Virginia Regulatory Town Hall
Department of Energy
Department of Energy
Previous Comment     Next Comment     Back to List of Comments
8/24/18  11:46 am
Commenter: John Morrill and Demetra McBride, Arlington County Government

Arlington's Comments to Virginia Energy Plan


Comments from Arlington County Government

Thank you for this opportunity to provide comment to Governor Northam’s forthcoming Virginia Energy Plan.

Arlington County has had much success advancing energy efficiency and clean energy options for its residents, businesses, and within County operations over the past 10+ years. Improved energy efficiency in buildings and transportation, and increased use of renewable energy in Arlington – as well as on-going improvements in the carbon efficiency of the electric grid – have produced a 24 percent reduction in community-wide greenhouse gas emissions between 2007 and 2016 in Arlington. This tremendous progress was achieved while Arlington’s resident population and jobs grew by eight percent, and retail sales grew by one-third.

Still, much work remains necessary. Governor Northam’s Virginia Energy Plan can be a timely catalyst to further economic growth, job growth, savings to consumers, and further reductions in carbon emissions throughout Virginia for the benefit of all. Arlington County urges the Governor’s Energy Plan to -- 

  1. Promote and achieve greater energy efficiency in buildings and transportation across Virginia,
  2. Promote an increase in use of renewable energy across Virginia through both distributed (on-site) applications and at utility scale, 
  3. Promote active partnerships between localities and state and utility programs. Localities are an essential partner for delivery of clean energy programming and advanced transportation and storage technologies at community scale, and 
  4. Establish the energy sector as a leader in adaptation, smart infrastructure, and resiliency planning.

Further detail and context is provided below.

1. Promote and achieve greater energy efficiency

a.    Energy efficiency is an important economic engine and job creator statewide. A recent statewide analysis identified nearly 100,000 jobs due to advanced energy technologies and practices, including over 75,000 in energy efficiency in Virginia. Within Arlington, over 3,000 jobs can be attributed to energy efficiency, including innovative start-ups working at the intersection of cybersecurity, building automation, and building efficiency.

b.    Energy efficiency improves community resilience and public health. Healthy homes begin with protection from outdoor pollution and moisture control indoors. Well-built, well-insulated energy efficient housing provides both. Well-insulated buildings – especially beyond code requirements – maintain indoor comfort conditions longer, in case of energy failure such as power outage due to storms. Energy-efficient use of electricity helps reduce stress on the electric grid, lowering the likelihood of outages due to grid congestion or high demand.

c.    Legislative remedies can further modernize Virginia’s electric utility regulations by removing impediments to cost-effective energy efficiency programs by regulated utilities. Presently, the total resource cost (TRC) test is applied to individual segmented programs (lighting, HVAC, residential, commercial, etc.), posing a hurdle to cost-effective program delivery as each program has to offset its own project management, marketing, and overhead costs. Instead, allowing utility-sponsored efficiency programs to be evaluated on a portfolio-wide basis would allow for centralized administrative, outreach, and evaluation (evaluation, measurement and valuation, or EM&V) costs, and support more broad-based programs to proceed to benefit all customers at less cost to the utility and customer.

To use an example from facility renovation work, instead of performing a lighting retrofit, and then a building tune-up, and then an HVAC upgrade, and then a building envelope upgrade – all of which have separate project management and overhead costs – a bundled approach to whole-facility improvement helps keep project management costs low.In addition, viewing the project as a system also allows for capital savings by right-sizing the new equipment to take advantage of improvements elsewhere. Such aggregation of work in efficiency program delivery can show similar economies of scale by distributing marketing, management, and overhead costs across a broader span of effort.

d.    To support energy efficiency and DER programs, consider whether the calculation of TRC and other cost-effectiveness calculations should factor non-energy impacts such as (i) the social cost of carbon, economic impacts, public safety, and health impacts; and (ii) utility-centric improvements such as streamlined administrative costs, improved customer service, and enhanced operability.

e.    Increase attention to stranded market sectors, such as solutions to the split incentives that hinder energy efficiency programming for the residential rental market and multifamily properties. Increasingly, high costs of ownership are forcing greater renter-populations.

2. Promote renewable energy across Virginia

a.    The vast economic catalyst of clean electricity generation – wind and solar technologies – remains lost to much of Virginia due to some policies in place that inhibit their market penetration (e.g. limits on net metering and power purchase agreements), and, the absence of other policies to incentive these technologies (e.g. no mandatory renewable portfolio standard, and no state tax incentives). Legislative remedies to these systemic hurdles are desirable.

b.    The purpose, reliability, and impact of a mandatory renewable portfolio standard are best served through increased, longer-term targets beyond those established for the State’s voluntary RPS, which currently terminates in 2025 at 15% against the base year.  We encourage the State to think boldly and, referring to current strides in solar expansion and off-shore wind pilot facilities, recommend significant targets for 2030 and 2040.

c.    A further specific legislative advance of interest is for locality (‘municipal’) net metering to allow excess generation from one solar electric generation facility at a local government account to be applied against another local government account, for full retail value of the excess generation, even if not on contiguous property. For example, a landfill typically does not require much electric power, but it has land area suitable for large solar generation. Meanwhile, fire stations and other public safety facilities typically do not have suitable roof area for solar. To allow excess generation at one locality site to be applied against the costs of operating essential public facilities aids local government (and taxpayers) in a meaningful way. [According to the Code of Virginia, a ‘locality’ may be a town, city, or county, while a ‘municipality’ is limited to towns and cities. The intent of this recommendation is inclusive of counties, and therefore ‘locality’ is the preferred designation.]

