I am writing today on behalf of Sigora Solar LLC to provide comments on the 2018 Virginia Energy Plan. Sigora Solar is a Virginia-based company providing residential solar, commercial solar and energy efficiency services.  Sigora is headquartered in Charlottesville, Virginia, with offices in Waynesboro, Richmond, and Manassas and we currently employ approximately 150 direct and indirect employees. We have installed solar on more than 1500 Virginia homes and businesses, serving thousands of Virginians.  Sigora is a member of MDV SEIA, Advanced Energy Economy (AEE) and Virginia Energy Efficiency Council (VAEEC), and as such, many of our positions and views have already been addressed by those organizations’ Virginia Energy Plan comments.

Sigora echoes all of the recommendations made by VAEEC, with the exception of the amended recommendation below.    

Carbon Trading Rule and DMME

Sigora suggests increasing the five percent set aside from the emissions allowances generated by the Virginia Carbon Rule to be increased to fifty percent and that those funds shall be allocated to DMME to invest in a variety of clean energy programs, including, but not limited to residential solar, commercial solar, energy efficiency projects and electric vehicle deployment.   

Sigora echoes the comments provided by AEE in regards to energy efficiency, demand side management and distributed energy resources with particular emphasis on the below item.

Exploration and Consideration of Advanced Metering Infrastructure Capabilities

The utilities must lay out a clear business plan to fully realize the customer benefits of advanced metering infrastructure.  This shall include, but not be limited to, demand response programs, usage of residential and commercial solar inverters to provide frequency and voltage regulation, the utilization of energy efficiency programs as an energy resource etc.        

Wholesale distributed Generation Market Pilot Program

Sigora would like to endorse Suntribe’s recommendation on the establishment of a wholesale distributed generation market pilot program for both Dominion and Appalachian Power Company.  The pilot program would explore and create the path to market for non-owner-occupied building owners, as well as serve as a complement for the 5,500MW of utility-scale renewables slated for procurement by SB 966. According to Craig Lewis, the executive director of Clean Coalition, “About 75% of U.S. commercial property is not owner-occupied and/or is split-metered and/or has more siting potential than load."[1]

Net metering

Additional notes, we urge the Legislature, Administration and the State Corporation Commission to preclude electric utilities from transitioning away from net metering until the following occurs.  An electric utility will not transition default residential service schedules to a time-variant rate structure until completing deployment of advanced metering infrastructure, collecting a minimum of two years of hourly interval data from all customers, and completing a rate pilot of the proposed new time-variant default rate.  An electric utility may offer a time-variant rate to residential customers on a voluntary basis.  To ensure transparency the utility company shall develop a web portal and smartphone application to allow customers to access all of their personal interval data, electricity consumption and any other relevant data point.  Additionally, all interval data and relevant data points associated with distributed generation, including but not limited to location and nameplate capacity, shall be shared and housed in real time at DMME.  

Low-to-Moderate Income Solar Pilot

The Administration shall allocate funds for the creation of a low-to-moderate income residential solar program.  The program would provide an incentive for the deployment of solar panels in the amount of $5500 per house (or an agreed upon and justified performance-based incentive).  Eligibility for the program would be limited to those households at or below 80% of Virginia’s area median income or the state median income, whichever is greater.  The incentive shall be transferable to third parties who pass a comprehensive consumer protection evaluation.  In order to receive the incentive, households must have an energy efficiency upgrade performed with evaluated, measured and verified savings equal to or greater than 12%.  The program shall be a pilot and funded at a rate of 10 million dollars annually for five years. The program shall be housed and managed at DMME.    

[1] https://www.utilitydive.com/news/rip-fits-as-us-feed-in-tariffs-fade-adopting-elements-could-spur-solar-gr/422727/