As energy consumers with operations, investments, and business interests in Virginia, we appreciate the opportunity to provide comments on the development of the State’s 2022 Energy Plan. We understand firsthand how clean energy helps businesses save money, reduce risks, stay competitive, and meet the expectations of our customers, employees, and shareholders. Investing in clean energy also improves public health and mitigates the risks to communities and businesses posed by climate change, yielding additional economic benefits and avoided costs. Accounting for these benefits and aligning the development and implementation of the Energy Plan with Virginia’s goals to deploy 30% renewable energy by 2030 and 100% by 2050, as mandated by the Virginia Clean Economy Act (VCEA), is vitally important to all Virginians. We hope the State will seize the opportunity to increase investments in policies that decarbonize the electric grid and increase the accessibility and cost-effectiveness of clean technologies.

States with ambitious clean energy standards have seen billions of dollars in economic, health, and other benefits. More than 88,000 Virginians worked in clean energy and clean transportation industries in 2020.  In fact, solar generation is the largest job source for all electric power generation in Virginia.[1]  A significant proportion of clean energy jobs also come from energy efficiency,[2] which provide critical services, such as low-income home weatherization, heating and cooling system maintenance and upgrades, and refrigerator recycling. Even so, there are many more clean energy jobs to be captured in Virginia.[3]

A clear and predictable legislative and regulatory pathway for clean energy investments will create many more local, family-wage jobs and simultaneously attract new businesses looking to power their facilities with the cleanest, most cost-effective energy sources. Without this certainty, Virginia risks businesses looking elsewhere to meet their clean energy needs.

We encourage you to consider the following guiding principles as you develop the 2022 Virginia Energy Plan to achieve the Commonwealth’s short and long-term energy, economic, and public health goals:

1. Reduce energy waste and maximize ratepayer savings and emissions reductions

The Energy Plan should include ambitious targets and programs to capture energy savings and reduce emissions cost-effectively. Demand side management (DSM) resources, including energy efficiency and demand response, relieve stress on the grid, thereby improving service reliability, and provide opportunities for customers to lower their monthly bills. Further, by reducing energy waste, utilities are able to delay and even avoid more expensive investments in new generation, transmission, and distribution assets. Thus, all utility customers benefit from energy efficiency, even if individual customers do not participate in those programs.

DSM programs are extremely flexible and are composed of numerous strategies, products, and technologies. Through strategic fuel switching policies, customers can achieve immense savings. Cold-weather heat pump technologies can save homes and businesses up to 50% in electricity use for heating. When deployed alongside effective consumer education, these technologies give consumers the ability to manage their energy consumption and their electricity bills. While all customer classes should take advantage of these resources, the savings opportunities from DSM programs are particularly beneficial for low-income households and small businesses.

Energy efficiency and demand response programs need stable, consistent funding to provide all of the benefits highlighted above. We recommend continuing to direct funding from regional carbon market participation toward energy efficiency. In addition, there are many near-term opportunities to increase energy efficiency investments through existing state programs and by leveraging collaborative public/private funding opportunities.

2. Enable viable pathways for all energy customers to purchase renewable energy

Investing in clean energy has helped our businesses and our supply chains cut energy costs, hedge against fuel price volatility, and make progress toward our commitments to reduce emissions. Because of these financial and societal benefits, companies in Virginia and nationwide are making significant commitments to use more clean energy. Nearly 100 companies in Virginia alone have committed to 100% renewable energy. We need to eliminate market barriers and provide additional pathways to invest in clean energy.

Proven clean energy investments such as solar and wind coupled with battery storage are consistently more cost competitive than fossil fuel resources and help hedge against volatile fuel prices. Companies want to make these investments in Virginia but are limited by the availability of in-state resources and utility offerings. Increasing adoption of distributed solar and batteries will provide important cost savings to all customer classes and provide grid-level benefits, including localized resiliency improvements. 

Competitive resource procurement is also critical to ensuring Virginia utilities pursue the most cost-effective energy pathways. Solicitation processes that are both transparent and competitive provide a platform for the consideration of new technologies and clean energy options, enable fair and equitable consideration of all resources, and support the diversification of Virginia’s energy mix.

3. Scale up electric vehicle infrastructure and programs

Businesses across the nation are investing in electric vehicles (EVs). Most EV owners save between $6,000 - $10,000 over the lifetime of the vehicle through reduced fuel and maintenance costs, and those savings are amplified when companies electrify entire fleets. EVs also avoid the volatility of gas prices, allowing businesses to better predict operating costs.

