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During the IRP meeting on August 23rd, the environmental justice slide of the presentation noted that the IRP would include "A generic evaluation of potential environmental impacts relative to different types of power generation facilities." Does this mean that the IRP will just discuss what the environmental impacts of these power generation facilities are as general types, or will it discuss the impacts of the specific amounts of each generation type it is including in its plans? I think that doing the latter is important to allow for the environmental impacts of different plans to be able to ensure that discussion of impacts takes the cumulative impacts of multiple facilities into account It is important to understand the environmental implications of certain plans leaning more heavily on certain generation types than others.
Yes, the IRP will only discuss potential environmental impacts of general types of power generation facilities. Without knowing a specific location, an environmental impact analysis can only occur in the abstract. For example, the extent of visual impacts on local farmland, open space easements, churches, and local residences is affected by local topography, trees, and vegetation, among other things. As another example, the extent (if any) of impacts to historic properties, air quality, wildlife, wetlands and other waters, and parks also depends on the nature of the local area.
In addition to a project’s location, information about the project itself makes a difference in an environmental justice review. Generation projects come in all shapes and sizes that are driven by numerous variables, including land use and availability, geography, topography, presence of sensitive environmental resources, distance to existing electric infrastructure, costs of interconnection, local views on the placement of new generating resources, stakeholder input, availability of off-takers, permitting, and financing, among other things. The lack of project specific information is a key limitation in evaluating the potential environmental consequences of generic generating resources.
We agree that a fulsome analysis of environmental impacts is important. That is precisely why the Company primarily addresses EJ in a project-specific context (e.g., filing more specific information about environmental impacts in appropriate CPCN proceedings) and why we feel the IRP is not an ideal proceeding to focus on addressing the goals of the Virginia Environmental Justice Act. As stated in the Company’s 2023 IRP proceeding – affordability, reliability, and the increasingly clean nature of our power generation portfolio is the focus of the IRP, and by pursuing all three of those focus areas simultaneously we believe we are, generally, working towards environmental justice across the Commonwealth.