Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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8/24/18  1:31 pm
Commenter: Nikki Rovner, The Nature Conservancy

The Nature Conservancy's Comments on the Virginia Energy Plan

We are grateful for the opportunity to submit comments on the 2018 Virginia Energy Plan.  These comments pertain primarily to mitigation, solar siting in Southwest Virginia, and energy efficiency.

Before turning to the substantive issues addressed in this letter, we first wish to convey a concern regarding the process of developing the Energy Plan.  The Conservancy appreciates the many avenues for stakeholder engagement that the Commonwealth has provided over the last several months.  We also note that most public engagement processes include an opportunity to comment on a draft document.  Recognizing that the Code of Virginia calls for the Energy Plan to be updated by October 1, we hope there will be an opportunity to respond to a draft plan before it is finalized.

We commend the Northam Administration for the emphasis on clean energy that is evident in the stakeholder tracks that have been established for the plan development process (solar and wind, energy efficiency, electric vehicles and advanced transportation, storage and offshore wind).  We are glad that Governor Northam shares our understanding that an increasing proportion of our energy must come from clean sources if we are to have any hope of staving off the worst effects of climate change or addressing the other environmental impacts of energy extraction, generation and transmission.

The Conservancy also recognizes that most sources of energy, even the cleanest ones, have impacts.  Renewable energy such as wind, hydropower, and solar need to be sited carefully to avoid impacts to priority resources, particularly to habitats that can provide resilient refuges for climate changes or provide linkages among these resilient sites.  To this end, it is crucial for the Commonwealth to have policies and practices that encourage energy siting and operation in ways that observe all three legs of the mitigation hierarchy: avoiding impacts to the most important places, minimizing the remaining impacts, and offsetting the impacts that cannot be avoided.  The mitigation hierarchy should be applied to all forms of energy and energy infrastructure, including extraction, generation and transmission.  We recommend that this principle be acknowledged throughout the Virginia Energy Plan.

A region of the Commonwealth that is of particular interest to The Nature Conservancy is Southwest Virginia.  For nearly three decades, our Clinch Valley Program has worked with local communities across the region to protect nearly 40,000 acres of globally important natural habitat while implementing conservation strategies that support sustainable economic development.  We recognize that the decline of the coal industry is having significant economic and social impacts on the region, and that there is an important need to diversify the regional economy.  Two economic development strategies that are aligned with our conservation goals in Southwest Virginia are (1) expansion of the outdoor recreation economy and (2) development of both distributed and utility-scale solar energy.  With regard to utility-scale solar, we note that region’s inventory of former mined lands could provide an ideal platform to demonstrate how renewable energy can be developed on previously disturbed areas.  This would serve as an example of how the expansion of renewable energy can generate jobs and new economic activity on currently unproductive sites, while also avoiding the biodiversity impacts that might result from the development of solar in currently forested areas.  The Conservancy is in active conversations with Virginia DMME, utility companies, and the Southwest Virginia Solar Working Group to better understand the opportunities and challenges associated with solar development in the region.  We would appreciate an acknowledgement in the Energy Plan of the need to explore compatible deployment of solar in this economically challenged and biologically rich region.

The only form of energy that is free of environmental impacts is the energy that is not produced.  For that reason, we strongly urge the administration to emphasize energy efficiency above all else in the Energy Plan.  In fact, the Energy Plan should be built on the foundational principle that efficiency is the least cost resource, equal to other sources of generation.  Fortunately, Virginia already has energy efficiency goals.  For example, the last administration established the goal of reducing state government electricity consumption by 15% by 2017 in Executive Order 31 (2014).  We urge Governor Northam to issue a new executive order establishing a new goal for his term. 

An even more important goal is the statewide goal to reduce retail electricity consumption by 10% by 2022. We submit that the single most important factor in whether Virginia will achieve this goal is the level of emphasis and effort devoted to achieving the goal by the Northam Administration.  We observe that there are at least two kinds of government goals.  One is the aspirational kind that is frequently mentioned but for which there is little accountability.  The second is the kind for which government leaders hold themselves accountable. 

As has been shared by DMME staff during several Energy Plan stakeholder meetings, more than half the goal amount remains to be achieved.  Only a focused effort within the Administration, in cooperation with the private sector, will bring the goal within reach.  The Northam Administration must therefore be an active, consistent advocate for the goal in every relevant decision-making process that is within the purview of state government.  These include State Corporation Commission consideration of utility Demand Side Management programs, utility Integrated Resource Plan filings with the SCC, the stakeholder process for developing utility portfolios of energy efficiency programs as called for in enactment clause 15 of SB 966 (2018), and Department of Housing and Community Development consideration of building code updates.

The Energy Plan should delineate the steps that the Northam Administration will take if it concludes that the 10% goal cannot be achieved within existing policies and conditions by 2022.  These should include proposing needed legislative changes such as an Energy Efficiency Resource Standard or the decoupling of electricity consumption and utility revenues and, if necessary, establishing a new target date so that citizens will know when they can expect the goal to be met.

We look forward to working with the Northam Administration to bring about a clean energy future for Virginia.

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