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8/24/18  4:39 pm
Commenter: Lisa Jacobson, Business Council for Sustainable Energy

BCSE Comments on 2018 Virginia Energy Plan

August 24, 2018

2018 Virginia Energy Plan Comments
Sent via Electronic Mail and Submitted at: 

Mr. Al Christopher
Director, Energy Division
Virginia Department of Mines, Minerals and Energy (DMME)
1100 Bank Street
Richmond, VA 23219

Re:         Virginia’s 2018 Energy Plan

Dear Mr. Christopher:

On behalf of the Business Council for Sustainable Energy, thank you for the opportunity to provide comments on the 2018 Virginia Energy Plan. The Business Council for Sustainable Energy, founded in 1992, is a trade association representing the energy efficiency, natural gas and renewable energy sectors. Its members include utilities, independent power providers, energy service companies, manufacturers, and the major sector trade organizations. The Council advocates for energy and environmental policies that promote markets for clean, efficient and sustainable energy products and services. The Council has several members that operate and contribute to the clean energy economy in Virginia. These include Johnson Controls, Schneider Electric, Covanta Energy, the American Wind Energy Association, the Solar Energy Industries Association, the US Green Building Council, the Energy Storage Association, and others. As a broad coalition, not all members endorse or take a position on the issues discussed in these comments.

The Council commends Virginia as a leader in advancing the clean energy economy. The Virginia Energy Plan process provides the Commonwealth an opportunity to continue showing leadership in this area, and to find new ways to advance energy and environmental policy through the development and deployment of clean energy and energy efficiency technologies. These technologies bring significant economic opportunity, including over 3 million jobs nation-wide, including over 80,000 in Virginia.[1] With the right policies, Virginia can continue to be a leader in this space.

The Council is also pleased that Virginia is moving forward with a regulation to establish a carbon trading scheme, with the goal of joining the Regional Greenhouse Gas Initiative. This is an important step toward meaningful carbon reduction and is a critical complimentary policy to a robust Energy Plan. The Council looks forward to continued engagement with the Department of Environmental Quality and others on this topic.

Renewable Energy Development

Renewable energy has seen a steady increase in deployment over the last ten years. According to the 2018 Sustainable Energy in America Factbook, the US got 18% of its electricity generation from renewables in 2017, putting it on par with the nation’s nuclear fleet. Virginia has improved in recent years, but still only generates about 5% of its electricity from renewable resources. Much of this comes from wind and solar, but also from biomass, hydropower, and other renewable technologies.

The Council recommends:

  • Consistent with the legislative intent of Senate Bill 966, helping to facilitate the development of greater than 5,000 MW of wind and solar energy capacity soon as possible in order to take advantage of the Investment Tax Credit and Production Tax Credits
  • Facilitating greater private sector participation in the energy sector, including expanding third-party power purchase agreements and third-party ownership and operation of community solar facilities. This will make Virginia a more attractive place to do business for corporations and medium-sized businesses wishing to power their operations with renewable resources. Corporate procurement of clean energy has soared, with a record 2.8 GW contracted for in 2017
  • Recognizing the carbon reduction and forestry management benefits of biomass

Electric Vehicles and Alternative Fuel Vehicles

Due in part to dramatic decreases in battery pack prices, sales of electric vehicles (EVs) increased in 2017. However, electric vehicles are not the only options for alternatives to internal combustion engines. Fuel cell vehicles and natural gas vehicles provide additional ways to decrease the carbon footprint of the transportation sector, which now emits more carbon than the power sector both nation-wide and in Virginia. Advances in sustainable transportation are critical to effective and meaningful carbon reduction.

The Council recommends:

  • ­Implementing policies that prioritize deployment of all types of alternative fuel vehicles, including fuel cell and natural gas vehicles

Energy Efficiency

Energy efficiency is a key component of the clean energy economy. Not only does energy efficiency provide over 75,000 jobs in Virginia, the industry helps increase the energy productivity of the economy, meaning Virginia can grow its economy without seeing a corresponding growth in energy consumption. The Council’s recommendations are aimed at helping Virginia strengthen its energy efficiency efforts to work toward achieving the statewide 10 percent reduction goal and potentially expanding the 15 percent “lead-by-example” reduction goal.

The Council recommends:

  • Adopting the most recent building codes and standards
  • Promoting the use of energy savings performance contracts (ESPCs)
  • Developing tools to track success, including analyzing programs not currently included in tracking systems, such as industrial programs

Energy Storage

Energy storage is another key tool in achieving cost savings and deployment of other clean energy technologies. Storage also offers ancillary benefits such as resilience and greenhouse gas reduction. The Council encourages DMME to continue working towards understanding and quantifying the benefits of energy storage so it can be used to its full potential.

The Council recommends:

  • Including a modeling exercise looking at various levels of system-wide storage deployment to determine what deployment scenario has net benefits for customers in cost-benefit analyses
  • Considering energy storage in Integrated Resource Plans
  • Updating interconnection rules to include energy storage 
  • Considering energy storage in rate design & utility programs


The Council appreciates the opportunity to submit comments to the DMME as it develops the 2018 Virginia Energy Plan. The Energy Plan will provide a roadmap for the Commonwealth to continue its leadership in advancing the clean energy economy and the Council’s recommendations are aimed at helping Virginia achieve its energy and environmental goals. In addition to the comments and recommendations here, the Council looks forward to continuing the dialogue and providing input on these and other clean energy issues in the weeks and months to come.



Lisa Jacobson
President, Business Council for Sustainable Energy






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