I am writing today on behalf of the Local Energy Alliance Program (LEAP) to provide comments on the 2018 Virginia Energy Plan. First, let me congratulate the administration on a well facilitated and helpful stakeholder process. We are greatly encouraged by the commitment of the Northam administration to continue improving our building’s efficiency, adding renewable technology, and looking for ways to reduce transportation emissions.

LEAP is a 501c3 organization headquartered in Charlottesville whose territory also includes northern Virginia. Since its inception, LEAP has established itself as a trusted leader in Virginia for home and business energy efficiency and renewables thanks to the relationships we have developed with our customers, contractors, local governments, and many other partners.

Homeowners struggling with high energy bills or uncomfortable houses, and business owners seeking to cut energy costs, come to LEAP for building science expertise and, when available, special rebates and loans to make energy upgrades more affordable.

As a trusted nonprofit, LEAP delivers direct education and services for improved energy performance to address climate change; create cost savings for families and businesses; healthier, safer, and more durable buildings; and local jobs and economic growth.

Our alliance model is a community-based, public-private partnership. Our programs help local governments meet their carbon emission reduction targets, improve the affordability and durability of our businesses and neighborhoods, and stimulate the local economy through job creation and retention. Energy efficiency improvements and renewable energy upgrades benefit the local economy first with local jobs, and secondly, by keeping utility costs down.

To that end, LEAP:

• provides energy evaluations of all building types including homes and businesses;
• provides low-income weatherization services funded by utilities;
• helps communities go solar with our Solarize campaigns that offer discounts and a streamlined process for homeowners and businesses to add solar energy systems;
• provides diverse sustainability services to local governments seeking to engage their constituents and implement clean energy technologies;
• hosts workshops and events and performs outreach to educate and empower the community on energy efficiency and clean energy topics; and
• engages partners around the Commonwealth to advance our transition to clean energy and fight climate change.

Our comments on how the 2018 Virginia Energy Plan can help LEAP with our mission are supportive of the four focus areas provided by the Department of Mines, Minerals, and Energy (DMME):

1. Achieving the 10% voluntary electricity reduction target

2. Developing lead-by-example strategies for state government

3. Initiating financing programs for energy efficiency projects

4. Exploring program design for DMME-managed programs

The recent passage of the Grid Modernization and Security Act of 2018 may generate some of these opportunities through its commitment by the IOUs to spend over $1B on energy efficiency programs. To ensure those funds are spent in the most effective and streamlined way, it is imperative that DMME has the ability to engage in the various processes related to utility filings before the State Corporation Commission (SCC). To that end, the state budget should continue to include funding for one FTE at DMME who is responsible for tracking and participating in SCC proceedings, including the energy efficiency stakeholder process as well as the Integrated Resource Planning process.

LEAP would particularly like to focus on the initiation of financing programs and exploring program design for DMME-managed programs.

Financing Programs

Beyond lack of knowledge, financing is one of the top barriers to retrofits and adding renewable energy systems. As the Virginia SAVES program lies dormant due to the new federal tax law, LEAP would like the administration to consider other ways to fund and use this well-branded program, for instance, we would be highly in favor of creating a statewide Green Bank, which has been so successful in states like Connecticut and Michigan. Other financial incentives that have worked well for our organization include interest rate reduction programs and revolving loan funds.

DMME-Managed Programs

As part of the proposed Virginia Carbon Rule, five percent of the emissions allowances generated will be allocated to DMME to invest in energy efficiency projects. As mentioned above, this set aside is an opportunity to continue funding the Virginia SAVES programs in order to invest in both public and private sector energy efficiency projects. Another suggestion would be to issue an RFP for a market rate or low-income EE program that fills a gap where Dominion and APCo cannot get programs approved.

Again, thank you for an excellent stakeholder input process and for the ability to provide these comments. We look forward to seeing the landscape change rapidly in the Commonwealth with the help of the Northam administration.

Sincerely,

Lesley Crowther Fore

Executive Director, LEAP