Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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8/23/22  11:57 am
Commenter: Ben M.

Rapid, equitable clean power built-out

We need to build on the momentum started with the VCEA and continue our path to 100% renewable energy and carbon neutrality. Action should be aggressive and take full advantage of the credits offered through the latest IRA bill. The renewable build-out should be the main priority of the administration (as it relates to energy) with heavy investment and supportive legislation for solar, wind, geothermal, storage, and other renewable resources. There are many facets to this transition that require careful consideration. Please see several considerations below.

As renewable penetration grows, we need to ensure grid reliability. In the very near-term this can be provided by existing natural gas resources. Beyond that, gas should not be the focus and we should instead invest heavily in energy storage. Virginia has the world's largest pumped hydro storage facility. Let's complement that project with distributed storage resources across the state, leveraging a variety of technologies. New solar and wind are now typically cheaper than new natural gas, so moving forward we should not consider natural gas a key part of our energy infrastructure and little-to-no new investment should be made. Where natural gas does exist, we should again leverage credits from the IRA and explore CCS technology to entirely offset emissions from those resources through the end of their lifetimes.

To further ensure reliability, Virginia should place greater emphasis on distributed resources and shared solar. These provide citizens of all means the ability to participate in the energy transition as well as localize energy generation to increase robustness of the grid. I'd like to see more micro-grid projects and other DER proofs-of-concept. Pursuing these solutions with vigor in the next four years will allow them to fully take shape in the years beyond, a genuine win for everyone involved. As to Virginia's burgeoning shared solar industry, the state needs to lower the minimum bill from the $55 that is currently proposed. The nation's highest such fee, combined with the required service fee, would place access to shared solar out of reach for many interested residents. The program should always be made readily available to low- to mid-income households and I applaud that provision of the current setup. However, access for that demographic does not need to come at the expense of access for other demographics. Making shared solar as widely available as possible is essential to reaching our climate and energy goals. When we say we will "pursue all possible solutions" that must include all forms of renewable generation, not just all different fuel sources.

Continuing the focus on equitable energy access, Virginia should not remove itself from the RGGI program. The program has proven its value to the state, the energy industry, and most importantly the communities most at risk from climate change. Our participation should never have been made a political talking point used to score votes, and I encourage that narrative to refocus on the costs and benefits the program provides. Limiting emissions from carbon-intensive resources and directing funds raised from the effort to assist communities in need is a laudable goal. That goal has been successfully achieved through our participation RGGI so far. Unless an equally-viable solution is implemented, the state should not exit the program.

One more component of equitable energy access must be considered: consumer protection. The SCC has not placed sufficient regulation on the investments and development pursued by big Utilities in the state. Presently, the incentive structure is such that ratepayers are always the ones bearing the risk of the Utilities' actions. It is easy to gamble other people's money if you are never at risk of repaying losses. This is precisely how the state allows the industry to run. It also results in a grossly over-expensive grid transformation. Consider our Utility that has a guaranteed 9-10% rate of return on capital investments. Present that Utility with a choice to upgrade the grid for a proposed energy project: 1) build a new $10 million transmission line or 2) implement a $200 thousand Dynamic Line Rating software system that will achieve the same result. Every single time the Utility will choose the $10 million dollar option. And as evidenced by history, every single time that Utility will gain approval to pass on that expense to the ratepayer. This is currently on clear display with Dominion's rejection of the SCC's proposed consumer protection policy for the new offshore wind project. While I believe that policy still stops short of fully encouraging inefficient behavior from the Utility, I support the effort made to place some risk on the entity building and operating the project. If we want to build the best electrical grid that we collectively can for this state, the incentive structure and regulatory oversight of big Utilities must be changed. If we do not change those policies, we may still achieve an excellent grid, but it will come with a drastically higher price tag and much longer timeline. These costs are often borne by marginalized and/or low-income communities. The longer we allow the current system to reign, the larger the energy equity gap will grow and the more difficult (and expensive) it will become to close it.

One final item I'd like to mention (ending on a happier note) is our transition to electric vehicles. Transportation continues to be the highest emitting industry in America. To tackle climate concerns, we can't solely replace all of our electrical generation with clean energy. We must also replace our combustion-heavy transportation with cleaner alternatives. Public transportation can go a long way and should be a notable focus, but American culture is unlikely to change enough in the near-term to remove our reliance on individual transport. Thus, we need to invest in our EV infrastructure. This of course means things like a wider and more reliable charging network, but also supporting vehicle manufacturers to bring their cars to our state. This could be through legislative incentives, expanding consumer tax credits beyond the federal level, and enabling greater access for customers to purchase vehicles directly from manufacturers (this last is particularly important for near-term acceleration). Beyond that, investing in clean transportation for schools brings a wealth of benefit in the short and long term. If done properly, the costs will be paid back in short order. And what better way to inspire the imaginations of youth than surrounding them with creative solutions that provide a wide range of benefit? Virginia already has some great experience on this front (Middlesex County for one) and we should lean on our internal knowledge to spread that value to more areas around the state.

If you have made it this far, I appreciate your time and your consideration of my thoughts. Please feel free to contact me via the email provided if I can be of further assistance or help push Virginia forward along a clean, equitable path.

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