Children need the EPA’s carbon pollution standard

This post, from guest blogger Samantha Ahdoot, originally appeared in the August 21 edition of the Fairfax County Times. I’ve written about the threat that increasing summer temperatures poses for people who have to work outdoors in ; here, Dr. Ahdoot tells us what carbon pollution means for children.

The end of summer fun? Higher temperatures resulting from carbon pollution could limit children's outdoor time.

The end of summer fun? Higher temperatures resulting from carbon pollution could limit children’s outdoor time.

Every day, parents protect their children from a myriad of risks. By strapping them in car seats, placing them on their backs to sleep and cutting their grapes into quarters, parents do everything in their power to insure their children against harm. President Obama’s Clean Power Plan will be called many things in the upcoming months, but it is ultimately an insurance plan. It is insurance for our children against the dangers of carbon pollution and resulting climate change.

Carbon pollution presents a major risk to the health, safety and security of current and future children. Rising atmospheric carbon is making our planet hotter. While skeptics may say this remains uncertain, our major scientific organizations (NASA, NOAA, IPCC) tell us it is at least very, very likely. With this increased heat, many other climactic changes are already occurring, including melting glaciers, rising sea levels and worsening storms. These fundamental changes ultimately impact human health, and children are amongst the most vulnerable to these changes. Some impacts are already affecting children today and are being seen by pediatricians like myself.

Allergic rhinitis, for example, affects about 10 percent of American children. With later first frost and earlier spring thaw due to rising global temperature, the allergy season has become longer. In the Northern Virginia region, where I practice, it has lengthened by about two weeks. More northern regions of the country have experienced greater lengthening. Higher carbon dioxide in the atmosphere also causes ragweed plants today to produce more pollen than in preindustrial times. Allergy season is therefore both longer and more severe.

Some infectious disease patterns have already been impacted by climactic changes. As global temperatures rise, many plants and animals are migrating poleward. They are bringing diseases, like Lyme disease, with them. There is now Lyme disease in Canada, and large increases in reported cases of Lyme have occurred in the northern U.S. Maine had 175 cases in 2003 and 1300 cases in 2013, while New Hampshire had 262 cases in 2002 and greater than 1300 cases in 2013. Children under five years old, who spend the most time outside playing in high-risk areas, have the highest incidence of Lyme disease.

Increasingly long and severe heat waves also place children at risk of heat-related illness. While the elderly are at highest risk from extreme heat, some groups of children also appear to be vulnerable. Infants less than one year, for example, have immature thermoregulation, and infant mortality has been found to increase due to extreme heat. A study from MIT found that by the end of the 21st century, under a “business as usual” scenario, infant mortality rates would increase by 5.5 percent in females and 7.8 percent in males due to heat-related deaths. U.S. student athletes are a high-risk group for heat injury. Teenage boys, most commonly football players, made up 35 percent of the roughly 5,900 people treated yearly in emergency rooms for exertional heat illness between 2001 and 2009. According to the CDC, heat illness is a leading cause of disability in high school athletes, with a national estimate of 9,237 illnesses annually.

Health impacts on individuals and communities will grow significantly if we allow carbon emissions, and global temperatures, to rise unchecked. Power plants contribute approximately one-third of U.S. greenhouse gas pollution. Reducing emissions from existing fossil fuel-fired power plants represents a major step towards altering our emissions, and climate, trajectory. Obama’s Clean Power Plan is, ultimately, like a car seat- an insurance plan for our children against a significant risk of harm. The road of climate change will be long and hazardous. Our children deserve to be strapped in.

Dr. Samantha Ahdoot is pediatrician in Alexandria. She is a Fellow of the American Academy of Pediatrics (AAP), and a member of the Executive Committee of the AAP’s Council on Environmental Health.

Finally, utility-scale solar for Virginia?

111022-N-OH262-322After a solar buying spree in other states, Dominion Power is at last taking a look at the possibility of building utility-scale solar in Virginia.

As reported in the Richmond Times-Dispatch, Dominion Resources, the parent company of Dominion Virginia Power, is considering building 220 megawatts of solar projects in Virginia, starting in 2017. The plan would involve five 40-megawatt “greenfield” projects, plus 20 megawatts located at existing power stations. (A greenfield is an area that is not already developed. So the large projects would be on former farmland, say, not closed landfills or old industrial sites.)

