Virginia Regulatory Town Hall
Department of Energy
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8/18/18  5:32 pm
Commenter: Mike Sandler, Carbon Share

Community Choice Energy, climate dividends, no more fossil fuels

August 18, 2018

To:  The Virginia Department of Mines, Minerals and Energy

Re: The 2018 Virginia Energy Plan

Thank you for considering these comments.  I attended and spoke at the listening session at George Mason University  on August 16, 2018.  I am originally from Northern California and have lived in Virginia for the past 5 years.  In California, I co-founded a group called the Center for Climate Protection ( I was a City Planning Commissioner in my town for 2 years, and I was the Program Manager for a regional agency whose focus was reducing greenhouse gas emissions in Sonoma County, California.  I currently work in the field of renewable energy and sustainability, and am part of a new organization called Virginia Clean Energy.  I encourage you to include the following aspects into the 2018 Virginia Energy Plan:

  • Support for Community Choice Energy (also called Community Choice Aggregation)
  • Consider including a price on carbon in statewide energy planning efforts and return the revenues collected to all Virginians as a “climate dividend”
  • Encourage support for additional electric vehicles and charging infrastructure
  • Deny future fossil fuel projects
  • Additional points from environmental stakeholders

Support for Community Choice Energy

Community Choice Aggregation (CCA), also known as Community Choice Energy, allows cities, counties, or groups of them (municipalities) to aggregate the electrical energy load of residential, commercial, and industrial retail customers within their boundaries, and select the delivered energy mix for their community by allowing localities to access the wholesale energy market directly.[1]  This establishes competition for energy supply.  CCA programs allow municipalities to define their power mix, and 50% renewable and 100% renewable have been implemented in other states. The existing provider is responsible for billing, transmission and distribution, and the regulatory status of the existing provider is unchanged.

CCA legislation has been implemented in California, Massachusetts, Ohio, Illinois, Rhode Island, and New Jersey. CCA legislation is under study in Utah, Minnesota, and Delaware. CCA programs are opt-out where ratepayers in the community have a simple mechanism to seek exemption from the CCA. Some CCAs exempt industrial and large commercial customers from the aggregated community energy mix.  Virginia code already provides for aggregation.  I ask you to include support for CCA, and direction to the State Corporations Commission (SCC) to conduct studies and support for cities and counties that wish to pursue CCA.

Consider including a price on carbon in statewide energy planning efforts

Other states such as California have shown leadership on climate change by creating a price on carbon. These efforts are often opposed by the fossil fuel industry, which is how you know that it is good for the planet and future generations.  I ask you to study the possible implementation of a price on carbon in Virginia.  If Virginia joins the Regional Greenhouse Gas Initiative (RGGI), this would be a step in the right direction, but it is still far short of what California, and even China, are doing.  If Virginia wants to be a leader in this space, it should look at an economywide carbon price.  Additionally, I encourage Virginia to adopt the Cap & Dividend model for carbon pricing, where revenues are collected from upstream fossil fuel companies (those that drill or extract the coal or oil from the ground) by auctioning a limted number of permits that decrease each year (the “cap”), and returning the revenues revenues back to people as a climate dividends (similar to Alaska’s Permanent Fund that returns oil revenues to the people of Alaska).  I urge DMME staff to read Peter Barnes’ books, including Who Owns the Sky?, Capitalism 3.0, and With Liberty and Dividends for All for more information.[2]  I also have a website on the topic at

Encourage support for additional electric vehicles and charging infrastructure

Virginia can do more to encourage consumers to purchase electric vehicles, and to facilitate the development of electric vehicle charging infrastructure.  As the Federal tax credit begins to expire for early adopter manufacturers such as Tesla and GM, Virginia can step in with additional incentives to keep this market moving forward.  The air quality benefits are likely in the millions of dollars, plus reduced incidences of childhood asthma and health impacts in disadvantaged urban communities. 

Local governments could benefit from simplification of the permit process for installation of charging stations.  Virginia can encourage private sector installations, especially at hotels, movie theaters and shopping centers where drivers will spend more than an hour at a time.

Deny future fossil fuel projects

Fossil fuels used to be the major electricity generating resource in the developed world.  But the climate change impacts made it untenable to continue this trajectory.  The Paris Climate Accords put the world on record as stating the fossil fuels would not continue to be the major source of energy in the world going forward.  Regardless of campaign contributions to politicians, fossil fuels must be phased out for humanity to have a plausible future on this planet.  Additionally, and less importantly than our species’ survival, the economic impacts of a climate-damaged planet are becoming apparent.  Although the media is slow to recognize this, the West is going up in flames, the South is inundated by hurricanes and flooding, New Orleans is sinking, sea levels are rising, and the agricultural economy is going to have a hard time adapting (in other words, get ready for food shortages).  With each summer that passes, the increasing temperatures and humidity here in the Mid-Atlantic make it impossible to go outside and have a nice day at the park.  We stay huddled inside in our air conditioned rooms.  We cannot pretend we don’t know this.  We cannot plug our ears while our children look to us for leadership.  We cannot question science and pray that God will bail us out of this mess that we have created.  We have to take responsibility and fix the problem.  It is not difficult.  We have to support renewable energy projects, a smarter grid that can handle it, energy storage to allow the sunlight to power our economy at night, and we have to eliminate funding and approvals for additional fossil fuel energy projects.  An “all-of-the-above” energy plan that includes continued use or even more fossil fuels is outdated and does not help solve this problem.  Additional points include:

  • Adopt a policy of opposition to new fossil fuel infrastructure, as it is not needed to support future energy needs and will further contribute to climate disruption.
  • Because methane, like carbon dioxide, is a hazardous pollutant and dangerous greenhouse gas and the primary component of fracked gas, Virginia should make a more concerted effort to limit methane emissions.
  • Until Virginia’s standards on hydraulic fracturing for gas are adequately strengthened to protect the public standards, a moratorium on fracking should be put in place.
  • Pipelines proposed through protected or hazardous regions where land and water quality standards are unable to be met should be rejected and Virginia’s laws should give no special rights to enter or take private lands without the owner's consent.

Additional points from environmental stakeholders

Finally, I would like to state my support for the many excellent comments from other environmental stakeholders such as

  • Implement a mandatory renewable portfolio standard that carves out specific targets for wind and solar and 30% renewable energy by 2030 for all utilities
  • Eliminate arbitrary restrictions on net metering to allow for residential solar growth - no system cap size or standby charges
  • Mandate that consumer-focused Green Power programs run by utilities purchase renewable solar, wind or hydro energy produced in the state, not just RECs out of state which doesn’t bill capacity
  • Strengthening and modernizing the Virginia grid for a 100% clean energy future by 2030. 

Thank you.



Mike Sandler

Springfield, VA





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