Virginia Regulatory Town Hall
Department of Energy
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8/22/18  5:21 pm
Commenter: Joy Loving, Climate Action Alliance of the Valley

Comments on the Virginia Energy Plan Second of Three Submittals

I am a solar producer, net metering customer, hybrid and electric vehicles driver, investor in utilities, citizen climate activist (as a Steering Committee member of Climate Action Alliance of the Valley), and distributed solar advocate.  I offer my perspectives about Virginia’s 2018 plan for our energy usage because they represent often competing interests that, taken together, nonetheless provide some insights into future consumer, energy producer, and investor behavior, and activist/advocate focus areas.  My family has made decisions that, I believe, illustrate fairly clearly the importance of Virginia’s embracing a new vision for its next Energy Plan.  To conform to the word limit of the on-line Town Hall comment submission process, my comments are divided into 3 submittals.  This is the second.  


What the Energy Plan Must Address

There are many aspects of, and implications for, energy production and distribution, grid management, customer energy usage patterns, the environment, and Virginians’ health.  Ultimately, these are interrelated and have strong interconnections and the upcoming Energy Plan will affect these directly and indirectly. SB966 provides for numerous studies, research, and initiatives.  This Markets Inside July 2018 article points out what Virginia’s largest utility has proposed.  Virginia needs to ask—and answer—questions about whether these proposals are the best use of the extra money (much from ratepayer overcharges) it has given the utility.  To answer those questions, Virginia needs a comprehensive Energy Plan that sets expectations.  However expert the State Corporation Commission is in evaluating such proposals, it needs better, more specific guidance than SB 966 contains.  Legislators are not energy experts, as their approach to energy legislation has proven over the years.  Virginia—not its utilities-- must direct and oversee implementation of this far-reaching legislation and the Energy Plan should specifically address this as well under the auspices of VEMA.  The fact that the State of Virginia chose to “join forces” with Virginia’s largest utility in holding public hearings that purport to simultaneously receive public input on both the Virginia Energy Plan and Dominion’s Grid Modernization Plan and SB966 implementation is most troubling.  While I understand that a public/private “partnership” with utilities is possible, I believe strongly that Virginia, not its utilities, must make independent decisions about its energy management across the board. In her August 15, 2018 blogpost, Ms. Main explains quite clearly why this is so.

In a July 2018 article, Five Technology Trends That Are Already Improving the Utility Customer Experience, Renewable Energy World (REW) illustrates that Virginia’s utilities will be hugely affected by Cloud Computing, Digital Transformation/loT, Electric Vehicles, Renewable Energy and Distributed Electrical Resources, and Security (cyber and Physical).  The article concludes “There is still some way to go for Utility companies to address these disruptive technologies — but address them they will, and the changes we will see in the industry can only be good news for the consumer.”  Virginia needs to be certain that this “good news” becomes a reality and not leave it to its utilities.  Listed below are what I believe are several such vital areas (though assuredly not all) that the energy plan needs to expressly recognize and address. 

Distributed Renewable Energy and Energy Efficiency

In a Rocky Mountain Institute (RMI) July 2018 three-part blogpost, RMI’s first blog included the following:

“One of the main themes at the 2018 RMI Electricity Innovation Lab (e–Lab) Accelerator event, held in Sundance, Utah, in May, was distributed grid infrastructure—the use of least-cost portfolios of distributed energy resources (DERs) to complement traditional electric grid infrastructure or to defer or avoid investments in it. These combinations, also known as clean energy portfolios (CEPs), consist of resources like utility-scale and distributed wind and solar generation, battery energy storage, energy efficiency, and demand response technologies used in place of new power plants or transmission and distribution infrastructure.

In a recent report, The Economics of Clean Energy Portfolios, RMI showed that new-built CEPs are already an economically attractive alternative to new gas-fired power plants in most cases and are likely to beat just the operating costs of efficient gas-fired power plants within the next two decades. With a system as heavily regulated, complex, and interconnected as the electric grid, however, stakeholders can’t just spot a favorable alternative to traditional practice and wing it.”