The company’s recent solar buys in California, Connecticut, Indiana, Georgia and Tennessee have all involved the unregulated, merchant side of Dominion Resources. But in this case, the plan is for Dominion Virginia Power to own the Virginia projects and sell the electricity to its customers here in the Commonwealth. This would require approval of the State Corporation Commission—which, as we know, is no friend to renewable energy.

A little more digging confirmed that Dominion plans to sell the solar energy to the whole rate base, rather than, say, to participants in the voluntary Green Power Program. How would they get that past the SCC? That remains unclear, but they know keeping the cost down will be key. Right now they’re looking at all the options to make it work. The company is still at the conceptual stage, is still looking for good sites of 100 acres and up, and hasn’t even made a decision to proceed.

So we should probably hold our excitement in check for now. After all, Dominion has had wind farms in Virginia “under development” for the past several years, with nary a turbine in sight.

Solar does have a few advantages over wind, though, from a utility perspective. For one, it produces power during the day, when demand is higher, while onshore wind tends to blow more at night. (Offshore wind, on the other hand, picks up in the late afternoon and evening, right at peak demand time.) And unlike wind farms in the Midwest and Great Plains, where turbines coexist peacefully with cows and cornfields, turbines in the mountains of the east have generated opposition from people concerned about impacts on forests and viewsheds. You find some curmudgeons who think solar panels are ugly, but they aren’t trying to block them wholesale at the county level.

With the sharp drop in solar costs over the last few years, large-scale solar has been looking increasingly attractive to utilities that want to beef up their renewable energy portfolios. As we learned recently, Dominion’s got a long way to go before it competes with even an average utility elsewhere. That puts it in a poor position to respond to the rapid changes heading our way. These include not just growing public demand for wind and solar and new regulatory constraints on carbon emissions, but also the much-discussed upending of the traditional utility model that depends on a captive customer base and large centralized generating plants running baseload power. Distributed generation and batteries increasingly offer customers a way to untether themselves from the grid, while wind and solar together are pushing grid operators towards a more nimble approach to meeting demand—one in which baseload is no longer a virtue.

Dominion and its fossil fuel and nuclear allies are fighting hard against the tide, but in the end, Dominion will do whatever it takes to keep making money. And right now, the smart money is on solar.

None of this means we should expect Dominion to become more friendly to pro-solar legislation that will “let our customers compete with us,” as one Dominion Vice President put it. But it does suggest an opening for legislation that would promote utility-owned solar, perhaps through the RPS or stand-alone bills.

Legislators shouldn’t view utility-owned solar as an alternative to customer-owned solar; we need both. And if being grid-tied means being denied the right to affordable solar energy, we will see customers begin to abandon the grid. But those aren’t arguments against utility-scale solar, either. Big projects like the ones Dominion proposes are critical to helping us catch up to other states and reduce our carbon emissions.

So full speed ahead, Dominion! We’re all waiting.


Report confirms Dominion’s worst-place standing on clean energy; public wonders how utility can be quite so bad

photo courtesy of the Sierra Club

photo courtesy of the Sierra Club

A new report from the non-profit group Ceres shows Dominion Resources, the parent of Dominion Virginia Power, winning last place among investor-owned utilities on a nationwide ranking of renewable energy sales and energy efficiency savings.

That’s left Virginians wondering how a company that talks so big succeeds in doing so little. And more importantly, what would it take for Dominion to rank even among the average?

Dominion came in 30th out of 32 in renewable energy sales, at 0.52%. On energy efficiency, it achieved 31st out of 32 on savings measured cumulatively (0.41%), and 32nd out of 32 measured on an incremental annual level (at 0.03%). Together these put our team in last place overall—a notable achievement for a utility that trumpets its solar investments and carbon-cutting progress.

To show just how awful Dominion’s performance is, the top five finishers achieved between 16.67% and 21.08% on renewable energy sales, 10.62-17.18% on cumulative annual energy efficiency, and 1.46-1.77% on incremental annual energy efficiency. National averages were 5.29% for renewable energy sales, 4.96% for cumulative efficiency savings, and 0.73% for incremental annual efficiency savings. Rankings were based on 2012 numbers, the latest year for which data were available.

