August 24, 2018

John Warren

Director, Virginia Department of Mines, Minerals and Energy

Washington Building

1100 Bank Street, 8th floor

Richmond, Virginia 23219

RE:  U.S. Green Building Comments for the 2018 Virginia Energy Plan

Dear Director Warren,

On behalf of the U.S. Green Building Council (USGBC), a non?profit organization with 12,000+ member companies nationwide, and our strong community in Virginia, we are pleased to provide our comments regarding the 2018 Virginia Energy Plan Update.

USGBC is committed to transforming the way buildings and communities are designed, built and operated through high-performaning, cost effective, green buildings that save energy, water and money. We urge the Northam Administration to make energy efficiency a priority resource in the State of Virginia. Energy efficiency measures provide wide-reaching benefits to all Virginians including: saving money, conserving resources, and achieving the environmental and economic development goals the Commonwealth. 

About USGBC

USGBC is a nonprofit organization dedicated to transforming the way buildings and communities are designed, built and operated, enabling an environmentally and socially responsible, healthy, and prosperous world. Best known for the successful Leadership in Energy & Environmental Design (LEED) green building certification system, we leverage our education, credentials, events, communications, and policy advocacy activities to support the public and private sectors in advancing high-performance, cost-effective, buildings that save energy, water and money. Reducing the contribution of buildings to climate change has long been a core area of our work along with a focus on supporting community resilience.

The Commonwealth is home to nearly 1,300 LEED certified projects, encompassing more than 162 million square feet of commercial, residential, healthcare, educational, retail and public space. Virginia is also home to over 100 USGBC member organizations encompassing architecture and engineering firms, product manufacturers, realtors, contractor and building companies, educational institutions and government agencies, as well as nearly 5,300 individual members. 

On behalf of our member organizations and credentialed professionals in Virginia, USGBC wishes to make the following comments to the Department of Mines, Minerals and Energy (DMME) concerning the 2018 Virginia Energy Plan:

Reduce Energy Use in Public Buildings

We recommend that the 2018 Energy plan include actions to advance energy efficiency through administrative authority beginning with an Executive Order to reinstate the 15% energy reduction goal in public buildings.  The Order should include the following: attaching minimum conditions to all funds for construction and provide data, support of local government programs, and transparency and best practice through a state clearinghouse or high performing building center. We also encourage the Northam Administration to maintain funding for DMME to continue and expand the Energy Data Warehouse to include energy usage at all state-owned or leased buildings and local governments already benchmarking their public buildings.

Expand Energy Performance Contracting

Energy Performance Contracting (EPC) is a valuable financing tool for Virginia State agencies, which have limited capital to engage in a comprehensive approach to reducing energy consumption in public facilities. To further capitalize on the energy saving potential of EPC’s, DMME should recommend that the State commits to a performance contracting goal for its buildings with a separate goal for higher education facilities. Lastly, to expand the state’s energy efficiency program for state and higher education facilities, DMME should develop guidance to deepen the performance contract developed to cover water, indoor air quality and on-site renewable generation where feasible and cost effective.

Benchmark Energy and Water Use

Benchmarking building energy data is a critical first step for a building owner or facilities manager to improve energy performance. The Department of Energy reports buildings that use EPA’s ENERGY STAR Portfolio Manager achieve an average energy savings of 7% over three years, which DOE estimates results in a significant financial savings of $120,000 to over $4 million depending on building sector.[1] Tracking energy performance over time not only results in low cost reductions in energy consumption and financial benefits, but can also lead to economic growth, job creation, and comfortable work environments.

We encourage a continued effort by DMME to lead by example in tracking energy use in state buildings. DMME can improve benchmarking and transparency efforts in public inventory by including requirements to benchmark energy and water use in all state facilities regardless of size as well as certifications such as LEED O+M for Existing Buildings or other equivalent certifications for high performing existing buildings.

In addition, DMME should support legislation granting localities the authority to enact mandatory commercial benchmarking programs. Beyond legislative efforts, it is also important for DMME to expand support of localities setting up their own public benchmarking programs with technical assistance and education.

Ensure Energy Efficiency Investments in the Carbon Trading Rule

The Grid Transformation Act provides tremendous potential for energy efficiency programs over the next decade. DMME needs to stay engaged in utility filings before the State Corporation Commission (SCC) to ensure electric utilities are on track to invest the $1.2 billion required by the Act over the next decade in energy efficiency projects. DMME must also advocate for changes to the SCC’s cost effectiveness test to allow expanded programs such as for low income efficiency projects, to pass. Energy efficiency has multiple cost benefits including economic, social and environmental benefits that must be captured in energy efficiency project evaluations.

Promote Commercial Property Assessed Clean Energy

Commercial Property Assessed Clean Energy (C-PACE) is a fast growing financing structure that can overcome common financing barriers in energy efficient commercial projects. Despite the many benefits that result from affordable, long-term financing for energy upgrades, local Virginia C–PACE programs have grown far more slowly than expected. DMME should work to support and launch C-PACE programs in local jurisdictions across Virginia. We encourage DMME to continue the valuable partnership with Mid-Atlantic PACE Alliance (MAPA) and use its new MAPA Regional Toolkit to support and inform Virginia local governments and other stakeholders on potential courses of action and available resources.

USGBC thanks DMME for its continued leadership and commitment to our shared goal to move the Commonwealth forward on the path towards a clean energy economy. Should there be any questions regarding our comments, please contact Maren Taylor at mtaylor@usgbc.org.

Sincerely,

Jennifer Gunby, Manager, State and Local Advocacy

Cindy Zork, Director, Community Virginia & Tennessee

[1]https://www.energystar.gov/sites/default/files/buildings/tools/DataTrends_Savings_20121002.pdf