Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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8/24/18  9:09 pm
Commenter: Alexandra Wyatt, Policy & Regulatory Mgr. - Mid-Atlantic, GRID Alternatives

Prioritize Low- and Moderate-Income Access to the Clean Energy Economy

GRID Alternatives is a leading voice for low-income solar policy and the nation’s largest non-profit solar installer, serving low- to moderate-income (LMI) families and affordable housing owners through residential, multi-family, and community/shared solar installations. GRID Mid-Atlantic, a regional affiliate of GRID Alternatives, is based in Washington, D.C. and serves the District of Columbia, Maryland, Delaware, and Virginia. Using a “barn raising” installation model, GRID Mid-Atlantic trains and leads teams of local job trainees and other community members to install solar electric systems for our clients, in partnership with our network of affordable housing developers, energy efficiency providers, local government agencies, workforce development programs, and solar industry partners. GRID Mid-Atlantic has installed over 180 solar systems in Virginia, Maryland, and the District of Columbia—saving LMI families $4.5 million, providing nearly 750 people with hands-on solar training, and preventing nearly 25,000 tons of greenhouse gases (GHGs) from entering the atmosphere. GRID Mid-Atlantic is pleased to have the opportunity to comment on Virginia’s 2018 Energy Plan in support of an inclusive and equitable renewable energy transition. 


GRID Mid-Atlantic advocates for a targeted, equitable approach for expanding access to solar and renewable energy in Virginia. Virginia has made progress but has significant work to do to reduce inequality within its renewable energy policy and programs. LMI families are disproportionately impacted by utility bills and energy-related pollution, and often do not have the same access to the growing clean energy economy.[1] The following principles should guide the drafting of the 2018 Energy Plan’s recommendations, and of future rules and programs to enable LMI customer access to solar, renewable energy and clean technologies in Virginia:

  • Providing access to solar for Virginia’s LMI families can create myriad positive impacts and significant benefit for the Commonwealth’s highest need communities.
  • Low-income customer solar and renewable energy adoption requires dedicated incentives tailored to the needs of low-income customers.
  • LMI customers in all housing types should be able to access the benefits of both onsite and offsite solar.
  • Virginia should invest significantly in renewable energy for underserved market segments, as well as in energy storage, electric vehicles and other renewable technologies. Grants, financing, and technical assistance can enable industry and nonprofit partners to facilitate LMI solar project development.
  • Up-front incentives are the most common way of ensuring low-income solar participation and direct benefit throughout the country because up-front cost is typically the largest barrier that low-income customers face for solar program participation. Low-income customers often do not have credit scores or a risk profile required to access loans or other project financing.
  • Bill savings is the most direct benefit for LMI customers, and one of the most crucial factors for a successful program. Incentives should be designed to ensure that LMI customers can experience significant bill savings, typically defined as 50% or more.
  • To ensure dedicated attention to consumer protections and creating maximum customer benefits, low-income solar programs should be administered by a third-party administrator experienced with low-income solar energy programs, such as a nonprofit or government entity.
  • Energy procurement practices should support workforce development in disadvantaged communities, as well as inclusion and diversity in the workforce.
  • The most effective low-income solar programs include:
    • long-term, dedicated funding; elimination of up-front costs;
    • integration with energy efficiency offerings;
    • seamless linking with existing energy assistance programs;
    • direction and funding for community education and engagement;
    • job training and placement opportunities;
    • built-in, robustly enforced consumer protections; and
    • other components to specifically address the barriers faced by low-income participants.

Cross-Cutting Strategies for Solar Energy in the 2018 Energy Plan

The most urgent factor that should shape the analyses and recommendations in Virginia’s 2018 Energy Plan is that climate change is already hurting the most vulnerable Virginians. Several severe weather-related Declarations of a State of Emergency this year in Virginia and elsewhere previewed the increasingly unstable climate future that is likely if GHG reductions are not undertaken quickly enough. LMI communities, which already face disproportionately high energy burdens and environmental justice issues, will face even higher disruptions and costs if our shift to clean energy is too small or too slow. Virginia should do its part for greenhouse gas mitigation efforts, not only because it is the right thing to do, but also because the energy transition presents substantial opportunities to improve equity, social and environmental conditions, and the economy within the Commonwealth. Solar is particularly essential to that energy transition.[2]