In case you’re wondering, American Electric Power, the parent company of Appalachian Power Co., earned 24th place for renewable energy, with 2.65% of sales from renewables—a number only half the national average and one we might have called pathetic if it weren’t five times higher than Dominion’s. AEP’s efficiency rankings also placed it firmly in the bottom half of utilities, running 23d and 20th for cumulative and incremental efficiency savings, respectively. However, AEP earned its own laurels recently as the nation’s largest emitter of carbon pollution from power plants due to its coal-centric portfolio.

A study of the rankings reveals that Dominion’s major competition for the title of absolute worst came from other utilities based in the South. The critic’s favorite, Southern Company, nabbed 31st place on the renewable energy sales measure, but failed to make the bottom five on one of the efficiency rankings. Another southeastern utility, SCANA, achieved rock bottom on renewable energy; but like Southern, its marginally better performance on efficiency disqualified it from an overall last-place ranking.

Why do utilities in the South do so poorly? Probably because they can. Most of the poor performers have monopoly control over their territories and are powerful players in their state legislatures. Lacking in competition, they do what’s best for themselves. Possessing political power, they are able to keep it that way.

Of course, they still have to contend with public opinion and the occasional legislator who gets out of line. For that it helps to have a well-worn narrative handy, like the one about how expensive clean energy is. Dominion has found that Virginia’s leaders fall for that one readily, even though it’s false.

And so, when asked about the Ceres report, Dominion responded that Virginia wouldn’t want to be like the states that have high-performing utilities. Dominion spokesman Dan Genest told the Daily Press, “The three states — California, Connecticut and Massachusetts — the report mentions as being leaders in those categories also have among the highest electric rates in the nation. Typical residential customer monthly bills are $228.85, $206.07 and $191.04, respectively. Dominion Virginia Power customers pay $112.45.”

This would be an excellent point, if it were true. Alas, Genest’s numbers appear to be a product of a fevered imagination. According to recent data reported in the Washington Post, California’s average monthly electric bill is only $87.91, Connecticut’s comes in at $126.75, and Massachusetts’ at $93.53, while Virginia’s is $123.72. (Virginia’s numbers presumably reflect an average of bills paid by customers statewide, probably accounting for the higher figure than Genest cites for Dominion’s “typical” customer.)

That’s right: in spite of higher rates, Californians pay way less for electricity than Virginians do, in part because they have achieved high levels of energy efficiency. If you do that, you can afford to invest in more renewable energy without people’s bills going up.

This is such a great idea that it seems like it would be worth trying it here. Remarkably, this is precisely the strategy that environmental groups have been urging for years in their conversations with legislators and their filings at the State Corporation Commission. With the pressure on from global warming and the EPA’s Clean Power Plan, this would seem to be a great opportunity to save money, cut carbon, and move us into the 21st century.

So go for it, Dominion. Aspire to lead! Or failing that, at least shoot for average.



Energy Plan must prepare Virginia for hotter summers

A version of this blogpost was previously published in theHampton Roads Virginian-Pilot on July 20, 2014

Virginians rally in front of U.S. EPA Headquarters in Washington, DC

Virginians rally in front of U.S. EPA Headquarters in Washington, DC

“Over the past 30 years, the average resident of [the Southeast] has experienced about 8 days per year at 95° or above. Looking forward, if we continue our current emissions path, the average Southeast resident will likely experience an additional 17 to 52 extremely hot days per year by mid-century and an additional 48 to 130 days per year by then end of the century.”

            –Risky Business: The Business Risks of Climate Change in the United States

This quote comes from a report issued in June by an all-star group of business and government leaders, laying out the costs involved in higher temperatures and sea level rise. The section on the Southeast is especially likely to make you want to move north and west.

Virginia has started to focus attention on rising sea levels because they are already taking a toll on Tidewater areas, regularly flooding neighborhoods in Norfolk and eating away at the Eastern Shore. In 2013, at the behest of the General Assembly, the Virginia Institute of Marine Science produced an in-depth report on sea level rise and our options for dealing with it. The report says southeast Virginia should expect another one to two feet of sea level rise by 2040, and up to 7.5 feet by the end of the century. We have our work cut out for us, but at least we’re facing up to it.

