatory Commission (FERC) pursuant to Section 205 of the Federal Power Act. The Applicants intend to file a market-based rate schedule with FERC that will allow sales from the Facilities to be at negotiated rates.

The Applicants will be responsible for the construction and operation of the Facilities and for the sale of electricity generated by them. The Applicants will operate the Facilities as exempt wholesale generators as defined under Section 32(a) of the Public Utility Holding Company Act of 1935.

The Applicants will enter into interconnection and operating agreements with PJM, a regional transmission organization, which will govern the interconnections of the CCGT and Solar Facilities with West Perm Power and PJM at the North Longview Switchyard in Pennsylvania. The Applicants, or the purchasers of the electricity generated by the Facilities, will enter into transmission service agreements with West Penn Power to govern the transmission of
the electricity across West Penn Power’s facilities. Such transmission of electricity will be subject to the terms of PJM’s Open Access Transmission Tariff on file with the FERC. The interconnections with West Penn Power will not compete with other utilities and will be for the sole purpose of transmitting electricity generated at the Facilities onto the grid for the wholesale market.

The Applicants assert that because they are not public utilities under West Virginia law, considerations relevant to the issuance of a certificate of convenience and necessity under W. Va. Code 5924-2-1 1 and 24-2-1 1a such as the need for the Facilities and the information required by Tariff Rule 42, should not be addressed by the Commission.

Therefore, the Applicants request a waiver of the Public Service Commission’s filing requirements to provide certain information including the utility service rendered, proposed rates, project construction costs, project financing and estimates of operating revenues and expenses, and the information required by
Tariff Rule 42 (e.g., statements of net income, operating revenues, depreciation, West Virginia jurisdictional rate base, plant in service and capital structure).

And, because the Applicants will not be regulated by the Commission as public utilities following completion of the Facilities, they request a waiver of the Commission’s filing and reporting requirements, metering requirements, customer relations, inspections and tests, standards and quality of service, promotional practices, consumer reimbursement program, uniform accounting requirements, and the requirement to allow Commission inspection of books, papers, reports and statements that are specific to regulated public utilities whose practices affect captive ratepayers.

Further information concerning the Application is available in the case file at the Commission offices at 201 Brooks Street, Charleston, West Virginia, or on the Commission’s website, www.psc.state.wv.us, under Case No. 19-0890-E-CS-CN.

The Commission set a procedural schedule, including a hearing on the Application. The hearing will begin at 9:30 a.m. on January 30, 2020 and will continue into January 31, 2020, if necessary, in the Howard M. Cunningham Hearing Room at the Commission’s offices at 201 Brooks Street, Charleston, West Virginia.

Anyone desiring to file public comments in support or in opposition to the Application may do so by mailing to the address below. The Commission will receive written public comments until the beginning of the hearing.

Anyone desiring to petition to intervene in this case must file a written request to intervene within thirty (30) days of the date of publication of this notice, unless otherwise modified by Commission order. Anyone requesting a hearing in this case must also file such
request in writing within the same 30-day period and state why a hearing is necessary. Failure to timely protest or intervene can affect your right to protest or participate in future proceedings in this case. If no substantial protests or requests for hearing are received within said 30-day period, the Commission may waive formal hearing and grant the Application based on the evidence submitted with said Application and its review thereof. All protests or requests to intervene shall briefly state the reason(s) for the protest or intervention. Requests to intervene must comply with the Commission’s rules on intervention set forth in the Commission’s Rules of Practice and Procedure. The Commission’s rules are available via a link on the Commission’s Home Page to the website of the West Virginia Secretary of State.

All written comments and protests, requests to intervene, and requests for hearing must state the case name and number and be addressed to Connie Graley, Executive Secretary, Post Office Box 812, Charleston, West Virginia 25323.

Public comments may also be filed online by clicking the “Formal Case” link at:
http://www.psc.state.wv.us/scripts/onlinecomments/default.cfm

LONGVIEW POWER 11, LLC, and
LONGVIEW RENEWABLE POWER, LLC

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Recommendation of Mon Valley Clean Air Coalition (MVCAC):

File a Letter of Protest with the WV Public Service Commission

Ask that the Certificate of Site Approval be denied unless Longview installs carbon capture to reduce emissions of greenhouse gases. Be sure to include the reference to Case # 19-0890.

Mail letters to: Connie Graley, Executive Secretary, West Virginia Public Service Commission, 201 Brooks Street, Charleston, WV 25301.

Or file comments on-line Protesting Case Number 19-0890 at: http://www.psc.state.wv.us/scripts/onlinecomments/default.cfm

Attend the Public Hearing. The PSC will hold a public hearing on Monday, Jan. 6, 2020 at 5:30 PM at the Monongalia County Courthouse, 243 High Street, Morgantown. You can present your comments in person at that time.