GRID Mid-Atlantic believes that incumbent utilities can benefit from an inclusive energy transition as well. Regardless, the Commonwealth must prioritize its people and climate first, even over utilities’ objections or preferences for an untenable status quo. If structural changes to Virginia’s energy market and regulatory frameworks are necessary to correct misaligned incentives and expedite clean energy, then Virginia’s elected and appointed officials should boldly make those changes happen.[3]

Virginia’s 2018 Energy Plan should consider a diverse range of strategies to promote clean, renewable energy. Strong, mandatory renewable portfolio standards have been important tools for spurring clean energy investments and promoting a clean energy transition in other states. Some states, like Massachusetts, assigned a higher value Solar Renewable Energy Credit (SREC) to projects serving low-income customers. Using revenue or diverting Alternative Compliance Payments or ratepayer funds to low-income solar programs and projects has also been utilized in a few markets, including the District of Columbia, New Hampshire, Colorado, and Illinois. Importantly, any carbon pricing or trading strategy must be developed with the input and close collaboration of a wide range of stakeholders, particularly from communities that already face disproportionate energy burdens or that would be disproportionately affected by product or service price increases. These communities have not contributed as much to the problem of climate change, yet have suffered disproportionately from traditional power generation. Targeted incentives are necessary to ensure that low?income consumers do not end up paying for the costs of carbon regulation through their electricity bills without also receiving the benefit of revenue, if any, from carbon pricing or allowance auction proceeds.[4]

Virginia should also consider raising its net energy metering cap, currently only 1 percent of a utility's adjusted peak-load forecast for the previous year. Many other states have an aggregate capacity cap for net energy metering of at least 5 percent of a utility’s load, or no aggregate capacity cap at all.[5] Maximizing the proceeds of net energy metering, along with minimizing fees and streamlining approval procedures, will allow GRID Mid-Atlantic to provide more electricity bill savings to our LMI rooftop solar clients and community solar subscribers. Conversely, crediting solar energy at anything less than the full retail rate, especially for LMI community solar subscribers, is yet another technical and financial barrier that reduces the savings they may receive from solar.

Single-Family Rooftop Solar

Currently, Virginia’s solar programs under-emphasize smaller distributed energy resources such as individual households’ rooftop solar, instead focusing on commercial, industrial, and utility-scale renewable energy.[6] GRID Mid-Atlantic believes this is a significant missed opportunity for LMI Virginians. Not only does rooftop solar have immediate financial and other benefits for homeowners, it also promotes more jobs. LMI rooftop solar programs can be integrated with energy efficiency and energy assistance programs, and are best when strongly supported by community engagement and consumer protection efforts. As noted above, the most important considerations for LMI involvement are immediate, significant bill savings and very low or no up-front cost. To enable project developers to deliver these benefits to LMI clients, Virginia’s 2018 Energy Plan should encourage the expansion of policies such as third-party ownership and targeted funding and financing support.

Additionally, Virginia’s statutory provisions regarding solar rights[7] should be strengthened, clarified, and publicized. Grid Mid-Atlantic urges the Governor and Virginia agencies to work with the Virginia Legislature to remove the grandfathering of covenants; narrow the kinds of “reasonable” limitations that community associations can impose; and engage in targeted outreach to make sure Virginians, especially LMI families, know their rights.

Multi-Family Residential and Community Solar

Community solar is an important option for people who want to go solar but cannot, whether because they rent their homes, or because of structural or shade issues, or for other reasons. Community solar projects can offer significant value to LMI subscribers, including financial benefit, training and community engagement opportunity, as well as additional environmental and social benefits. Unfortunately, Virginia’s legal framework is not very conducive to competition, innovation, or rapid scaling in community solar. For example, it does not facilitate ownership models other than utility-owned and -controlled community solar. This should change.[8]

Virginia’s 2018 Energy Plan should consider virtual net metering; different types of owners and program administrators in addition to utilities; differential incentives for LMI subscribers; alternate financing considerations such as back-up guarantees, low-cost public financing, and/or on-bill financing; and LMI carve-outs or SREC multipliers, among other policies, to enable community solar in Virginia to reach its full potential.[8] In GRID’s experience, standalone low-income solar programs work best. Policy leadership from Virginia agencies also can guide utilities and developers to identify sites ideal for interconnection, and to give preference to certain types of sites (e.g., brownfields) for LMI community solar.

