September 16, 2022
Virginia Department of Energy
RE: Nexamp Comments on the 2022 Virginia Energy Plan
Nexamp greatly appreciates the opportunity to provide input and to work with Governor Youngkin and this Administration as Virginia embarks on developing a new Energy Plan for the Commonwealth. This is a critical juncture for the Commonwealth to chart its energy future. Enacting policies to unlock the potential of clean energy in Virginia can increase the state’s energy security, improve grid reliability, and allow Virginia residents and businesses greater access and choice in making their energy decisions.
Nexamp was founded over a decade ago, and since that time has grown from a small residential solar installer to a fully integrated solar development company and one of the leading providers of community solar or “shared solar” across the country. The growth and success of our program can be attributed to our fair and equitable subscription program. Our program was designed to ensure that everyone – regardless of income, credit history, roof space or geographic location – can participate in solar. We do not run credit checks on prospective customers, there is no cost to join our program and no penalty for leaving the program (we ask for 90 days’ notice), and we offer a stable, guaranteed discount of at least 10% against the customers’ standard electricity rates. Even as rates change over time, our customers are guaranteed the same fixed discount for as long as they choose to participate in one of our shared solar farms.
We are proud of the program we have built and the access to clean, renewable energy that it has afforded residents, small businesses, non-profits and others. We have developed projects with reserved offtake for low and moderate income (“LMI”) customers in Illinois, Maryland, New Jersey and in New York State; and we are actively investing in projects that will soon participate in Virginia’s new shared solar program.
As outlined by the Department of Energy, Nexamp understands that the 2022 Virginia Energy Plan will be focused on four key objectives: lower cost of living, job creation, bringing people to Virginia and an “all-of-the-above” energy approach. Nexamp commends these objectives, and in keeping with them, respectfully offers the following suggestions for consideration for the Energy Plan.
Expand the Shared Solar Program
Virginia’s shared solar program offers an opportunity for residents and businesses within Dominion’s service territory to participate in solar energy without the need for rooftop panels or an onsite project, expanding access to all regardless of where they live. In addition to low income customers and renters, this is also an opportunity for businesses, both large and small, to invest in solar without the logistical difficulties of siting solar on their own. Through participation in shared solar, customers are able to offset part of their electricity costs, lowering their energy burden.
Shared solar is an important complement to the state’s other energy investments in an “all-of-the-above” approach. It provides clean energy access to a broader range of Virginians, and in terms of development, the projects are between the scale of rooftop solar and utility-scale solar, providing communities a new opportunity to site solar projects in their jurisdictions with a smaller footprint.
Currently, however, this opportunity is limited to only a small subset of Dominion customers. At a total of 200 MW of program capacity, the current shared solar program is far too small to reach many Virginians. Nexamp recommends expanding the shared solar program to 5,000 MW.
In addition, the shared solar program should be expanded beyond Dominion to the electric cooperatives and Appalachian Power Company. Customers in those territories have no ability to invest in solar without a rooftop system. Particularly in Southwest Virginia, this program can provide significant opportunity and economic development. In Nexamp’s view, there is no justification for the benefits of this program to not reach across the Commonwealth.
Alongside shared solar projects comes significant investment in local communities, from lease revenue for local property owners, to local tax revenue, to construction and electrical work. Currently, however, the cap on shared solar is providing a disincentive for Nexamp and other companies to invest in Virginia long-term. All companies need some amount of certainty when making hiring decisions and investment plans. A long term vision for the program will provide the critical impetus for continuing to hire and invest in Virginia.
Revise the Shared Solar “Minimum Bill”
Included in Virginia’s shared solar program is the concept of a “minimum bill” to ensure customers continue to contribute toward the costs of the electric system. The version approved by the State Corporation Commission, however, fails to meet the statutory intent and in practice is likely to prevent most customers from being able to participate in the program. In order to ensure that all Virginians are able to participate, as the statute and the program envision, the minimum bill must be revised. Nexamp recommends that the minimum bill be set at a reasonable and fixed amount for all customers.
Policy Director, Mid-Atlantic