Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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9/16/22  2:55 pm
Commenter: Susan Bonney

Virginia must sharply cut its GHG emissions

I respect William Penniman and his significant experience, knowledge an analysis. I echo his comments and suggestions for the Virginia Energy Plan. More than ever, Virginia must act to sharply cut its GHG emissions with a long-term plan to achieve a zero-carbon electric supply by 2050 and a 50% reduction in carbon emissions by no later than 2035.  As the electric sector’s carbon emissions are being reduced, Virginia needs to dramatically improve energy efficiency in buildings, appliances, heating and cooling and industrial equipment and convert its transportation system to electric vehicles which produce no emissions in their operations.  Virginia must also act to reduce GHG emissions from other parts of the energy sector.

  1. Cutting CO2 Emissions in the Electric System

It is very possible to reduce CO2 emissions in the electric system to net-zero.  The zero-carbon technology exists and it is getting better and cheaper.  Political leadership and commitments are the major missing ingredients.  The 2022 Energy Plan needs to supply the zero-GHG vision and the climate-imperatives upon which that vision is based.

  1. Continuing participation in the Regional Greenhouse Gas Initiative (RGGI) is vital since RGGI is a proven method of reducing CO2 emissions and provides badly needed funds to mitigate climate risks and harms.  It has been shown to reduce CO2 emissions, lower utility bills and improve the health of residents.  In Virginia it is also a source of badly needed funds to mitigate climate impacts and energy bills for residents.
  2. Solar, wind and hydropower are known renewable energy technologies to produce electricity.  The costs of these sources has dropped substantially over the past decade and they are now cheaper than traditional sources.  Their value is also greater because they can supply electricity without climate and other pollutants.  It is true that they are intermittent, but diversity of facility locations (e.g., onshore, offshore, and distributed throughout homes and businesses around the state and technologies across a large electric grid, combined with storage technologies and demand-side management (DSM), can get the system to net carbon neutrality over time. These technologies continue to improve and their prices continue to fall.
  3. All barriers to privately owned solar and wind generation and to storage (including deterrents in utility rate schemes) should be eliminated.  User-owned, collectively-owned and third-party-owned generation that provides zero-carbon electric or thermal energy benefit the public; they should be opened to market innovations and encouraged.  Net metering should be retained and expanded for residential solar.  Generation by communities and third-parties should be left to private contracts without the burdens of utility regulation.  Among other possibilities, developers of condominiums, apartment buildings, or commercial complexes should be able to provide (by sale or by lease agreement) solar energy to tenants whether or not the tenants are individually metered by utilities, without submitting to SCC regulation. 
  4. Storage technologies are improving rapidly, and pumped storage is a well-established technology.  Batteries can be implemented at the utility scale or on-site in homes, electric vehicles (EVs) and businesses ready to serve the utility’s needs, or in the event of outages, the immediate needs of individuals or businesses.  Microgrids can further supplement the system and provide local security.  Investments in batteries should be permitted whether by utilites or by private owners or third parties.
  5. Virginia has operating nuclear plants, which should continue to operate – so long as it can be done safely.  Nuclear waste remains an unresolved issue making nuclear an unacceptable long-term answer.
  6. Forest-based biomass is NOT carbon neutral.  The theoretical view that future trees will recapture the carbon from combustion is not supported by the realities.  The climate crisis is now and our energy-related emissions must be cut by 90-100% by 2050.  Existing forests with mature trees do capture CO2 and provide an important climate-mitigation function.  But they are large and well-established.  There is no carbon neutrality in making carbon emissions worse for decades by burning wood now based on unenforced “promise” that seeds planted today may grow enough over 50-200 years to match what mature trees to now.  CO2 will increase in the meanwhile.  Nor is there any legal enforcement of claims that only scraps and waste wood is being burned.  Moreover, wood burning is less efficient from a Btu standpoint and its emissions of CO2 and N20 per MWH is inordinately high.
  7. Energy efficiency and DSM can help to achieve a net-zero electric system, by reducing the total electricity that needs to be generated and by temporarily curtailing uses during peak or other stress periods.  Energy efficiency can lower electric bills even if electric generation and storage costs were to rise.
  8. A rational, public-oriented plan for grid modernization and transformation could knit the evolving distributed generation and demand-side resources into a well-balanced, reliable system, which takes full advantage of competitive markets’ ability to provide better services at lower costs.  In contrast, leaving grid “modernization” in the hands of the traditional monopolies will stifle innovation, allow them to defend old investments and supply strategies, and allow them to promote demand growth and payments to affiliated businesses, like natural gas pipelines and supply companies. 


  1. Energy Efficiency Improvements Are Critical.

Energy efficiency should be the first line of defense against energy waste and GHG emissions.  Efficiency improvements can dramatically reduce the amount of electricity and fossil fuel that is needed to heat, cool and operate our homes and businesses.  Reducing energy consumption is critical to reducing GHG emissions. The Electric Power Research Institute found that Virginia utilities had achieved only 2% of the energy efficiency improvements available to them.