Solar Energy Workforce Development

Training the next generation of Virginia’s energy workers is both a crucial input, and a prime benefit, of expanded deployment of renewable energy. Solar jobs have many advantages, including a growing industry (seven times the overall state economy[9]); high pay; and wide geographic distribution across the Commonwealth. However, Virginia ranks 31st in solar jobs per capita.[9] Virginia’s 2018 Energy Plan should focus on making sure that individuals from disadvantaged communities have at least proportionate access to these opportunities. Toward this goal, Virginia’s energy and environmental agencies should partner with entities, including nonprofits and other government agencies, that have strong workforce development experience.

Financing Solar Energy

Having a variety of financing models available broadens the possibilities for low-income solar, including through nonprofits like GRID Mid-Atlantic. Broadly accessible or LMI-targeted green bank programs, loan guarantee programs, tax incentives, third-party ownership and power purchase agreement (PPA) options, and other mechanisms have all been used successfully in other states, and should be considered in Virginia’s 2018 Energy Plan.

States can also leverage federal funding for low-income solar. Examples of federal funding that has supported solar in some states include the Weatherization Assistance Program (WAP) and (LIHEAP). Using such funding for solar energy can eliminate the need to spend future public funds on ongoing assistance for the solar beneficiaries.[10]

Electric Vehicles and Solar Electricity

GRID Mid-Atlantic is encouraged that the Virginia Department of Environmental Quality (DEQ) intends to use Volkswagen settlement funds to develop a statewide public electric vehicle charging network. Again, we urge DEQ to implement this network in a way that actively and specifically targets LMI families and ensures that they are not excluded from access to clean, low-maintenance electric vehicles. Electric vehicles also offer opportunities to promote distributed solar energy resources and enhance their grid benefits, so Virgina should consider electric vehicles and solar policy in tandem to maximize their complementary benefits. By pairing electric vehicles with solar power, Virginia can help LMI families swap gasoline for sunshine. Communities can produce their own transportation fuel and keep that money in the community, while reducing GHG and air pollutant emissions in their neighborhoods.[11]


Virginia has many options for its energy future. Extending the previous governor’s “all of the above” approach to energy sources[12] is not a feasible option—not in the long run, and perhaps not in the near future, either. Virginia’s 2018 Energy Plan should be a Clean and Equitable Energy Plan. This necessitates planning for a renewable energy transition, of which solar electricity, made accessible to LMI families and communities through targeted policies, should be a core component.

Inclusive solar policy addresses many of the objectives of the Energy Policy of the Commonwealth set forth by the Legislature including lower costs; stable prices; local production and energy independence; reliability and resilience; natural resource conservation; protection of pristine natural areas; pollution reduction (including GHGs and unhealthy air pollutants); and avoiding the disproportionate adverse impacts on economically disadvantaged or minority communities that traditional energy sources impose.[13] Moreover, solar provides excellent opportunities for workforce development in underserved communities, offering quality careers to those who need them most. However, these objectives are only possible with ambitious action from Virginia’s leadership. For the sake of all current and future Virginians, GRID Mid-Atlantic hopes that Virginia’s 2018 Energy Plan lays the groundwork for a climate-focused, swift, inclusive, and just transition to clean energy.

Thank you for the opportunity to provide these comments.


Alexandra M. Wyatt

Policy and Regulatory Manager

GRID Alternatives



[1] See;

[2] See

[3] See

[4] See;;

[5] See generally

[6] Va. Code § 56-585.1:4.

[7] Va. Code §§ 67-700, 67-701.

[8] See;;


[10] See

[11] See


[13] Va. Code §§ 67-100.1; 67-101.1-13; 67-102.A.1, .6, .8; 67-201.A-C.

CommentID: 66712