Thank you for accepting these comments to the "2022 Virginia Energy Plan" on behalf of Virginia Clean Energy (VCE), a non-profit organization based in Northern Virginia.  Our mission is to promote Community Choice Aggregation (CCA), also known as Community Choice Energy or Municipal Aggregation, to achieve renewable energy and climate goals for localities and the Commonwealth.[1]  We were founded independently in 2018, a few years before the Virginia Department adopted its shorthand name Virginia Energy.  We are not affiliated with the State or any local governments.

CCA allows cities, counties, or groups of them (municipalities) to select the delivered energy mix for their community by allowing localities to access the wholesale energy market directly.  CCA programs allow municipalities to define their power mix, and 50% renewable and 100% renewable have been implemented in other states.  CCAs give municipalities the choice to vote for locally generated power from local renewable energy projects that create jobs near their communities.  We have been in conversation with many local elected officials in Virginia, who have expressed an interest in CCA.  We hope the Virginia Energy Plan can promote CCA as an energy and economic development strategy that will meet the goals of the Commonwealth.  For example, a study conducted by a Northern Virginia County found that, with an investment of less than $4 million, a CCA would provide:

• Annual rate savings to residents and customers of $35 million, increasing to $200 million by 2033.
• Inject an additional $50.3 million per year into the Northern Virginia economy, creating an additional 421 local jobs.
• Provide $23 million net revenue in the third year, increasing to $250 million by 2033.  This money would fund programs benefiting low-income households or lower rates for all customers. 
• Reduce greenhouse gas emissions. The mid-range estimate of these emission reductions is the equivalent of taking 1 million cars off the road.

VCE recognizes that some stakeholders would benefit from some additional information about the current state of energy and the climate in Virginia in 2022.  The Virginia Energy Plan should include or advance the following ideas and policies:

• Climate change is real.  Please see the IPCC reports or other scientific documents for details.  Future generations are depending on our generation taking action to reduce fossil fuel use immediately.[2]
• Support the Virginia Clean Economy Act, a landmark law passed to help produce fossil-free electricity in Virginia.
• Remain part of the Regional Greenhouse Gas Initiative (RGGI), which creates an important incentive to reduce carbon pollution emissions and can be a revenue source to Virginia's local governments and others to plan and respond to existing climate challenges such as flooding, extreme weather and heat.  Carbon pricing should be supported in general, even if the carbon price is low at first.
• Promote Incentives for solar PV and electric vehicles.  The Virginia Energy Plan should include aggressive support for all policies and programs that expand rooftop solar PV and electric vehicles and infrastructure.