Virginia Regulatory Town Hall
Agency
Department of Energy
 
Board
Department of Energy
 
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6/15/23  6:50 pm
Commenter: John Morrill, Fairfax County

Comments from Fairfax County
 
A. Respondent Characteristics 1. Respondent name John Morrill 2. Respondent organization (if applicable) Fairfax County government, Office of Environmental and Energy Coordination 3. Point of contact\'s address, phone number, and e-mail address 12000 Government Center Parkway, # 533, Fairfax VA 22035, 703-324-1792, john.morrill@fairfaxcounty.gov 4. What type of organization do you represent (government, non-profit, solar installer, financier, developer, energy efficiency provider, weatherization provider, etc.), or are you responding as a private citizen? Local government 5. Area or locality served or representing Fairfax County 6. What role would you or your organization play in any projects conducted through this program? Fairfax County, primarily through an emerging Fairfax County Green Bank (to be a 501c3 organization), is interested in providing low- and moderate-income solar and shared solar financing program(s) in Virginia. B. Program Affiliate Roles: 1. What types of entities should be directly affiliated with the Virginia-based program to provide this funding opportunity to disadvantaged communities? What should the organization role(s) entail? Partnerships between any program sponsor or lending entity (whether for-profit or non-profit or governmental) and community-based organizations (CBO) are essential to success in delivering program and funding opportunities to disadvantaged communities. Fairfax County government and the Fairfax Green Bank formation team have been in consultation with the extensive network of CBOs in Fairfax and elsewhere in northern Virginia. Continued development of these partnerships is deemed essential to the success of the green bank effort. C. Behind-the-Meter Solar Program Design and Questions: 1. What eligibility criteria should be considered or required for evaluating residential single family home occupants as potential beneficiaries of the program? Median household incomes vary substantially across various regions of Virginia. To gain a broad constituency of equitable participation, multiple criteria should be considered for eligibility; these include thresholds that take into account local area median income (AMI) levels, not just statewide figures. In that spirit, eligibility such as the Justice40 screening tool (which Fairfax County already uses extensively in its community energy planning), WAP/LIHEAP enrollment, SNAP benefits, and the One Fairfax vulnerability index can identify individual households and communities as beneficiaries. 2. What contractor criteria should be required for local system installers of behind-the-meter solar, storage and/or enabling home upgrades? Contractors should be selected through a competitive process that includes verification of credentials and certifications appropriate to the industry. Virginia Energy should consider providing a minimum set of criteria that all vetting must adhere to and provide flexibility for a local list to include additional criteria. 3. Should energy efficiency or weatherization standards be required prior to solar and/or storage installations? If so, how should energy efficiency be measured, modeled or documented? Although energy efficiency upgrades or attainment of certain minimum energy performance levels are desirable for all households as a matter of public interest, it is not desirable to require such upgrades or standards for potential beneficiaries of the LMI solar installations. Experience elsewhere has shown that addition of rooftop solar often leads to subsequent interest in greater energy efficiency thanks to the feedback gained from reduced utility bills and the desire to ‘get to zero’. D. Shared Solar, Community Solar or Multi-family Shared Solar: 1. How should program incentives and/or credit enhancements be designed to enable shared solar projects and/or multi-family shared solar projects to provide utility bill savings to subscribers? Shared solar projects should be structured in a manner that ensures, through incentives or credit enhancements that lower the cost of implementation, direct and immediate utility bill savings to subscribers, especially in cases where the rate structures impose minimum monthly bills on subscribers. E. Overall Program Design: 1. How should the Program ensure utilization of Renewable Energy Certificates (RECs) to increase economic feasibility for the Program and increase savings to the household? One concept Fairfax County is studying for its green bank is direct purchase (by the green bank) of multi-year REC values as an incentive to lower the cost of LMI solar installations. The SRECs would be owned and retired by Fairfax County to meet its own carbon reduction goals for county operations, while providing immediate value to subscriber via reduced project cost and lower utility bills. 2. What workforce development elements should be considered to ensure disadvantaged communities benefit from this public investment opportunity? The shortage of skilled tradespeople across the United States and in Virginia in particular is a fundamental hurdle to a widespread clean energy future. All potential routes of workforce development should be explored and pursued statewide, including collaboration with community colleges, training centers, and career resources for refugees, veterans, dislocated workers, and individuals re-entering the workforce. Partnerships with community-based organizations and state programs in these areas should be nurtured and leveraged to the greatest extent possible. 3. How should marketing and outreach activities be designed to reach disadvantaged communities? Local governments are particularly close to the communities they serve, and the safety net programs local government agencies operate provide a very strong channel for outreach activities aimed to benefit disadvantaged communities. Fairfax County is eager to deploy state clean energy resources to its citizens, and the county’s One Fairfax vision provides a framework for outreach focusing on delivering programs to LMI, disadvantaged, and vulnerable households in our community.
CommentID: 217270