An August 2018 ILSR report  explains that the cost of renewable energy in most states is more than competitive with traditional sources.  The title (How Cheap is 100% Renewable Electricity? Really Really.)—and the article’s “Bottom line: in nearly 40 states, renewable electricity is less expensive than the existing power supply”—imply, more use of renewable energy for electricity makes economic sense.  Virginia is shown as one of the 40 states.

In his Roanoke Times op-ed of July 23, 2018, titled Virginia’s electric grid should be resilient, locally-fueled, and democratic, Aaron Sutch, Program Director of Solar United Neighbors of Virginia (SUN/VA), gave this description of the new utility model that Virginia needs:

“Virginia’s modern electric grid must be a two-way, democratic energy system that builds resilient power into our communities — while giving consumers the choice to participate in and benefit from energy production.  It must keep us safe from extreme weather events and cyber-attacks — and must be fueled with clean, local energy.

The cornerstone of a modern grid will be distributed ‘rooftop’ solar coupled with battery storage and electric vehicle technologies.  Instead of relying on energy generated hundreds of miles away and transmitted through vulnerable infrastructure, rooftop solar allows us to power our grid with a local, resilient, and affordable fuel supply.

Modernizing our grid will also empower Virginians to have greater energy choices.”

Mr. Sutch is not alone in his views. 

In a July 2018 interview with Energy News Network, Harrison Godfrey, Executive Director of Virginia Advanced Energy Economy, said:

“Our five priorities are interdependent and include using energy efficiency and demand response more effectively; expanding market access to renewable energy sources; improving and streamlining the permitting regimes to accelerate the deployment of renewables; and integrating electric vehicles into a broad transportation infrastructure that reaches from passenger cars to municipal bus systems to port service vehicles.

Our fifth goal, which undergirds everything else, is grid modernization for the 21st century to give customers more flexibility and control. That goes beyond smart meters and other new technology.  Just as important are regulations that ensure customers have more choices and control about energy use.”

“The Virginia chapter is one of 27 such industry organizations that is part of a national association of businesses dedicated to secure, clean and affordable energy.”  It launched in February 2018.

Another Energy News Network article, in August 2018, is headlined Virginia’s rural co-ops learning lessons with community solar.  This article describes the efforts of one Virginia co-op CEO who said, about his solar projects:  “The nice thing about not having a profit motive is that we can focus on what the customers want…”  The author noted that “While co-ops pride themselves on being nimble and inventive, many were wary of switching to solar until its price became competitive with coal and natural gas. That was especially true in Virginia, a longtime conservative coal state.”  And a spokesperson for the Virginia-based National Rural Electric Cooperative Association noted:  “It took leaders … in the co-op community….” He was responding to members by prioritizing their interests over tradition.”

Virginia doesn’t have to develop a distributed solar model from scratch.  There’s plenty to be learned from other states” experiences.  There’s Minnesota, New York, Ohio, and South Carolina, to name a few.  And this ILSR report in July 2018 quantifies how much rooftop solar there is in the U.S., and discusses some reasons for it.  Another July 2018 ILSR report, Reverse Power Flow: How Solar+Batteries Shift Electric Grid Decision Making from Utilities to Consumers, shows how solar and storage will transform the way decisions about energy are made.  Virginia needs to be ready for these changes.  “The times, they are a changin’”—as illustrated in this Energy News Network piece about North Carolina’s “experiment” with solar energy.  Virginia needs to pay attention.

Two articles in July and August 2018 illustrate the impacts on Appalachian residents from expensive coal-sourced electricity.  Inside Climate News focuses on Kentucky and West Virginia.  Appalachian Voices’ blogpost describes The burden of rural home energy costs.

