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8/24/18  2:58 pm
Commenter: Michael Town, Virginia League of Conservation Voters

Virginia LCV comments re: 2018 Virginia Energy Plan

To: Department of Mines, Minerals, and Energy

From: Michael Town, Virginia League of Conservation Voters

Date: August 24, 2018

Re: Comments on the Virginia Energy Plan

Thank you for the opportunity to comment on Virginia’s 2018 Energy Plan. This outline has the potential to drive Virginia’s energy policy for years to come and the Commonwealth is truly at a pivotal turning point in how we generate, transmit, and distribute energy.

As an organization, Virginia LCV’s goal for Virginia is to achieve 100 percent clean energy by 2050. We view this plan as playing a key role in achieving this goal, as the steps we take over just the next few years could have long-term impacts on Virginia’s energy future.

Our comments for the Energy Plan will focus on the Grid Transformation and Security Act of 2018, or Senate Bill 966, which was signed into law in July. This legislation has the potential to completely change our electricity makeup in Virginia. If implemented correctly, this law will see the fastest acceleration of renewable energy and energy efficiency gains we’ve ever seen. If implemented poorly, however, Virginia ratepayers could be on the hook for massive costs with minimized environmental benefit.

This is why Governor Northam, through executive action, should commission an independent oversight entity to convene stakeholders, perform an in-depth analysis of Virginia’s electricity generation infrastructure and current regulatory framework, and prepare a final report on how to adequately modernize our grid and electric utilities in a way that benefits ratepayers and our environment, and fosters economic growth.

SB 966 put the future of this massive overhaul into the hands of electric utilities that benefit most through the construction of infrastructure that’s often unnecessary. By leaning on independent recommendations and involving the general public and stakeholders, we can better ensure the spirit of this law is executed thoroughly and lives up to its promises of cutting carbon pollution by adding renewable energy and increasing energy efficiency.

The independent body should evaluate whether grid modernization in Virginia takes into account the following:

  • Greater opportunities for competitive sourcing of energy and customer choice when it comes to purchasing electricity;
  • Increased use of distributed energy sources and non-centralized energy generation;
  • Increased use of renewable, carbon neutral energy sources;
  • New energy and environmental policies, especially those designed to curb climate-disrupting climate emissions;

A big part of making the grid modernization effort work for Virginians is following through with its ambitious energy efficiency goals.

The Northam Administration, by executive order, should reconstitute the Executive Committee on Energy Efficiency and task it with ensuring utilities maximize cost-effective EE portfolios, identifying best practices to ensure utility grid modernization investments lower customer bills, and making sure that utilities’ carbon allowance revenues are reinvested to customer benefit for efficiency.

In order to ensure the utility EE investment commitments under the grid modernization effort are effective, Virginia’s legislature should convert the state’s currently ineffectual energy efficiency goal into a mandatory EE resource standard, at an annual ramp-up rate of .2% reduction in total retail sales beginning in 2020, until 2% annual savings is reached and maintained.

By acting in this way, we can ensure we take full advantage of our cleanest energy resource – the energy we don’t use.

Virginia has the opportunity to truly transform how we generate and distribute electricity, but we need to get it right. The Northam Administration should take an increased role in guiding this process from the start to put it on the right trajectory, one that will result in a healthier environment and economy. 


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