Over the next few years, the Advanced Clean Cars (“Clean Cars”) program in Virginia will increase the availability and development of more-efficient passenger vehicle models in the state, build a more competitive marketplace, and provide access to cost-saving opportunities for all Virginians. Additional programs that apply to commercial trucks and buses will ensure that businesses also have access to the vehicles they need to decarbonize their transportation fleets, reaping cost-saving benefits and reducing local air pollution.[4]

There are a variety of programs that incentivize customer EV adoption across all customer classes, including discounted off-peak charging rates for EV owners, rebates for EV purchases and charging installations,[5] and public EV charging and car sharing. Utilities should couple investments in incentive programs with investments in programs and technologies that balance energy demand, such as utility-scale energy storage and vehicle-to-grid technology, to increase the energy supply and resiliency of the electric grid while generating savings for all electricity ratepayers.

In conjunction with utility programs and private retailers, federal funding opportunities, such as the National Electric Vehicle Infrastructure funds, can support strategic in-state EV infrastructure build out to ensure a reliable charging network for Virginia drivers as well as public and commercial fleets. 

4. Encourage innovation and investment in emerging clean energy technologies

Policies should encourage innovation, investment, and manufacturing in emerging clean energy and transportation technologies, such as battery electric vehicles, offshore wind, renewable thermal, and energy storage to ensure Virginia continues to take advantage of the cleanest and most cost-effective energy resources.

We encourage Virginia to maintain its position as a leader in offshore wind development. The state’s location on the East Coast, advanced maritime workforce, and in-state supply of industry leaders create an optimal investment opportunity for offshore wind. Rapidly increasing this cost-effective and renewable resource during this decade will create thousands of additional high-wage, local jobs and add $18 billion in economic benefits to the state if the goals of the VCEA are met.[6]

Renewable thermal technology (RTT)  can utilize a broad range of local renewable energy sources that would otherwise be wasted, such as waste energy from industrial processes or waste incineration. There are several types of RTTs that can provide heating, cooling, and power generation. These applications can range from small domestic systems to large scale applications used in industrial processes and heating and cooling networks.

Due to the complexity of the power grid and the power supply, promoting energy storage is essential for all elements of a power system, including generation, transmission, and demand response. These storage forms can take many forms (e.g., chemical, kinetic, or thermal), with the traditional system of hydro storage being the dominant form; however, due to the burgeoning need of a 21^st Century electrical supply, the deployment and priority of other energy storage systems is necessary to promote energy sustainability. Thus, state investment in sophisticated analytical tools for planning, operation, and regulation of electricity systems through energy storage is necessary in order to deploy and use storage efficiently, and to ensure a viable 21^st Century electrical power system.

5. Consider the avoided costs and other economic benefits of deploying clean energy when performing cost-analyses

In addition to consideration of federal funding opportunities for clean energy investments, cost analyses of climate and energy policies should include the abundance of avoided costs and other economic benefits from deploying clean energy instead of conventional energy sources. Clean energy investments have the significant added benefit of reducing harmful air pollutants and associated health costs. Improved air quality will result in fewer instances of respiratory illness, particularly among children and the elderly, which will help to deliver up to $34 million in health benefits, and avoid thousands of missed work days and hospitalizations in Virginia annually. RGGI participating states have decreased their CO2 emissions by 59% from 2005 to 2020, as compared to Virginia emissions, which fluctuated with no discernable trend within that same period. However, RGGI in its first year helped the Commonwealth cut pollution from coal and gas plants by over 13%, improving our air quality and reducing our dependence on imported fossil fuels.

Investments in conventional energy generation, on the other hand, emit harmful emissions that endanger human health and strain the healthcare system, pose a substantial risk of becoming stranded assets in the near future, and expose energy users to considerable risk in the form of highly volatile fuel costs. It is critical that any analysis captures these avoided costs when evaluating the true cost of clean energy investments.

6. Anticipated job growth and the importance of ensuring a reliable and skilled workforce to meet the energy and economic demands of the 21^st Century

U.S. Energy Information Administration (EIA) projects that renewables will collectively increase to 49% of global electricity generation by 2050. The Commonwealth needs to invest in workforce development to meet the growing needs of the renewable economy. For the companies and employers engaged in the energy sector in Virginia, the largest sector being solar, 57.7% of employers reported difficulty finding and retaining employees to meet their energy employment needs; 26.1% of respondents determined that it was very difficult. With an emphasis on workforce development investments, increased wages and economic opportunities will be readily available to many blue-collar communities throughout the Commonwealth.

The passage of the Virginia Clean Economy Act, adoption of the Advanced Clean Cars program (“Clean Cars”), and participation in the Regional Greenhouse Gas Initiative (RGGI) position Virginia and our businesses to make critical progress on decarbonization while supporting a competitive, resilient state economy. It is critical that these programs continue to achieve our shared goals of driving new in-state investment, encouraging innovation, and fostering long-term economic health. We urge the administration to pursue an Energy Plan that continues to provide a supportive environment for clean energy and clean transportation investments and, in turn, remain on track in its pursuit of a prosperous low-carbon economy.

Thank you for your consideration and please be in touch with any questions.

Sincerely,

Akamai Technologies, Inc.

Danone North America

Lutron

Mars, Inc.

Nestlé

Siemens USA

Virginia Wesleyan University

Worthen Industries