3.  Promote active partnerships between localities and state and utility programs

a.    The state (DMME and others) should partner with localities for insights into state energy use and management as well as program delivery to constituents. During stakeholder discussions in July 2018, it was revealed that Virginia still does not have comprehensive assessments of basic energy use at many state agencies. Some localities have extensive experience with benchmarking their own facilities, and their experience and lessons learned can help state agencies beginning similar work. U.S. DOE State Energy Program (SEP) funds should be pursued to provide support to DMME and participating localities in this effort. The practical insights gleaned and financial rewards from a deep thorough dive into actual energy use should not be underestimated.

b.    DMME and others should support peer learning exchanges between localities on energy efficiency and other clean energy programs and practices.  This is another ripe area for U.S. DOE SEP funds and state collaboration. Some localities are home to nationally-recognized expertise in energy program delivery, and the socialization of best practices can help lift communities across the state.

c.    The state should encourage and facilitate partnerships between utilities and localities on utility energy efficiency program delivery. Local governments have dozens of ways to touch residents on a weekly basis. Localities partner with investor-owned utilities in several other states already, helping deliver energy efficiency programming using rate-payer dollars. This approach can be ideal for reaching disadvantaged communities, as well as for pilot programs of particularly innovative approaches. Local governments can enhance program performance and increase cost-effectiveness, through a diverse menu of relationships with utilities and the commonwealth, including as third-party implementers; marketing, education and outreach (ME&O) platforms; public-private partnerships; and as incubators and laboratories for energy efficiency, renewables, electrification, new technology, and distributed generation systems. Of course, as collaborators and partners in the state’s energy portfolio, local governments would support utilities and be held to the same standards of performance, cost-effectiveness, transparency, reporting and participation as the state’s existing program administrators.

d.    Arlington County is a national leader in smart growth, transit-oriented development, and transportation demand management (TDM). Further improvement in the efficiency of transportation in Arlington will occur through the transformative electrification of vehicular travel.  As a compact urban jurisdiction, Arlington is not ideally suited for electric vehicle charging infrastructure (EVSE) along the public right-of-way. However, Arlington has expertise and other resources for strategic development of EVSE planning and implementation, and can serve as a model for accessible and smart EVSE in constrained metropolitan areas. Arlington is eager to partner with the state and utilities on thoughtful deployment of EVSE, vehicle-to-grid (V2G), and related energy storage options to maximize the benefits of vehicular electrification.

e.    One immediate way the state might facilitate use of electric vehicles is through a state contract for electric school buses. Virtually all jurisdictions operate school buses, usually powered by diesel fuel. Diesel engines produce air pollutants right in the proximity of our most vulnerable, children between ages 5-18. Through the economies of a large-scale purchase, a state procurement mechanism for electric school buses could lower the price of electric buses to enable transition to this cleaner alternative more quickly than if each Virginia jurisdiction were to act alone.

f.    A few localities across the state have promoted voluntary bulk-procurement of rooftop solar electric systems by residents, either through a “solarize” campaign or a “co-op” effort (they vary slightly in format).  Also, some localities have pursued the U.S. Dept. of Energy’s SolSmart designation for removing local permitting hurdles to solar installations in their jurisdictions. The state should help promote more widespread use of these tools to help lower customer energy costs and locality permitting burdens. More widespread understanding of the ease and benefits of rooftop solar can be a catalyst for economic development in any community.

g.    Consider new financing mechanisms and opportunities for the energy sector, e.g., a statewide “green” bank, low-or-no interest revolving loan funds, collaboration with the real estate banking and agenting communities to create energy-enhanced mortgage and remodeling loan products, pay-for-performance pilots, and expanding zoning mechanisms that allow local jurisdictions to pilot and implement innovative energy programs.

4.  Establish the Virginia energy sector as a leader in adaptation, smart infrastructure, and resiliency planning

a.    The State is encouraged to collaborate with independent system operator PJM to actively study the benefits of a decentralized grid, grid modeling, and the integration of distributed energy resources (DER); more specifically, the benefits, costs and application of DER as well as the investments in the existing articulated grid to support optimal delivery of DER to consumers. Some transformation of the existing grid will be necessary to ensure reliable, consistent and sufficient DER delivery (such as large-scale solar and storage), and to address potential barriers such as reactive power, voltage support, and frequency regulation.

b.    There is value in the creation of a standing Grid Advisory Committee to assess aspects of DER, including but not limited to utility grid interfacing, energy storage, microgrids, and distribution system modeling. In addition, local governments are well-situated to facilitate public-private partnerships, ME&O, permitting, land use, and other administrative and managerial functions in piloting these strategies with utilities, tracking data, and providing proof-of-concept, demonstration, and best practices platforms.

c.    Incorporate adaptation science and studies into resource generation and infrastructure planning activities.

d.    Develop research on methane leakage from natural gas systems, to ensure that state goals for greenhouse gas reductions are not impeded.  For the last reported period (2017), the State derived 50% of its net electricity generation from natural gas. 

e.    Develop and implement stakeholder-driven road-mapping processes to facilitate commercialization of emerging DER technologies, e.g., demand-response, V2G integration, system improvements to enable high-penetration of renewable generation, microgrids, zero-net-energy biofuel cells, and energy storage.

f.    We encourage the DMME to enhance its partnership with the Governor’s Office of Commerce and Trade to host workshops and develop strategies for energy-centric economic development that establishes the state as a magnet for emerging technologies and to attract energy leadership enterprises.  Further, the State can attract greater and more diverse business and economic activity as a leader in energy innovation, progressive energy distribution systems, and energy adaptation, reliability, and resilience.


Demetra McBride, Chief, Office of Sustainability & Environmental Management

John Morrill, Energy Manager

CommentID: 66634