Virginia Regulatory Town Hall
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Department of Energy
 
Board
Department of Energy
 
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8/24/18  8:02 pm
Commenter: Joshua Griset

Nuclear Concerns, Weatherization Assistance, and Energy Efficiency Financing
 

My name is Joshua Griset. I am a long-time Virginian, a resident of Falls Church, public administration graduate student, and a fellow at George Mason University’s Center for Energy Science and Policy (CESP). I am pleased to provide comments on the 2018 Virginia Energy Plan and wish to thank you for providing a 60-day public comment period to ensure that citizens have a voice in the plan’s development.

                        

I. Introduction

My comments pertain to several program areas that it would behoove Virginia to fund in the short-term, as well as the long-term to safeguard our natural resources, ensure efficient energy usage, and provide the public a sound path forward in a changing climate. Virginia must:

 

  • Create a contingency plan in the event nuclear facilities shut down permanently;
  • Expand the Weatherization Assistance Program;
  • Create financial mechanisms to fund renewables and increase energy efficiency;
  • Incentivize retrofit programs, especially at the point of sale;
  • Increase efficiency in building codes;
  • Modernize the energy grid to improve the supply-side efficiency of power plants and the grid generally; and,
  • Make Virginia a RGGI state and find a way to allow RGGI funds to go to efficiency and renewable programs.

 

II. Contingency Planning for if Nuclear Facilities Close

Virginia must ensure there is a contingency plan for if nuclear facilities within the state shutdown.

 

Nuclear power plants are having a hard time competing with natural gas and renewables. When nuclear plants permanently shut down communities ask:

 

  • What is the plan for the nuclear waste stockpiled on the facility?
  • What do we do with the radiated facility?
  • Or, rural community is losing high net worth jobs, impacting our economy, how will we be compensated?
  • What is the plan?

 

Often there is no plan, leaving communities in the lurch.

 

I hope the facilities in Surrey and Northern Neck stay open, but Virginia must ensure there is a plan in place for the nuclear waste and radiation if those facilities close down.

 

III. Expand the Weatherization Assistance Program

Winter is coming. Virginia must expand the Weatherization Assistance Program. Last winter was so cold that Dominion sent a preemptive press release warning customer of a significant increase to their bill. However, some increases were more significant than others.

 

The poor tend to live in older homes, which are less efficient and not as well insulated to the effects of weather.  When winter comes, this means that many will pay electric bills that are not just higher, but also much higher than everybody else’s. This past winter some Virginians had bills that were over three times the normal amount, to over $500. 

 

According to a 2016 Federal Reserve study, 46% of Americans do not have more the $400 in emergency savings.

 

There was a media response, and Dominion was kind enough to offer a payment plan to those who needed it after this winter.  But, at best it was a Band-Aid. It is not enough. Winter is coming. Virginia must redouble its efforts with its Weatherization Assistance Program.

 

IV. Create Financial Mechanisms to Fund Renewables and Increase Energy Efficiency

If a lump of coal had 100 units of energy, when burned in a coal plant it would lose roughly 70% of its energy in the process of creating electricity. Then once in the grid, it loses another 70% from transmissions loses due to distance, substations, transformers, etc. Then the building will be as efficient as they happen to be. An incandescent light bulb will only use 1-2 units of the original energy potential from the lump of coal with 100 units; the other 98-99% is wasted.  This is a real waste; we must become more efficient.

 

Energy Efficiency is the cheapest, cleanest, most readily available way to balance budgets, put money back into the pockets of citizens, reduce the need for new energy infrastructure, and fight climate change.

 

A common critique of energy efficiency initiatives is “If they are so great, then why do we let the market figure it out? Why do need efficiency programs?” I myself am a capitalist. But capitalism is not without its market failures or holes in the market design that prevent the advancement of an obvious good.

 

One market failure is called the “split incentive” or as I call it “the Renters Dilemma.” There is a lack of incentive for owners to invest, and a disenfranchisement by those who need the investment most, the renter (whether commercial or residential). The landlord does not pay the energy bill; the construction company does not pay the energy bill, the energy company does not pay the energy bill, the renter does.

 

A renter in a house may spend $30 on fancy light bulbs, but they are not going to pay $1000 for a new water heater, or $3000 to insulate the house.  The renter is not incentivized to invest in a home they may move out of in a year, besides…. it isn’t their property. Likewise, landlords, construction, and energy companies are not incentivized to make buildings more efficient because they do not pay the energy bill, least of all energy companies who stand to make a profit from lack of efficiency.

 

Another market failure is the lack of financial products for renewables and energy efficiency upgrades available in Virginia.  The lack of financing opportunities and diversity of financial product hinder homeowner/landlord investment. When you finance it, renewable/efficiency investments will come. Some programs that must either be expanded/permitted in Virginia are:

 

  • C-PACE-Commercial Property Assessed Clean Energy
  • R-PACE- Residential Property Assessed Clean Energy
  • PPA- Purchase of Power Agreement
  • EPA- Energy Purchase Agreements (EPAs)
  • ESA- Energy Service Agreements
  • ESPC- Energy Savings Performance Contract
  • Green Banks

 

V. Join the Regional Greenhouse Gas Initiative

Make Virginia a Regional Greenhouse Gas Initiative (RGGI) state and find a way to allow RGGI funds to go to efficiency and renewable programs. While RGGI is up for approval, Virginia must find a way to reconcile the constitutional issues (with RGGI and the SCC) to permit RGGI to fund energy efficiency and renewable programs. RGGI has provided states with hundreds of millions of dollars each year for such programs to be spent in their state.

 

VI. Conclusion

To safeguard our natural resources, ensure efficient energy usage, and provide the public a sound path forward in a changing climate, Virginia must fund programs that:

 

  • Create a contingency plan in the event nuclear facilities shut down permanently;
  • Expand the Weatherization Assistance Program;
  • Create financial mechanisms to fund renewables and increase energy efficiency;
  • Incentivize retrofit programs, especially at the point of sale;
  • Increase efficiency in building codes;
  • Modernize the energy grid to improve the supply-side efficiency of power plants and the grid generally; and,
  • Make Virginia a RGGI state and find a way to allow RGGI funds to go to efficiency and renewable programs.

 

Thank you for consideration of my comments.

 

Sincerely,

Joshua Ian Griset

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