By contrast, we have not yet begun planning for higher summer temperatures. As the Risky Business report warns, these higher temperatures will make much of the humid Southeast literally uninhabitable without air conditioning. And that has profound implications for our energy planning, starting now.

More intense summer heatwaves will place additional stress on the electric grid and cause costly spikes in power demand. Power outages, today mostly an inconvenience, will become public health emergencies unless there are back-up sources of power readily available, such as solar PV systems with battery storage distributed throughout every community.

Better building construction will be critical to keeping homes and businesses cool reliably and affordably. Since buildings last for many decades, we shouldn’t wait for summers to become deadly before we start mandating better insulation. It is vastly cheaper and more effective to build energy efficiency into a building than to retrofit it later.

This makes it especially unfortunate that the McDonnell administration caved to the home builders’ association last year and did not adopt the updated residential building codes, which would have required these kinds of improvements in new additions to our housing stock. Governor McAuliffe’s failure to reverse the decision this year remains incomprehensible.

However, the McAuliffe administration is now engaged in three planning exercises that ultimately converge around Virginia’s future in a warming world. The Department of Mines, Minerals and Energy is currently writing an update to the Virginia Energy Plan as required by statue every four years, and which must be submitted to the General Assembly this October. On a slower track, a revived Climate Commission will begin conducting its work over the course of the next year. And most recently, the Department of Environmental Quality has announced listening sessions this summer focused on the U.S. EPA’s proposed climate rules.

This timeline puts the (energy) cart before the (climate) horse. The writers of the Energy Plan will not have the benefit of the climate commission’s deliberations, and won’t know what the final EPA rules will require. With pressure from utilities, fossil fuel interests and home builders, business-as-usual thinking might prevail. That would be a mistake.

We don’t know whether the worst extremes cited in the Risky Business report will become reality, or whether the U.S. and the rest of the world will manage to reduce greenhouse gas emissions enough to slow the rise of the oceans and check the worst of the heatwaves. But while we hope for the best, it makes sense to plan for the worst.

And in this case, planning for the worst will also reduce the likelihood of it happening. If we improve building efficiency starting now, we will cut down on the emissions driving a Risky Business future. If our disaster preparedness includes solar panels on businesses and government buildings, we cut emissions and make the grid more resilient.

Global warming has to be part of Virginia’s energy planning from now on. It’s just too risky to ignore it.



Now’s your chance: Virginia seeks public input on carbon rules

Photo by Josh Lopez, courtesy of the Sierra Club.

Photo by Josh Lopez, courtesy of the Sierra Club.

On June 2 the U.S. EPA proposed a Clean Power Plan for the states, and now the Virginia Department of Environmental Quality wants to know what Virginians think about it. Starting July 22, DEQ is holding four “listening sessions” to get the public’s views:

  • Tues, July 22 in Wytheville, VA, Snyder Auditorium, Wytheville Community College, 1000 East Main Street, 5 PM to 8 PM.
  • Thurs, July 24 in Alexandria, VA, Meeting Room, John Marshall Library, 6209 Rose Hill Drive, 5 PM to 8 PM.
  • Mon, July 28 in Virginia Beach, VA, Auditorium, Virginia Beach Public Library, 4100 Virginia Beach Blvd., 5 PM to 8 PM.
  • Thurs, Aug 7 in Henrico, VA, Administration Board Room, Henrico County Govt. Center, 4301 East Parham Rd., 5 PM to 8 PM.

Depending on turnout, speakers may be limited to 3-5 minutes, though written testimony can be any length. Written comments can also be submitted to

The purpose of the listening sessions, according to DEQ, is to help the agency determine what comments it will file on the EPA plan, and how Virginia can implement the rules as they have been proposed.

The first question is one for the public—do we support EPA’s plan to cut carbon emissions? The answer, of course, is an emphatic yes. In fact, EPA’s proposal is too modest, and we can do better.

Carbon pollution affects everyone in Virginia: residents of coastal areas experiencing recurrent flooding and beach erosion due to sea level rise; farmers whose crops will suffer from higher summer temperatures and drought; people who have asthma or heart disease; the elderly, who suffer most during heat waves; and parents who want to leave a healthier planet for our children and grandchildren. DEQ needs to hear from all these residents.