Public Service Commission in Morgantown on Monday 1/6/20

Prepared by the West Virginia Chapter of Sierra Club, PO Box 4142, Morgantown, WV 26504

What is Longview proposing?

Longview Power proposes to construct a 1200-MW gas-fired power plant in Monongalia County on 54 acres adjacent to their existing coal-fired plant near Fort Martin. They also propose adding a 20-MW solar farm to cover 127 acres on lands to the north of that site. Gas would be supplied by a 20-inch diameter pipeline from the TransCanada line in Pennsylvania(1). New roads, water lines and transmission lines would also be needed.

What else does Longview want?

Longview is also requesting a Payment In Lieu Of Taxes (PILOT) Agreement with Monongalia County(2). The proposed 30-year PILOT has not yet been approved, but would reduce Longview’s property taxes by over $200 million(3).

Doesn’t Longview already have a PILOT Agreement?

Longview has a PILOT Agreement for the existing coal-fired plant (Longvew I). This 30-year PILOT provided $108 million to Monongalia County. The coal-fired Longview I plant is rated at 695 MW, so the proposed 1200-MW plant (Longview II) is almost twice as large. Longview proposes to pay only $58,222, 513 under the proposed new PILOT for Longview II.

What are the environmental impacts?

While the air pollution emissions include 282 tons nitrogen oxides, 552 tons VOCs, and 175 tons fine particulates, and others pollutants each year, the emissions of over 3 million tons of greenhouse gases will be an important impact that is currently unregulated1. Gas-fired power plants often claim that greenhouse gas emissions are reduced, however this ignores all the upstream emissions of methane associated with well drilling, pipelines, compressors, etc.

The Intergovermental Panel on Climate Change recommends that, to prevent global temperatures from rising more than 2 C, there must be a rapid reduction in greenhouse gas emissions. Numerous scenarios are possible, but all involve rapid reductions in emissions of fossil fuel carbon, at least 50 % reduction by 2030, and almost all fossil fuel emissions must end by 2050.

How can this be achieved?

Technologies called Carbon Capture and Sequestration (CCS) can capture the carbon dioxide from the exhaust stream, concentrate it, and pump it deep into the Earth, where it will remain indefinitely. Such technologies are already being used in some areas to enhance oil production. But the cost of retrofitting a plant is high, and the energy demand reduces the efficiency of power plants.

Use of biomass fuels is one alternative that recycles carbon dioxide in the air through photosynthesis, so no net emissions of carbon dioxide occurs. But if biomass fuels are used in power plants with CCS, the net effect is to remove carbon dioxide from the air. Currently, this is costly, but would become competitive if a carbon tax or cap and trade program were implemented.

Will the Longview II plant be economically competitive?

That depends on whether the electricity is needed. Under current market conditions, electricity from gas-fired power plants is cheaper than from coal. However, demand for electricity is not growing, so new generation facilities will compete directly with existing power plants. Longview’s economic analyses assume that electricity markets will remain stable, and ignores the need to address climate change. If greenhouse gas emissions are restricted, power plants may need CCS to remain compliant. Alternatively, as renewables become cheaper, even gas-fired plants may not be competitive.

References:

1. PSC. Joint Application of Longview Power…. (Siting Certificate). Case # 19-0890-E-CS-CN. Available at: http://www.psc.state.wv.us)
2. Longview. 2019. Non-Binding Term Sheet – Longview Expansion Project. Sept. 11, 2019. Submitted to Monongalia County Commission.
3. Boettner, T. 2019. PILOT Agreements Cost State Millions in Tax Revenue: An In-Depth Look at Longview Power Plant. WV Center on Budget and Policy. Available at: https://wvpolicy.org/pilot-agreements-cost-state-millions-in-tax-revenue-an-in-depth-look-at-longview-power-plant/

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What you can do:

File a Letter of Protest with the WV Public Service Commission. Ask that the Certificate of Site Approval be denied unless Longview installs carbon capture to reduce emissions of greenhouse gases. Be sure to include the reference to Case # 19-0890.

Mail letters to: Connie Graley, Executive Secretary, West Virginia Public Service Commission, 201 Brooks Street, Charleston, WV 25301.

Or file comments on-line Protesting Case Number 19-0890 at: http://www.psc.state.wv.us/scripts/onlinecomments/default.cfm

Attend the Public Hearing. The PSC will hold a public hearing on Monday, Jan. 6, 2020 at 5:30 PM at the Monongalia County Courthouse, 243 High Street, Morgantown. You can present your comments in person at that time.