In a July 2018 blogpost, Ivy Main said that “Virginia’s energy laws were written by and for monopoly utilities that are heavily invested in coal, gas and nuclear. The Virginia Code contains a thicket of barriers that protect utility profits from competition and limit the options of developers, consumers, local governments and businesses.”  After providing data on Virginia’s installed solar and wind energy (0 of the latter), Ms. Main explains how “Customers’ ability to purchase renewable energy is still limited” in Virginia.  After pointing out that “In 2017, Dominion Energy Virginia acknowledged for the first time that solar had become the cheapest form of energy in Virginia”, Ms. Main notes that the two largest Virginia utilities have nonetheless proposed rates for renewable energy that exceed their costs for “brown” power.  Further, she tells us that “A new law passed in 2018 (SB 966) puts 5,000 MW of utility wind and solar ‘in the public interest,’ although this language is not a mandate.”  She adds that “The 2018 law also makes it in the public interest for utilities to develop up to 500 MW of distributed solar (some parts of the bill say just 50 MW).”  In this way, SB966 is similar to the current Virginia renewable portfolio standard that isn’t a standard, rather a 15% goal, achievement of which is not enforceable and strictly voluntary for the utilities.  These inherent contradictions and inadequacies in Virginia law are clear illustrations of why Virginia needs to take control of its energy management.

Distributed, also known as “rooftop” solar has numerous benefits.  It

  • Creates local, non-outsourceable jobs
  • Builds clean, local energy in our communities;
  • Helps reduce energy bills and give consumers energy choice; and
  • Works with battery storage to keep the lights on during a natural disaster.

Here are some examples of reasons and ways to take advantage of distributed energy resources:

  • Encourage customer-owned battery storage.
  • Develop pumped hydroelectric storage facilities to store wind and solar power -- NOT fossil fuel generation -- and construct them on “brownfields”, not “greenfields”.
  • Require utilities and regulators to work harder to reduce retail electricity consumption 10% by 2020;
  • Place a moratorium on new fracked gas pipelines because existing infrastructure can already meet our energy needs;
  • Allow and incentivize all citizens (homeowners, farmers, businesses) who install grid-tied solar PV with battery backup systems to support the electric grid by either supplying the grid in times of need or providing battery storage capacity in times of excess.  [The grid manager would be positioned to use this “excess” distributed energy for grid load-leveling, providing power to the local load first, as needed, and if available, to the larger grid, especially during peak usage times in summer.  This is similar to the notion of extracting energy from batteries of plugged in EVs and plug-in hybrids in a “smart grid”.  A distributed system of grid-tied battery banks would make a significant contribution to the general electrical needs of the populace served by a grid manager.  Using distributed battery storage capacity is an integral part of a system of sensible ‘smart grid’ solutions which will be adopted eventually by Virginia’s utilities, most likely with their own assets.  The challenge is to create State laws allowing individuals the right to help out while providing their own clean energy.
  • Eliminate barriers to customer-owned and third-party financed solar power.
  • Provide state tax credits or other incentives to encourage the growth of distributed renewable energy and energy storage resources.

I endorse Aaron Sutch’s comments about the Virginia Energy Plan:

 “Rooftop ‘distributed’ solar builds resilient and local energy into our communities. It creates jobs and give consumers energy choice and freedom. Virginia’s energy plan must recognize its unique value and set forth a vision and action steps in this context. I respectfully urge Governor Northam and the DMME to consider the following recommendations as part of the 2018 Energy Plan. 1) Provide incentives for solar coupled with battery storage as a resiliency strategy.  Data from areas recently hit by weather disasters (Puerto Rico and Florida) demonstrate that on-site solar energy coupled with battery storage is the best way to provide resilient power during natural disasters. 2) Expand incentives and reduce barriers to customer-owned solar to create well-paying local jobs.  According to data from the Solar Foundation, 84% of Virginia’s solar jobs are in the ‘distributed’ rooftop solar sector.  Rooftop solar, and the jobs it creates, depend on fair market access and incentives like net metering and third party ownership. It is hindered by utility-imposed standby charges, arbitrary limits on net metering and system size limitations. To grow solar jobs, Virginia needs to expand net metering, third party ownership and eliminate unnecessary barriers to customer-owned solar. 3) Discussion and action around grid modernization must include consumer participation as a key element. Virginia’s truly modern grid will be a two-way energy system that directs benefits and control back to energy consumers. Advances in rooftop solar, battery storage and electric vehicles now enable energy consumers to actively participate in their energy system. As such, conversations around grid modernization must include adequate input from consumers and ratepayers and adequately value solar distributed generation.”

To Be Continued in 3rd submittal...

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