August 24, 2018
Department of Mines, Minerals, and Energy
3405 Mountain Empire Road
Big Stone Gap, Virginia 24219
COMMENTS OF THE ADVANCED ENERGY BUYERS GROUP
THE 2018 VIRGINIA ENERGY PLAN
The Advanced Energy Buyers Group (“AE Buyers Group” or “Buyers Group”) respectfully submits written comments for consideration by the Department of Mines, Minerals, and Energy (DMME) as it compiles the 2018 Virginia Energy Plan. These comments reflect our experience as large energy customers in the Commonwealth, and specifically as customers pursing advanced energy technologies and services to meet our energy needs, including renewable energy, energy storage, energy efficiency, demand response, electric vehicles, and more. Given this perspective, we advocate for an energy system in Virginia that (1) includes flexible and cost-effective options for all customers to purchase advanced energy, especially large commercial and industrial customers; and that (2) ensures that all utility investments in maintaining reliable, clean, and affordable electricity are prudent and cost-competitive, and that they deliver positive quantifiable benefits to all Virginia customers—preparing the Commonwealth for the future by embracing innovation, saving consumers money, and minimizing the risk of future stranded assets. An energy system that embraces customer-driven growth of clean energy and that encourages innovation will meet the needs not only of our companies, but of all Virginia customers.
ABOUT THE ADVANCED ENERGY BUYERS GROUP
The Advanced Energy Buyers Group is a business-led coalition of large energy users engaging on policies to expand opportunities to procure energy that is secure, clean, and affordable. Members of the Buyers Group are market leaders and major employers spanning different industry segments, including technology, retail, and manufacturing. Our companies are among the 71% of Fortune 100 companies and 43% of Fortune 500 companies that have established renewable and/or climate targets as part of our corporate sustainability commitments. We share a common interest in expanding our use of advanced energy, such as renewable energy like wind, solar, geothermal, and hydropower; demand-side resources like energy efficiency, demand response, and energy storage; and onsite generation from solar photovoltaics, advanced natural gas turbines, and fuel cells.
In 2017, members of the AE Buyers Group totaled over $1.2 trillion in revenue and collectively consumed over 18 terawatt hours (TWh) of electricity, including over 11 TWh of renewable electricity, equivalent to the electricity sales for the states of North Dakota and Delaware, respectively. This collective electricity use includes a significant footprint in Virginia. The members of the AE Buyers Group are united by six guiding principles:
In the comments that follow, the AE Buyers Group provides recommendations to bring Virginia’s energy system into better alignment with these guiding principles.
The AE Buyers Group supports an energy system in Virginia that responds to the needs and preferences of customers seeking to address their own energy needs with advanced energy, while also ensuring that the system as a whole enables and encourages innovation, technology adoption, and increased reliability without sacrificing on affordability.
I. Virginia should enable commercial and industrial customers to meet their energy needs, preferences, and goals by providing options for customers to purchase renewable energy and other advanced energy technologies and services.
Virginia is a growing technology hub, and home to strong manufacturing, industrial, and retail sectors. As the companies powering Virginia’s economy increasingly pursue renewable and other advanced energy resources to meet their electricity needs, the Commonwealth should position itself to satisfy this shifting corporate demand. Doing so will not only meet the needs of businesses such as members of the Buyers Group, but also unleash investment that will modernize Virginia’s energy infrastructure.
Virginia has made good progress toward enabling corporate renewable energy procurement, and has the opportunity to build upon this strong foundation to secure a true leadership position. Specifically, the Commonwealth has made progress to date in the following areas:
However, Virginia still falls short of meeting the first two guiding principles set out by the Buyers Group. Namely, customers in the Commonwealth lack sufficient variety of choices to meet their advanced energy goals, and not all customers of different sizes and profiles have access to solutions that meet their needs and preferences. To address these shortcomings, Virginia should prioritize the following reforms:
Implementing these reforms through the Virginia Energy Plan will bring the Commonwealth much closer to meeting the needs of a range of commercial and industrial customers.
II. Virginia should ensure that utility investments in maintaining reliable, clean, affordable electricity are prudent and cost-competitive, and that they deliver positive quantifiable benefits for all Virginia customers while avoiding risk of future stranded assets.
As large energy users dependent on reliable and affordable electricity, we also support efforts to lower costs, increase clean energy deployment, embrace innovation, and increase system flexibility, reliability, and resilience. This applies not to our own operations and corporate decisions, but to investments and actions by utilities and system operators at the direction of or with the support of regulators, policymakers, and other key decisionmakers.
The sixth and final guiding principle of the AE Buyers Group states, “Federal and state market and regulatory structures should enable innovation and cost efficiencies, and should facilitate the transition to a more secure, flexible, clean, and affordable energy system.” This principle reflects the fact that large customers are impacted not only by their ability to make direct energy purchases and investments, but by the broader electricity system that serves them. Specifically, the electricity system directly impacts our electricity costs, the emission profile of our utility-delivered electricity, and the reliability of the electricity system that serves our facilities. In addition, market and regulatory conditions can result in logistical and financial barriers (or opportunities) for our own advanced energy purchases.
In our own operations, we have seen that a diverse mix of advanced energy technologies and services—including investments in energy efficiency, participation in demand response programs, use of electric vehicles, reliance on energy storage, and purchase of onsite and offsite renewable energy—can lower costs and create new revenue streams while supporting a more diverse, flexible, and responsive grid. Given the rapid advances in cost and performance for energy storage, renewable energy, demand response, smart grid technologies, electric vehicles, and energy efficiency, we strongly support efforts to prioritize deployment of these cost-competitive resources to meet resource needs in the Commonwealth. Specifically, we support an electricity system in Virginia that:
An electricity system focused on innovation and customer participation will result in improved affordability, reliability, flexibility, and resilience—to the benefit of all Virginia residents.
As businesses seeking renewable and other advanced energy to meet our own energy needs in the Commonwealth, and as customers dependent upon a reliable, flexible, responsive, and affordable grid, members of the Advanced Energy Buyers Group support forward-looking efforts to identify improvements to Virginia’s energy system. The AE Buyers Group appreciates the opportunity to provide input on the 2018 Virginia Energy Plan, and we respectfully request DMME’s consideration of our perspective.
The Advanced Energy Buyers Group
 These comments represent the consensus view of the Advanced Energy Buyers Group, but do not necessarily reflect the position of any individual company.
 See PJM Interconnection, “PJM History,” available at https://www.pjm.com/about-pjm/who-we-are/pjm-history.aspx
 Advanced Energy Economy and Virginia Advanced Energy Economy, Customer Renewable Energy Options in Virginia (June 2018), https://info.aee.net/renewables-options-for-virginia.