While this cap is a step forward towards responsible GHG management, the proposed cap is far higher than what we can easily meet under current projections. As a Virginia voter, I urge the DEQ to reconsider its proposed emission cap and update its baseline scenario to reflect more realistic estimates.

The current cap of 33 or 34 million tons CO2 is based on the assumption that energy demand is going to increase at a rate of 1.9% and 3% for residential/industrial and commercial development, respectively. I argue that these numbers are wrong and a new baseline scenario needs to include the increased solar capacity in the next 15 years. When including solar capacity, residential/industrial demand growth is under 1% for the next 15 years. Moreover, commercial demand is growing only because of the prevalence of server farms. The energy demand of these solar farms is covered by newly-installed solar. For example, a 500 MW plant has been proposed in Spotsylvania, and Microsoft has purchased more than half of the energy it will produce.  

Spotsylvania’s 500 MW solar farm is projected to cut 1 million tons of CO2 per year, so why is this already-planned projection not accounted for in the determined cap? Additionally, Dominion has 3 new natural gas plants that will displace coal plants and result in reduced emissions: another reason to lower the cap, since the plants will be able to provide the same amount of energy with lower emissions compared to coal.

If the DEQ keeps its baseline emissions too high, it inflates the cost of reaching the cap. The DEQ should consider including Emission Containment Reserve as part of the cap (9VAC5-140-6210. CO2 allowance allocations) plus output-based allocation (9VAC5-140-6215. CO2 allocation methodology). The cap should also start in 2019 and reduce emission from there. Absent a persuasive reason to delay until 2020, DEQ should begin implementing the cap in 2019 to effectuate the Governor’s Executive Order as soon as possible.