The problems with achieving greater energy efficiency are several, and solutions are needed, including:

Virginia’s statewide building codes are inadequate.  They have long failed even to keep up with national codes (the International Energy Conservation Code), when, by law, they should be “at least as stringent” as the latest IECC.  This includes incorporation of standards that go beyond the IECC.  The results include higher GHG emissions. higher costs to building occupants for decades after a dwelling is built, and greater economic insecurity for low- and moderate-income residents.  It will cost buyers (and the public) far more to retrofit dwellings (particularly in the case of building envelopes) than it would have for the builder to include a more efficient designs in the first place and the higher construction costs would be paid with mortgages in the case of new home purchases. 

Many of the state’s efficiency programs are run by utility companies that want to increase their sales and to justify their past and future investments, not reduce usage.  Creating an independent “efficiency utility” funded through utility rates could help to better align efficiency incentives and investments.

All business and residents should be incentivized to reduce their energy consumption, particularly their combustion of fossil fuels.   

Net-zero GHG buildings (combining efficiency and clean energy) should be required or, at least, strongly incentivized (e.g., rewarded with tax benefits and favorable publicity). 

Energy efficiency performance. energy costs and GHG emissions should be collected and publicized for new and existing buildings.  Building owners and operators should be required to demonstrate energy cost savings and GHG reductions to owners and tenants. 

The state should strengthen its own efficiency policies by (1) setting clear goals and plans for annually reducing energy usage by each state agencies; (2) making leaders within each department personally responsible for achieving the energy-reductions; (3) tracking and publicizing energy usage and progress; and (4) rewarding employees who make the most meaningful contributions to achieving the goals.  Generally announcing energy reduction goals (e.g., 10% over 5 years) is not going to be effective without clear assignments of responsibilities and consequences for meeting or not meeting the goals.  Energy efficiency performance contracting should be encouraged and facilitated.

Local governments need help and incentives.  It is easy for local officials to take a short-term view that avoids investments that would benefit taxpayers over time.  State funding assistance should be tied to reduced energy usage or shifting entirely to zero-carbon energy.  There should be a large revolving fund to provide financial assistance to local governments to help them cover their up-front costs to save energy, which would then be repaid and re-loaned to others.


  1. Electric Vehicles.

Electric vehicles have no point-of-use pollution emissions, have much less need for maintenance, and lower per-mile operating costs.  Operating and maintenance costs are far lower than for gasoline or diesel vehicles.  Automobile owners can save $1,000 or more annually with EVs.  

EVs a major benefit for consumers and the environment, particularly as electric systems shift to zero-carbon energy production.  GHG reductions are far lower even considering today’s upstream electricity generation.

The central problems to getting to much greater EV usage are (a) lack of buyer awareness of benefits, (b) fears that the low availability of charging facilities will interfere with convenient travel particularly over longer trips, and (c) upfront costs.  Virginia should address these issues with at least the following measures:

    1. Building codes should be revised to require that Level 2 EV chargers or, at least, electric conduits and panel space be installed in garages, carports and parking lots of all new single-family or town house developments.  Electric infrastructure to add Level 2 or 3 EV charging for residents is also needed for multifamily dwellings.  80% of charging is done at home due to greater convenience and lower costs.  Retrofits are so costly as to deter installation of chargers if infrastructure is not installed at the outset.
    2. Building codes for hotels and motels should require installation of a mix of Level 2 and Level 3 chargers covering a minimum percentage of parking spaces to reflect growing needs of travelers.
    3. Building codes for other commercial buildings and government buildings should require that a certain number of spaces provide Level 2 or Level 3 charging capabilities.  
    4. Schools should be incentivized to replace diesel buses with electric buses.  The opportunity for charging overnight and limited driving distances will make school buses good candidates for electric operations.  The benefits will be enhanced by reducing children’s exposure to diesel exhaust.  Government electric vehicle fleets would also be a good investment to reduce O&M costs and GHGs.
    5. Tax or other incentives should encourage EV purchases.


  1. Building Electrification

Dwellings and other buildings need to shift to electric technology, including heat-pump technology which is vastly more efficient and reduces GHGs compared to combustion-based technology.  Manufacturing and commercial buildings likewise need to electrify to the maximum extent possible, as rapidly as possible.

  1. Methane emissions.

Methane is a dangerous GHG with a potency over 20 years of 87 times that of CO2.  Since we need to reduce climate changes as rapidly as possible, it is not acceptable to continue to emit methane from fossil fuel production (natural gas, petroleum or coal) or from pipelines, local distribution facilities or processing operations – all of which contribute significantly to methane emissions.

The Energy Plan should call for prompt regulatory measures to reduce methane emissions from the fossil-fuel supply chain.  DEQ and DMME have the authority to require reductions in methane emissions from these fossil fuel operations and should use that authority to require emissions reductions.  Much of the reductions come from poor maintenance, carelessness or conscious decisions to vent methane.  Those can be regulated with the result of significantly reducing methane emissions.  Regulatory proceedings should be initiated as soon as possible.


In sum, Virginia’s new Energy Plan should prioritize reducing GHG emissions and other pollution from energy use and production using every tool available, including zero-GHG energy supplies and energy efficiency.  Business as usual or moving backward would amount to digging ourselves and future generations into an ever-deeper and more destructive hole.  It is vital we stop digging by stopping emissions of GHGs as rapidly as possible, while rapidly taking measures to reduce harms that are already occurring and growing.

CommentID: 128714