DEQ’s second question is how we should go about cutting carbon. The EPA plan proposes a carbon budget for Virginia that would reduce our emissions by 38.5% over 2005 levels by 2030. It wouldn’t tell us how to do it, but outlines four broad categories of options:

  • Increasing the efficiency of existing coal plants to reduce carbon emissions;
  • Increasing utilization of existing natural gas-fired power plants;
  • Expanding the use of wind, solar, or other low- or zero-emitting alternatives; and
  • Reducing consumption through energy efficiency.

We may be able to do all of these, but the third and fourth categories offer the big opportunities. Virginia lags behind other states on energy efficiency, has so little solar that the industry trade groups haven’t bothered to track it, and has no wind power at all. As a result, we have a lot of low-hanging fruit to go after. So EPA’s 38.5% is readily achievable if we refocus our energy policies to support energy efficiency and zero-emission energy sources like solar and wind.

This is hardly a new theme, though the EPA plan gives it new impetus. For years environmental groups have argued to the State Corporation Commission, utilities and the legislature (and anyone else who will listen), that a sound energy policy for Virginia should include substantial investments in energy efficiency, solar and wind. That combination offers the most bang for the buck and provides the most benefit to Virginians in the way of clean air, jobs and business opportunities.

It’s been a hard sell; Virginia utilities make more money when they sell more power, so they don’t like efficiency measures that lower demand, and the SCC has always favored “cheap” energy, no matter what it costs us. EPA’s plan can help us overcome these barriers if Virginia adopts the right policies. These could take the form of an energy efficiency resource standard (EERS) and a law giving teeth to our renewable portfolio standard (RPS). Alternatively or in addition, we could join a regional cap-and-trade system that effectively puts a price on carbon, such as the northeast’s very successful Regional Greenhouse Gas Initiative.

If any of these are to become a reality, it will take public demand to make it happen. Even with carbon taking center stage now, there is room for utilities to carry us in the wrong direction. Dominion Virginia Power sees carbon regulation as an opportunity to develop nuclear power at ratepayer expense, in spite of the costs, the risks, the shortage of cooling water, and the lack of any long-term plan for radioactive waste. Expensive central power stations, heavily subsidized by the public but comfortably familiar to executives and lucrative for shareholders, remain Dominion’s top choice.

With Dominion using its cash and clout liberally in Richmond, its preference for more gas and more nuclear will carry greater weight with decision-makers than such an approach deserves. So if the public wants anything else, it had better speak up—and now’s the time to do it.







What’s North Carolina got that we ain’t got? Solar.

solar installation public domainRenewable energy advocates were delighted by the news last week that American University, George Washington University, and George Washington University Hospital, all in DC, have contracted to buy 52 megawatts of solar power from three projects to be built in North Carolina. The projects will be owned and operated by Duke Energy. It’s one of the biggest solar deals in the East, and puts the two universities and the hospital at the forefront of nonprofit institutions.

Many universities have been debating the merits of divesting their endowments from fossil fuels, an important but mostly symbolic move in the fight against global warming. But buying solar for campus operations and investing in solar projects on campus actually carries the ball forward. It reduces fossil fuel use, helps the solar industry grow, and supports local jobs.

Although in this case, the jobs aren’t local. The astute reader will have noticed that an entire state lies between the District of Columbia and North Carolina, but it got skipped over in this deal. A project like this one in Virginia would have about quadrupled our entire installed solar capacity to date. We, too, have under-utilized agricultural land and communities pining for new additions to their tax base, and we have solar installers working in every corner of Virginia. We could have done this. So what has North Carolina got that we ain’t got?

Pro-solar policies, for one thing. North Carolina offers a 35% tax credit that is driving the huge growth in solar in the state; North Carolina has about thirty times more solar than Virginia. The credit probably explains how the universities and the hospital could be promised a price for solar electricity that will be less than the price for regular “brown” power.

As word of this gets around, there will be a lot of other nonprofits looking at this deal and considering similar projects for themselves. North Carolina will see even more activity like this in the future—meaning it will continue to benefit from growth in the solar industry, creating jobs and bringing in new revenue.

