COMMENTS OF WILLIAM PENNIMAN
CONCERNING NECESSARY ELEMENTS OF 2022 VIRGINIA ENERGY PLAN
I submit these comments as a citizen of Virginia with both children and grandchildren. My comments are for them and for my fellow citizens. My comments reflect nearly 50 years working on energy issues in the United States, including a decade on climate issues.
The authors of the 2022 Virginia Energy Plan must look to the future not to the past or even to the moment. The Energy Plan must advance the goals established by the General Assembly’s approved energy policies and aim to meet the GHG reduction goals recognized by scientists and world leaders. This includes reducing carbon dioxide (CO2) and other greenhouse gas emissions (GHGs) with a net-zero goal for 2050, and a 50% reduction much sooner.
The Energy Plan needs to lay out an all-of-the-above strategy to reduce GHG emissions as rapidly as possible, not short-sighted measures to boost or drag out fossil fuel production or consumption. The latter might feel good for the moment or attract campaign donations from deep-pocketed fossil fuel interests but it would be fundamentally at odds with the interests of our nation and our children.
Failing to cut GHG emissions as rapidly as possible would severely harm our children and our Nation. It would be fundamentally immoral and unpatriotic.
The GHG-Reduction Imperative
Climate change (a.k.a global warming) is driven by humanity’s GHG emissions, which are primarily the result of fossil fuel production and combustion. GHG emissions from energy, particularly CO2, methane (CH4), nitrous oxide (N20), are driving up atmospheric and ocean temperatures in Virginia and around the world. Those temperature increases are fundamentally altering weather patterns, driving increasingly severe:
And, if that was not bad enough, these crises are growing worse at a much faster rate than had previously been foreseen and are triggering “feedback” affects that will accelerate climate change even faster.
And, if that wasn’t bad enough, the adverse impacts from continued emissions of CO2 and N20 will last for many centuries after each pound of CO2 or N20 is emitted. The direct heating impacts from methane may last a fraction of the time, but those impacts are 87 times worse than from CO2 over the 20 years after emission, and the economic, ecological and human harms will last long beyond those 20 years.
Since GHGs are cumulative, postponing reductions will lead to increasingly steep reductions in a few years or increasingly severe harms to our children and their children.
Needed Plan Elements
More than ever, Virginia must act to sharply cut its GHG emissions with a long-term plan to achieve a zero-carbon electric supply by 2050 and a 50% reduction in carbon emissions by no later than 2035. As the electric sector’s carbon emissions are being reduced, Virginia needs to dramatically improve energy efficiency in buildings, appliances, heating and cooling and industrial equipment and convert its transportation system to electric vehicles which produce no emissions in their operations. Virginia must also act to reduce GHG emissions from other parts of the energy sector.
It is very possible to reduce CO2 emissions in the electric system to net-zero. The zero-carbon technology exists and it is getting better and cheaper. Political leadership and commitments are the major missing ingredients. The 2022 Energy Plan needs to supply the zero-GHG vision and the climate-imperatives upon which that vision is based.
Energy efficiency should be the first line of defense against energy waste and GHG emissions. Efficiency improvements can dramatically reduce the amount of electricity and fossil fuel that is needed to heat, cool and operate our homes and businesses. Reducing energy consumption is critical to reducing GHG emissions. The Electric Power Research Institute found that Virginia utilities had achieved only 2% of the energy efficiency improvements available to them.
The problems with achieving greater energy efficiency are several, and solutions are needed, including:
Virginia’s statewide building codes are inadequate. They have long failed even to keep up with national codes (the International Energy Conservation Code), when, by law, they should be “at least as stringent” as the latest IECC. This includes incorporation of standards that go beyond the IECC. The results include higher GHG emissions. higher costs to building occupants for decades after a dwelling is built, and greater economic insecurity for low- and moderate-income residents. It will cost buyers (and the public) far more to retrofit dwellings (particularly in the case of building envelopes) than it would have for the builder to include a more efficient designs in the first place and the higher construction costs would be paid with mortgages in the case of new home purchases.
Many of the state’s efficiency programs are run by utility companies that want to increase their sales and to justify their past and future investments, not reduce usage. Creating an independent “efficiency utility” funded through utility rates could help to better align efficiency incentives and investments.
All business and residents should be incentivized to reduce their energy consumption, particularly their combustion of fossil fuels.
Net-zero GHG buildings (combining efficiency and clean energy) should be required or, at least, strongly incentivized (e.g., rewarded with tax benefits and favorable publicity).
Energy efficiency performance. energy costs and GHG emissions should be collected and publicized for new and existing buildings. Building owners and operators should be required to demonstrate energy cost savings and GHG reductions to owners and tenants.
The state should strengthen its own efficiency policies by (1) setting clear goals and plans for annually reducing energy usage by each state agencies; (2) making leaders within each department personally responsible for achieving the energy-reductions; (3) tracking and publicizing energy usage and progress; and (4) rewarding employees who make the most meaningful contributions to achieving the goals. Generally announcing energy reduction goals (e.g., 10% over 5 years) is not going to be effective without clear assignments of responsibilities and consequences for meeting or not meeting the goals. Energy efficiency performance contracting should be encouraged and facilitated.
Local governments need help and incentives. It is easy for local officials to take a short-term view that avoids investments that would benefit taxpayers over time. State funding assistance should be tied to reduced energy usage or shifting entirely to zero-carbon energy. There should be a large revolving fund to provide financial assistance to local governments to help them cover their up-front costs to save energy, which would then be repaid and re-loaned to others.
Electric vehicles have no point-of-use pollution emissions, have much less need for maintenance, and lower per-mile operating costs. Operating and maintenance costs are far lower than for gasoline or diesel vehicles. Automobile owners can save $1,000 or more annually with EVs.
EVs a major benefit for consumers and the environment, particularly as electric systems shift to zero-carbon energy production. GHG reductions are far lower even considering today’s upstream electricity generation.
The central problems to getting to much greater EV usage are (a) lack of buyer awareness of benefits, (b) fears that the low availability of charging facilities will interfere with convenient travel particularly over longer trips, and (c) upfront costs. Virginia should address these issues with at least the following measures:
Dwellings and other buildings need to shift to electric technology, including heat-pump technology which is vastly more efficient and reduces GHGs compared to combustion-based technology. Manufacturing and commercial buildings likewise need to electrify to the maximum extent possible, as rapidly as possible.
Methane is a dangerous GHG with a potency over 20 years of 87 times that of CO2. Since we need to reduce climate changes as rapidly as possible, it is not acceptable to continue to emit methane from fossil fuel production (natural gas, petroleum or coal) or from pipelines, local distribution facilities or processing operations – all of which contribute significantly to methane emissions.
The Energy Plan should call for prompt regulatory measures to reduce methane emissions from the fossil-fuel supply chain. DEQ and DMME have the authority to require reductions in methane emissions from these fossil fuel operations and should use that authority to require emissions reductions. Much of the reductions come from poor maintenance, carelessness or conscious decisions to vent methane. Those can be regulated with the result of significantly reducing methane emissions. Regulatory proceedings should be initiated as soon as possible.
In sum, Virginia’s new Energy Plan should prioritize reducing GHG emissions and other pollution from energy use and production using every tool available, including zero-GHG energy supplies and energy efficiency. Business as usual or moving backward would amount to digging ourselves and future generations into an ever-deeper and more destructive hole. It is vital we stop digging by stopping emissions of GHGs as rapidly as possible, while rapidly taking measures to reduce harms that are already occurring and growing.
September 1, 2022