Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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8/23/18  12:33 pm
Commenter: Scott Sklar

Expand PPA, on-bill financing, and Integrate Distributed Generation to Power Critical Infrastructure

While the Virginia Energy Plan is a step in a good direction, the State should want to maximize energy efficiency  for the residential, commercial industrial, and institutional sectors - since energy efficiecny is always ess expensive than generating energybfrom any source, and it adds more disposable income into the Virginia economy. The second leg of a plan need to maximize all the renewable energy, the entire portfolio including biomass, geothermal, hydropower and marine energy (freeflow, tidal, wave, ocean currents and thermal), solar (all types: photovoltaics, solar daylighting, solar water heating, solar thermal), and wind energy (including small wind, on-and, and off0shore wind). The Institute of Local Self reliance's report Energy Self Reliant States concluded that Virginia could meet 177% of its eectrcity cost effectively from it indigenous renewable energy resources.

The State Corporation Commission (SCC) needs the direction and authority to allow Virginia eectric utilities to achieve a greater return by incentiving energy efficiency, working with local governments and institutions. While they will reduce revenues by allowing ratepayers to save energy, if they receive greater returns for thos eefforts, it will equal out economically for them, save ratepayers significant money, and pump these saved dollars into the broader Vireginia economy. 

The SCC needs authority to follow eleven other States to allow on-bill financing for high-value energy efficiency and distributed generation and energy storage. Essentialy is allows utilities to finance these applications onthe electric utility bill, and the obligation is tied to the meter - meaning it allows renters and leasers -- businesses and apartmernt dwellers affordably access these technology solutions and energy savings, with approval from their landlords. The obligation is tied to the meter till the investment is paid off, and the electric utility should be allowed to make the same return as it would for a new electric generation plant. Half of all buildings are rented and leased, so this opens up a wide market and will especially help small business and low income ratepayers.

And finally, power purchase agreements (PPAs) drives private capital in financing cost effective solutions for especially for commercial, industrial, and institutional ratepayers.  Virginia has artificially constraned the market only towards universities and schools, but this needs to be widened.  Energy choice is an essential principle, and te State of Virginia should not limit the market artificially.  This especially should applied tompwoering our critical infrastructure: cellular towers, datacenters, pipelines (for water, sewage, fuels), water and sewage treatment plant, major inetrsection and reailway crossing lighting, first responder buildings (urgent care & ambulence, police & fire stations) and even private sector applications such as gas station island pumps, and outpatient healthcare services. In good times, these electric loads are powered by dedicated renewable energy and in some cases storage systems, and in bad times they seamlessly "islad" off the grid and maintain their operations.

I am honored to teach the first course in the USA on "Renewable Energy and Critiical Infarstructure" at The George Washington University at their Arlington building this summer, and have taught seminars at National Defense University (NDU) and the war college at Fort McNair, as well as at CECOS for the US Navy on these issues. My two buildings in Arlington, VA have all their criitcal functions powered by hybrid renewable energy systems with smart battery banks toed to high-value energy efficiecny, which I routinely give weekly tours.

I hope the State of Virginia propels itself into the forefront of energy secuity, energy savings, reduction of use of fresh water, regulated emissions (mercury, NOx, SO, and particulates) and greenhouse gas emissions, and in-state job creation by adopting these aforementioned proposals.  I want to remind State decision makers that you have leading nationalcompanies in the field based in Virginia, and the Virginia-based universities, including (but not limited to) George Mason University, Marymount College, The George Washington University, and Virginia Tech have numerous programs, courses, and faculty dedicted to these solutions, and would be wise to more formally integrate these institutions into driving practical and economic solutions like those described above.

Thank you for your serious consideration.

Scott Sklar, Ajdunct Professor, The George Washington University 

       and President, The Stella Group, Ltd.

706 North Ivy Street, Arlington, VA 22201  VA Phone:  703-522-1195



The Stella Group, Ltd.. is a strategic technology optimization and policy firm for clean energy users and companies, with a focus on system standardization, modularity, and web-enabled diagnostics. Scott Sklar is an Adjunct Professor at The George Washington University teaching three unique interdisciplinary sustainable energy courses, and an Affiliated Professor with CATIE, an international graduate university in Costa Rica offering graduate degrees on sustainability. Sklar is the Energy Director at GWU’s Environment and Energy Management Institute (EEMI). Sklar chairs the Steering Committee of the Sustainable Energy Coalition. On June 19, 2014, Scott Sklar was awarded the prestigious The Charles Greely Abbot Award by the American Solar Energy Society (ASES) and on April 26, 2014 was awarded the Green Patriot Award by George Mason University in Virginia

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