Virginia is not a leader by any measure as it relates to renewable energy generation (distributed and utility scale), mandatory clean carbon free policy standards, and incentives to transition away from fossil fuel use.  By the same measures our utilties are not only not leaders in a move towards a clean carbon free energy future they fight it tooth and nail and it's time for that to change.  While there are numerous policies and programs that can be implemented as I'm sure is being demonstrated in other comments received, here are some of my suggestions for inclusion in the updated Virginia Energy Plan:

Mandatory Renewable Portfolio Standard (RPS):

- Require utilities to adhere to a mandatory RPS that requires renewable carbon free energy to be a significant percentage of the electric power generation portfolio (RPS is currently optional)

- Increase the percentage of renewable carbon free energy required by the RPS over time to keep growing the quantity of renewable carbon free energy available to customers

- The optional RPS is basically ignored by the utilities and they continue to build fossil fuel transport and generating infrastructure that risks being stranded but still paid for by the rate payers

Mandatory Clean Peak Standard (CPS):

- Require utilities to adhere to a mandatory CPS which requires a certain percentage of delivered electricity during peak demand periods to come from carbon free generation resources to continue to expand clean energy generation while reducing electricity costs and making it easier to meet peak demand without fossil fuel peaker plants

- This is a recent concept that builds on the RPS and is being considered in several other states

 
Independent Non-Wire Alternatives (NWA) Analysis:

- Require utilities to engage an independent NWA analysis whenever new transmission, distribution, or generation infrastructure is proposed to detemine if cleaner less expensive alternatives such as energy efficiency, battery storage, demand response, and other related investments cost less and could be used to defer or preclude the building of expensive infrastructure

- Requre utilities to submit the results of the independent NWA with all SCC filings for approval of grid and generation infrastructure

Tariffs

- Require utilities to offer tariffs that include incentives such as time-of-day rates to shift electricity use to off-peak hours

- Require utiities to offer tariffs for charging electric vehicles during off-peak hours

- Require utilities to offer tariffs for municipalities including schools that incent the adoption and transition to electric vehicles including passenger cars, municipal and school buses, and other types of vehicles purchased or leased by local jurisdictions

Energy Efficiency:

- Virginia is far behind other states in promoting energy efficiency and as a result is wasting energy, paying higher utility bills, and suffering air, water, land, and climate pollution

- Energy efficiency is the least expensive energy resource and Virginia should have mandatory energy efficiency policies that require and / or incentivize greater levels of energy efficiency from our utilities

- Require stronger energy efficiency standards for new buildings, retrofits, appliances, and lighting

Transportation Electrification:

- Electric vehicles (EVs) are cleaner today than conventional cars even after accounting for emissions from the electricity used to charge them; as the grid shifts to 100% renewable sources of electricity, EVs become 100% clean; they offer immediate reductions in local particulate pollution, particularly as compared to old diesel vehicles

- Implement programs to incent and help fund a transition to electrified transportation for local jurisdictions that own and lease vehicles including municipal and school buses

- Transportation is the largest source of greenhouse gas emissions in Virginia and state policy should incentivize EV use and develop the infrastructure needed for large-scale adoption to reduce both particulate and greenhouse gas emissions

Thank you for your consideration.

Steve Banashek, Alexandria VA