GRID Alternatives Mid-Atlantic (“GRID Mid-Atlantic”) appreciates the opportunity to provide comments on the Regulation for Emissions Trading Programs. GRID Mid-Atlantic is an affiliate of the international GRID Alternatives organization and our mission is to make clean energy technology accessible to everyone. GRID Mid-Atlantic is a separate 501(c)(3) and has a local Board of Directors that represents the region including Virginia. We have a unique hands-on job training model that provides solar at no cost to low-income families in the Mid-Atlantic region based on an established national model. After opening our doors in 2014, GRID Mid-Atlantic has installed a megawatt of solar and provided nearly 700 individuals with hands-on solar training in that time. Although the majority of that impact has been outside Virginia’s borders due to weak policies, regulations and programs guiding the industry. We see an opportunity to leverage this program to support deploying solar energy and adding new jobs to the Virginia economy.  

GRID Mid-Atlantic’s comments are focused on the benefits and potential impacts of this regulatory proposal. We understand the consignment auction under which allocations will be traded is designed to be revenue neutral. However, as described in the Virginia Register of Regulations Volume 34, Issue 10[1], the Virginia Department of Mines, Minerals, and Energy (“DMME”) will have a contract with a third-party administrator that would sell allowances allocated to DMME and make the funding available for use in a variety of programs to help reduce carbon dioxide emissions. Accordingly, one of DMME’s objective strategies is to accelerate the adoption of energy efficiency practices and expand the deployment of renewable energy.[2] This funding could be utilized to create new economic opportunity in the commonwealth through solar energy.  

Solar provides long-term financial relief to families struggling with high and unpredictable energy costs, living-wage employment opportunities in an industry adding jobs at a rate of 20 percent per year, and a source of clean, local energy sited in communities that have been disproportionately impacted by traditional power generation.[3] Virginia solar jobs increased by 10 percent in 2017, and the state now has over 3,500 solar workers. Virginia is poised to experience 1.5% solar jobs growth in 2018.[4] Low-income ratepayers pay a disproportionate amount of their income on utility bills. These customers stand to benefit most from solar energy, and must be prioritized through targeted policies and programs.  

In addition, the Virginia Register of Regulations Volume 34, Issue 10[5] also points out the assumption that all revenues raised from the auction by regulated utilities are returned to ratepayers. In the case of distribution utilities dependent on other wholesalers for power, such as rural electric cooperatives, municipal electric entities, and possibly others, those wholesale contracts could impose costs on those dependent purchasers with no mechanism--and certainly nothing that Virginia Department of Environmental Quality (“DEQ”) could make a requirement--for the wholesaler’s auction proceed revenues to offset those costs or return those revenues to the underlying load that is responsible for paying those costs. There may be possible solutions to this issue; however, those solutions would be outside DEQ’s purview, either involving an order from the State Corporation Commission, a mandate to run auction revenues through a FERC formulary rate in a certain way, or General Assembly legislation.  Low-income consumers that use electricity—should not be pay for the costs of carbon regulation without also receiving the benefit of revenue, if any, from allowance auction proceeds.  The proposed regulation does not fully address this issue.

GRID Mid-Atlantic has seen the benefits of low-income solar programs in various markets across the country. We recommend the Regulation for Emissions Trading Programs reflect the opportunity that low-income ratepayers directly benefit from a low-income solar program funded by DMME’s allowance funding. Importantly, a low-income solar program would have the goals of significantly reducing the electrical energy burden of Virginia’s low-income ratepayers and training the next generation of Virginia’s solar workers.  We believe this type of programming would also complement DMME’s strategic objective to expand the deployment of renewable energy and overall reduction of carbon dioxide emissions. We hope that DEQ take these comments into consideration while designing the program. Please do not hesitate to reach out if you have any questions or would like to discuss further.

Thank you for the opportunity to provide comment.

[1] http://register.dls.virginia.gov/vol34/iss10/v34i10.pdf (p 930)

[2] https://solutions.virginia.gov/pbreports/rdPage.aspx?rdReport=vp_StratPlan102&selAgency=409&selVersion=2016-18&run=Run

[3] http://www.lowincomesolar.org/why-act/

[4] https://www.thesolarfoundation.org/solar-jobs-census-factsheet-2017-VA/

[5] http://register.dls.virginia.gov/vol34/iss10/v34i10.pdf (p 929)