The Mid-Atlantic Renewable Energy Coalition (MAREC) would like to express its appreciation for being able to submit these comments on Virginia 2018 Energy Plan.  We commend the Commonwealth for its work on this extremely important effort.  MAREC will focus its comments to the development of renewable energy in Virginia and the surrounding region.

MAREC is a nonprofit organization that was formed to help advance the opportunities for renewable energy development primarily in the region where the Regional Transmission Organization, PJM Interconnection, operates.  MAREC’s footprint includes Virginia and eight other jurisdictions in the region.   MAREC members include utility scale wind and solar developers, including offshore wind developers, wind turbine manufacturers, and non-profit organizations dedicated to the growth of renewable energy technologies.  MAREC members have developed, owned, and operated thousands of megawatts of renewable energy serving the PJM territory.  MAREC members are developing wind and solar projects in Virginia.

As indicated, MAREC is focused on renewable energy development.  MAREC believes that Virginia is a ripe area for development of both utility scale solar and wind development.  To the extent that the Commonwealth can facilitate development of these resources the better.  We are very encouraged by the passage of Senate Bill 966 in 2018, which among other things considers over 5000 MW of solar and wind energy to be “in the public interest.”  Both the General Assembly and the Governor deserve a great deal of credit for getting the bill over the goal line.  With this recent development, both wind and solar developers have taken notice and now consider Virginia a state in play for renewable energy development.  One key aspect of this bill enactment is that the Commonwealth must move from the legislative process to an implementation process related to facilitating fair siting of developments, ensuring that there is strong buy in from the Virginia Electric Power Company and the Appalachian Power Company to actually get 5000 plus MW in the ground and having agencies like the State Corporation Commission approve projects that facilitate the intent of the legislation.  MAREC will focus on a couple of Areas: solar and onshore wind; offshore wind; and the PJM grid’s ability to accept many more GW of wind and solar energy than SB 966 specifies.  This applies to Virginia and the PJM region in general.

Solar and Onshore Wind

It appears that Virginia has opened its doors to the development of solar and onshore wind.  Implementation is critical to the success of this new effort.  We suggest, that from the siting process through the project approval process, the Commonwealth should utilize whatever tools it has to ensure that the public interest as intended in SB 966 is met.  The following are several recommendations to meet the renewable energy goals of SB 966:

• The Department of Environmental Quality (DEQ) should continue to refine its Permit by Rule regulations to ensure fair and consistent rules for permitting renewable energy projects of 150 MW or less.  We commend for its efforts to date as they have established a working mechanism to efficiently get projects through the permitting process.  As with any process, improvements can be made.  We understand that the DEQ will be moving forward soon to reopen the regulations for potential revision and we support that effort.

• The appropriate Commonwealth agencies should provide any necessary assistance to developers and localities, where projects have requested to be sited, to encourage fair development, while at the same time responding to the concerns of the localities with information and counsel on how to work through the local siting process.

• The Commonwealth should monitor the process for getting applications for project approvals through the State Corporation Commission (SCC).  The purpose of this recommendation is to make sure there is sufficient progress in getting renewable energy projects approved as contemplated by SB 966.  To the extent that a lack of progress is identified, then the impediments to that progress should also be identified and; a process to determine how improvements to this implementation issue can be made.  These improvements could be developed though additional legislation, Executive Order, a request to have the SCC review its own approval process, or by other means deemed appropriate.

• There should be strong encouragement of third-party, renewable energy, purchase power agreements for large commercial and industrial customers.  Many of these customers desire these arrangements as part of their corporate sustainability goals.  These agreements are also sought after by these entities as a result of lower and stable pricing for renewable energy, primarily solar and wind energy, which have no fuel costs.  These corporate customers often, in part, make the decisions on siting and expansion of corporate offices and other facilities based on the availability of these types of agreements and state policies supporting renewables.  Right now, there are limitation on these types of agreements because of the Commonwealth’s regulatory scheme stemming in part from restrictive statutes.

Offshore Wind

Virginia has a vast resource for offshore wind.  The Commonwealth has already taken a number of key steps in the effort of becoming an offshore wind hub, including targeting this issue in the State Energy Plan, as well as the Department of Mines, Minerals and Energy’s (DMME) efforts to leverage the vast energy resources into becoming an offshore wind manufacturing hub.  The economic development impacts of this resource could be a huge economic boon to Virginia, but it also would be another substantial tool in its arsenal for carbon reduction efforts.

• MAREC believes that it is key that Virginia continue to support Dominion Energy's Coastal Virginia Offshore Wind project.  The project can be the gateway for the development of massive amounts of offshore wind capacity off the coast. 

• DMME should continue its important efforts to help develop a strategic plan to encourage the development of the industry comprising of both offshore wind projects and related supply chain.

• As is the case with newer energy technologies, there is often a cost curve reflecting some higher pricing earlier in the development of the technology, but then leading to wider-scale deployment and efficiency, which end up driving prices downward.  In the case of offshore wind, which has been widely deployed in Europe, we are already seeing significant reductions in cost in the United States, as the results of other state solicitations are becoming public.  In Massachusetts, pricing from the accepted bid from its initial offshore wind solicitation has been reported as low as S74 per MWh for the first year of operation of the project.[1]   

PJM Grid

The beauty of the grid in Virginia is that it is part of a much broader grid that brings to bear vast generation and transmission capabilities.  It is critical to understand that the PJM grid can integrate vast resources of renewable energy in Virginia and regionally and continue to operate effectively.  In 2014, PJM investigated what its system could reasonable bear as it relates to wind and solar energy penetration and concluded that: “[t]he study findings indicate that the PJM system, with adequate transmission expansion and additional regulating reserves, will not have any significant issues operating with up to 30% of its energy provided by wind and solar generation.”[2]  Virginia and the PJM grid have a long way to go before they reach a 30% penetration level. We note that this study did not investigate the impact of energy storage to its system, which would surely improve penetration levels considered in the study.

As far as the grid is concerned, Virginia should not consider it to be an obstacle for including substantially greater amounts of renewable energy.  The system has the ability to call on its vast resources to balance any additional resources contemplated by the Commonwealth.   

MAREC again wants to express it appreciation for our ability to comment on the Energy Plan.  Please feel free to reach out to MAREC to gain a better understanding of our organization and any help we can offer as the Commonwealth navigates its way through its Energy Plan process.

[1] https://www.greentechmedia.com/articles/read/first-large-us-offshore-wind-project-sets-record-low-price-starting-at-74#gs.O0wm5II

[2] PJM Renewable Integration Study, Executive Summary Report, Revision 5 at 6-7 (Mar. 31, 2014), available at http://www.pjm.com/-/media/committees-groups/subcommittees/irs/postings/pris-executive-summary.ashx?la=en