Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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8/17/18  3:38 pm
Commenter: Bill Hafker

Need for VA Energy Plan to also be a Climate Plan, and a proposed Framework to accomplish that

Thank you for this opportunity to comment on the Virginia Energy Plan.

I attended the Listening Session at George Mason University on 8/16.  I support the comments made by the vast majority of those who spoke in favor of Virginia committing itself to far more aggressive action on reducing its Greenhouse Gas (GHG) footprint than it has to date, including removing regulatory/legislative barriers to increasing cleaner energy as a greater percentage of power provided in the state.

I am confident that the state has the expertise to assess the many options available to it to achieve greater energy efficiencies as well as other ways to significantly lower its GHG footprint.  The range of these is extremely far ranging including things as varied as setting its own auto fuel efficiency standards, requiring Leeds certifications or solar installation for future construction both commercial and residential, setting its own cost of carbon/carbon tax on operations in the state or alternatively offering a low carbon tax break, improving mass transit, increasing the gasoline tax and using the funds for GHG reducing investments, etc.  I believe that the state, like many other entities are doing, should commit itself to the U.S. Paris Agreement targets despite the fact that the President unwisely made us the only country on earth not party to that Agreement.  I would respectfully request was also mentioned by several speakers; that the State Energy Plan be explicitly prepared in such a way that it is not only a Credible Energy plan, but simultaneously a credible 2 Degree Celsius Climate Plan.  Perhaps uniquely I would also like to offer a Framework for what is required for it to meet the latter of those 2 objectives.

The following link will take you to a paper I presented in June at the Annual Conference of the Air and Waste Management Association on “A Framework for Credible 2 Degree Celsius Climate Planning”.

Based on my 36 years of experience as an environmental engineer with ExxonMobil, it uses the petroleum sector to illustrate how the Framework would be used.  The Framework is however equally applicable to a State Energy AND Climate Plan. I hope that you will read the paper as you consider its use in your planning process, but I would like to highlight a few points from the 11 Elements in the Framework that I believe are vital for you to address in your Plan.

-        You must prepare and document the FULL GHG inventory for the state from some year you intend to use as a baseline.  This includes ALL GHG emissions that occur in the state regardless of who has direct control of them. This should include both absolute emissions and as much as possible normalized emissions (this may require you to partition the absolute emissions into several categories suitable for a similar normalization factor.) 

-        You must state a target for your emissions reductions (both absolute and normalized) and the timeframe to accomplish it.

-        You must commit to specific quantifiable actions that will be taken to achieve those targets, AND project what the actions will deliver by when based actions committed to vs others under consideration or in process of being legislated.

-        You must document and communicate progress annually, and identify steps to make up gaps between your goal and what the plan is delivering. 

We stand little to no chance of succeeding in our effort to meaningfully address climate change, unless ALL stakeholders become engaged. This includes energy suppliers, energy users, government, investors, and the voting public.  It will not matter if tremendous efforts are made by, or against, a fossil fuel company or the industry as a whole, unless the market rewards those companies rather than punishes them, and unless the demand for their products is reduced.  If the market votes against climate friendly actions by selling stock, a company will correct its behavior in response to shareholder expectations.  If demand remains unchanged, it will make NO difference to GHG emissions if one company becomes a renewable leader, while other companies still sell the fossil fuel demanded by the market.  This brings in the crucial role of government fulfilling its responsibility to it’s state’s citizens, and to humankind worldwide, to use both carrots and sticks to encourage the other stakeholders to act in ways that ensure that their actions are consistent with the Paris Agreement goal of seeking to hold temperature rise to no more than 2 degrees Celsius (though with progress to date, even that may soon be out of reach, if it is not already).

I would be extremely happy to discuss the Framework with those preparing your plan if that would be of help to you/them.  I can also provide you the PowerPoint slides from my presentation if those would be of use.  I was unable to see a way to attach them in your comment submittal format.


Bill Hafker


CommentID: 66185