Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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9/16/22  5:26 pm
Commenter: Chesapeake Climate Action Network

Energy priorities for the Commonwealth


Chesapeake Climate Action Network has worked for 20 years to advance climate justice in the Commonwealth. In the past several years, CCAN has helped to pass necessary legislation to facilitate an energy transition to clean, renewable sources and away from carbon-based fuels that warm the planet and sicken its people. 



One such policy is our participation in the Regional Greenhouse Gas Initiative, which the legislature directed us to participate in during the 2020 General Assembly session. RGGI is key not only to ramping down emissions and keeping us tethered to our clean energy goals, but also to funding programs that increase Virginia’s resilience to flooding and extreme weather. To date, RGGI has produced over $400 million of benefits to residents. With catastrophic flooding from Southwest Virginia to Northern Virginia and Hampton Roads, we cannot afford to not pro-actively invest in resilience. It is critical that the Energy Plan reflect our RGGI participation and consider thoughtfully how the allocation of funding can be informed by the Coastal Resilience Master Plan and other state planning processes.


Clean Energy Goals

The 2022 Virginia Energy Plan must prioritize meeting clean energy goals. This means outlining a path by which our utilities and electric cooperatives can achieve the targets laid out by the Clean Economy Act, including a robust analysis of transmission needs. The plan should prioritize energy efficiency and consider how regulatory authorities can expand upon existing energy efficiency targets, which are the cheapest and quickest way to allow us to reduce emissions and meet clean energy goals. Any cost analysis should appropriately evaluate the volatility and expense of the global fossil fuel market, which is currently driving energy bill increases.


Distributed Generation

The Plan should provide some guidance for how the state can maximize its distributed generation potential while bringing down costs, particularly for rooftop solar. This should include recommendations or research as to an appropriate fee for the shared solar program in Dominion territory, which is currently so high as to prevent enrollment from classes of customers who are not exempt from the fee. 



The Plan should outline a public education plan to link residents to the benefits the Inflation Reduction Act (IRA) provides for solar, home electrification, and electric vehicles. It should provide guidance for agencies which may make use of IRA funding, and how state lawmakers may appropriate it to serve our clean energy goals. This should include research and analysis of where the $106 million for EV chargers coming from the Infrastructure Investment and Jobs Act (IIJA) should be distributed, with a keen eye for equity of access. The state should explore how federal funds can be appropriated to communities which have historically been the site of fossil fuel infrastructure and generation, particularly where existing state programs for brownfield development already exist.


Ratepayer Protections

A system of endless Rate Adjustment Clauses (“riders”) is not working for Virginians, who have the 8th highest energy bills in the nation – the vast majority of which is associated with fossil fuel facilities, many of them chronically underperforming. The Plan should outline how the state can better empower the SCC to review base rates and explore alternatives to rider-forward cost recovery.


CommentID: 128780