We, the undersigned, represent organizations within the Virginia Grassroots Coalition. One of our top priorities is moving Virginia toward a clean energy economy and drastically reducing statewide greenhouse gas emissions.
We appreciate the opportunity to comment on the development of the 2018 Virginia Energy Plan. We understand that the Plan will focus on five stakeholder tracks: solar and wind, offshore wind, energy efficiency, electric vehicles, and energy storage. While critically important, these tracks do not address comprehensive grid transformation and offer at best piecemeal solutions to some of our most pressing energy and environmental issues.
I. The Energy Plan Should Call for a Comprehensive Grid Transformation Study
To successfully compete in the 21st century economy, Virginia must transition from the status quo and modernize its grid and its utility laws. Effective grid transformation should:
Other state governments including those of New York, Minnesota, Rhode Island, Massachusetts, Michigan, Nevada and Ohio are aggressively pursuing grid transformation.
In Virginia, however, grid modernization is largely left in the hands of the for-profit utility monopolies. Thus, hundreds of millions of rate-payer dollars will continue to pay for projects that benefit utility shareholders rather than the public. As clear from Dominion’s first filing in 2018 with the State Corporation Commission, Dominion intends to use money it previously overcharged consumers for capital projects that “harden” the existing grid, rather than for projects that provide consumers’ choice, produce economic efficiencies, reduce the carbon footprint, or in any way create a truly modern grid.
A. Independent Grid Transformation Study with Recommendations
We strongly urge that the 2018 Virginia Energy Plan include a recommendation for the Governor to initiate a comprehensive Grid Transformation Study. The study, along with its recommendations, should be completed before multi-millions are spent on grid modernization measures, as defined by the for-profit utilities, which are at best ineffective and at worst counterproductive. Thus, the study should be final by the fall of 2019 – at which time, a final report with recommendations must be provided to the Governor, the General Assembly, relevant regulatory agencies and the public. The study should include a strong stakeholder process with participation by consumer and environmental groups, local governments, the electric utility industry, relevant state representatives, experts and the general public.
The study should be led by an organization that is independent from the utilities. The organization must have technical expertise in grid transformation technologies and should be knowledgeable of different regulatory and incentive-based approaches as well as other states’ grid modernization efforts. Finally, it must be capable of evaluating the potential environmental and economic benefits of different grid transformation options and tools.
B. Grid Transformation Study Components
The grid transformation study must be far broader than the limited grid modernization definition in SB966. At minimum, it should address:
II. Barriers to Solar Energy Must be Eliminated
The recent energy legislation, “Grid Transformation and Security Act” (SB966), has a number of significant flaws. It failed to set a sufficiently high target for solar. It also failed to remove a variety of barriers to third-party solar generation. These barriers negatively impact the solar industry, local government solar, as well as residential and business solar. The 2018 Energy Plan should provide a robust review of these barriers and recommend legislative remedies and other reforms. Remedies and reforms are especially critical to open the market for investment in distributed solar. Some of the most critical reforms are listed below.
Thank you for your consideration of our comments and recommendations. We look forward to your response.
Sharon Shutler, We of Action (WofA)
Luisa Boyarski, Together We Will Northern Virginia
Stair Calhoun, Network NOVA
Cindy Cunningham, Virginia Progressive Legislative Alert Network (VAPLAN)
Robbin Warner, Postcards4VA
Chris LeMenestrel, Virginia Democracy Forward
Marianne Burke, Indivisible Virginia 11
Anne Moriarty, Hunter Mill Indivisible
Molly Bakal, Indivisible Northern Virginia
Cindy Speas, Lewinsville Faith In Action
Heidi Zollo, Herndon-Reston Indivisible
Matt Sowd, Herndon Huddle
Juliet Hiznay, Kristin Haldeman, Indivisible Arlington
Kathleen Mullen, Indivisible Below the Beltway
Alice Robie, Zero Carbon Virginia
cc: NOVA Senators and House of Delegates Representatives
over this text and enter your comments here. You are limited to approximately 3000 words.