City of Alexandria Comments Regarding Governor Northam's Virginia Energy Plan

The City of Alexandria appreciates the opportunity to provide comments to the Virginia Department of Mines, Minerals, and Energy for consideration in the development of Governor Northam’s Virginia Energy Plan.

The City of Alexandria has a long history of prioritizing and promoting energy efficiency actions and the use of clean energy resources to Alexandria residents, businesses, and within the City’s operations. Such actions include energy efficiency improvements in residential and commercial buildings, and transportation systems; and a dramatic increase in solar photovoltaic systems within the Alexandria community. [1] Notwithstanding, ongoing efficiency improvements of the electric grid and an increase in clean energy generation resources have resulted a nearly 22% decrease in Alexandria’s greenhouse gas emissions between 2005 and 2015 despite an increase in population and a growing economy. [2]  

Still, much work remains necessary, and significant strides in improvement are possible over the coming 10 years. Governor Northam’s 2018 Virginia Energy Plan can be a timely catalyst to further economic growth, job growth, savings to consumers, and further reductions in carbon emissions throughout Virginia for the benefit of all. As such, Alexandria requests that the Virginia Energy Plan prioritize:

• Accelerating implementation of all feasible energy efficiency and emission reduction measures for buildings and infrastructure, and transportation systems;
• Transitioning Virginia’s electricity grid to 100 percent clean energy to mitigate Alexandria’s and Virginia’s contribution to climate change;
• Optimizing the economic, environmental, and social performance of new and existing buildings.

We offer the following specific recommendations for consideration.

1. Accelerate Energy Efficiency for Buildings and Infrastructure, and Transportation Systems

• Emphasizing energy efficiency as the ‘first fuel’ to address electricity generation needs in the Commonwealth of Virginia, and to reduce overall electricity and natural gas energy-use goals;
• Commission a new energy efficiency potential study to assess the scale, availability, and cost of energy efficiency as an economic, resiliency, and generation resource in the Commonwealth of Virginia;
• Include non-wire alternatives, including maximum energy efficiency opportunities into any transmission infrastructure planning process.
• Prioritize Grid Transformation and Security Act funding on energy efficiency for residential and commercial buildings to increase grid resilience, reliability, and security;
• The Virginia Department of Mines, Minerals, and Energy (DMME), State Corporation Commission (SCC), Virginia Department of Environmental Quality (DEQ), utility companies, and relevant stakeholders should emphasize partnerships with Virginia local governments to identify, program, and delivery energy efficiency programs to Virginia communities;
• Provide financial incentive to local governments, state agencies, and private owners of conventional roadway, street, and outdoor lighting to convert to dark-skies compliant light-emitting diode (LED) technologies;
• Significant expansion of weatherization and low-income energy efficiency programs, including increasing financial support of affordable housing organizations energy efficiency opportunities;  
• Offer state-wide rebates for energy efficient building systems equipment, including lighting, HVAC, hot water, and related systems for all customer classes with primary support for residential customers;
• Prioritize and support legislation to authorize localities to establish mandatory benchmarking and disclosure programs
• Invest any proceeds from the Regional Greenhouse Gas Initiative (RGGI) sale or trade of carbon allowances to be prioritized to further accelerate and scale investment in residential and commercial energy efficiency programs;
• Implement electricity and natural gas rate design, including time or use (TOU) rates, which incentivize individual and organizational energy conservation activities that are consistent with choices utilities make to minimize system costs;
• Incentivize energy efficient data center design and construction as economic development opportunity;
• Encourage and expand opportunities for state agencies, local governments, institutions, commercial buildings, and residential buildings to participate in demand response programs through PJM Interconnection;
• Continue funding of the VirginiaSAVES program through state-backed funding sources;
• Direct the Virginia Department of Mines, Minerals, and Energy (DMME), State Corporation Commission (SCC), Virginia Department of Environmental Quality (DEQ), utility companies, and relevant stakeholders to pursue strategic partnerships with Virginia local governments to identify electric vehicle charging infrastructure needs, coordinate deployment of public electric vehicle charging infrastructure, and incentivize transition of personal-occupancy vehicles to electric vehicle technologies;
• Significant expansion of electric vehicle charging infrastructure
• Prioritize funding received through the Virginia Volkswagon Mitigation Trust to be invested in public bus transportation system and school district bus system electrification transitions;
• Implement electricity rate design, including time or use (TOU) rates, which incentivize individual and organizational use of electric vehicle transportation technologies that are consistent with choices utilities make to minimize system costs and take advantage of solar and wind electricity generation;
• Incentivize transportation-based energy storage system technologies to enable resilient grid management approaches.

1. Transition Virginia’s Electricity Grid to 100 Percent Clean Energy

• Establish aggressive and mandatory requirements for renewables in the state’s overall energy mix, including implementation of a mandatory Virginia Renewable Portfolio Standard (RPS) with a focus on in-state solar renewable energy credit (SREC) market;
• Require utility integrated resource plans (IRP) to require energy efficiency and renewable energy resources, with primary focus on solar and wind electricity generation resources, as primary generation resources;
• Expansion of net-metering options for local governments to include aggregate or virtual net metering, including allowing local government entities to install solar facilities of up to 5 MW on government-owned property and use the electricity for schools or other government-owned buildings located on nearby property, even if not contiguous;
• Expansion of net-metering options for residential customers to include community solar and solar leasing, including allowing all customers to attribute output from a single solar array to multiple meters on the same or adjacent property of the same customer;
• Allowing the owner of a multi-family residential building to install a solar facility on the building or surrounding property and sell the electricity to tenants;
• Lifting the 1% cap on the total amount of solar that can be net metered in a utility territory;
• Clarifying that third-party financing using power purchase agreements (PPAs) is legal statewide for all customer classes;
• Removing the restriction on customers installing a net-metered solar facility larger than required to meet their previous 12 months’ demand;
• Raising the size cap for net metered non-residential solar facilities from 1 MW to 2 MW
• Remove standby charges on residential facilities sized between 10-20 kW;
• Prioritize the investment into grid modernization in the Commonwealth to further support distributed generation from renewable energy to emphasize customer benefits and grid resilience;
• Support development of distributed generation and net-metering rate structures that provide fair retail value of solar and renewable energy electricity generation for all surplus electricity generated and added to the grid, including value of emissions reductions, resiliency, and related benefits;
• Incentivize battery storage systems tied to solar by providing a state-level tax credit for purchase and use of such systems;
• Direct the Virginia Department of Mines, Minerals, and Energy (DMME), State Corporation Commission (SCC), Virginia Department of Environmental Quality (DEQ), utility companies, and relevant stakeholders to participate in PJM Interconnection (PJM) proceedings regarding valuation and pricing of regional transmission operator (RTO)

1. Optimize Performance of New and Existing Buildings

• Provide increased outreach, implementation assistance, start-up financial resources to local governments to implement Commercial Property Assessed Clean Energy (C-PACE) programs;

• Increase stringency of energy efficiency building codes; including adoption of most recent International Energy Conservation Code (IECC) and International Green Construction Code (IGCC);
• Policy support to incentivize net-zero construction for new residential and commercial buildings;
• Establish state-wide mandatory green building standards for private commercial and new construction to emphasize energy-use reduction;

Respectfully,

Bill Eger, Energy Manager

City of Alexandria, Virginia

[1] https://www.alexandriava.gov/uploadedFiles/tes/eco-city/EAP-Achievements-Since%202009-11-27-17.pdf

[2] https://www.alexandriava.gov/uploadedFiles/tes/eco-city/Alexandria%20GHG%20Factsheet_Apr2018%20-%20FINAL.pdf