North Carolina’s Duke Energy also seems to be more interested in developing solar in its home state than is Dominion Virginia Power. Duke is no angel—like Dominion, it uses its membership in the American Legislative Exchange Council (ALEC) to concoct attacks on customer-owned solar.

But Duke has signed on to own and operate the two universities’ projects, while Dominion busies itself complaining about other North Carolina solar projects.

Meanwhile, back in Virginia, Dominion brags that it intends to install an 800-kilowatt solar system on two buildings in Sterling. News reports put the price tag at $2.5 million, or $3.125 per watt, for what Dominion says will be the biggest rooftop solar installation in Virginia.

Of course, it’s only the state’s biggest rooftop system because Dominion’s customers face a 500-kW cap on the size of solar projects they can net meter under a Virginia law that Dominion fights hard to maintain. This low cap is one more barrier for Virginia.

And in its announcement, Dominion did not suggest the company harbors any actual enthusiasm for solar. In a carefully worded statement, Dominion’s vice president for customer solutions, Ken Barker, said the project “reflects Dominion’s commitment to understanding how solar power can fit into our generation mix,” and “will enable us to evaluate the benefits and study the impact of distributed solar generation on our electric grid.”

That “commitment to understanding” is a long way from a commitment to supporting a vibrant solar market in Virginia. That’s something we have yet to see from Dominion.

And in case you’re wondering, the project will be built by—ahem—a North Carolina developer.

Governor McAuliffe gets his chance on energy and climate


Virginia Sierra Club activists Tom Ellis and Ann Moore. Photo by Ivy Main

Virginia Sierra Club activists Tom Ellis and Ann Moore. Photo by Ivy Main

2014 is shaping up to be an exceedingly interesting year for energy policy in Virginia. The rewrite of the Virginia Energy Plan, the re-establishment of the Governor’s Climate Commission, and EPA’s just-proposed carbon rule create three separate pathways that will either intersect to form a coherent and coordinated state policy, or will take us into a chaotic tangle of competing agendas.

Add in the myopia of the State Corporation Commission and the control of the General Assembly by utility and coal interests, and we’ve got an unpredictable plotline here. All you energy watchers are going to want to stock up on popcorn for this show. Or better yet, become a player—read on to find out how.

First there’s the energy plan. Virginia law requires a new iteration every four years, with this year’s due October 1. To help with the work, Governor McAuliffe appointed the Virginia Energy Council two weeks ago. The Council consists primarily of energy industry members, with only one environmental representative and no consumer advocates. (Although come to think of it, that might be because Virginia doesn’t have any consumer advocates. But still.)

The Council will be working with the staff of the Department of Mines, Minerals and Energy, which has already begun holding “listening sessions” and accepting comments to get input from the public. The next one will be held tonight, June 17, in Annandale, Virginia. Get there early and sign up for a speaking slot. Other locations include South Boston on June 19, Abingdon on June 24, Norfolk on June 26, and Harrisonburg on July 1.

The existing energy plan, created under Governor McDonnell, is the sort of “all of the above” hodgepodge that you’d expect from a process where you bring in a bunch of energy company executives and say, “Have at it!” I’d be concerned that the same fate awaits the new one, but for a couple of new factors: the reboot of the Governor’s Commission on Climate Change and the looming threat of EPA’s carbon rule. (Making this the first time ever that I’ve welcomed anything I called a looming threat.)

The Climate Commission was supposed to have launched by now, and if it had, I might have been able to say something definite about how it will interact with the Energy Council. Unfortunately, Governor McAuliffe got a little sidetracked by something you may have heard about: the political chaos that ensued when a certain Democratic senator resigned his seat and threw the Senate into Republican hands under suspect circumstances in the middle of a battle over the Governor’s signature initiative.

(In fairness. the senator’s backers insist he acted only out of the purest self-interest and not because he’d been bribed, there being a legal difference. Still, from now on anyone who screws over a large number of friends at once will be said to have “Pucketted” them.)

As you may remember, Governor Kaine established the first Governor’s Commission on Climate Change back in 2007 to study the effects of global warming on Virginia and to make recommendations on what to do about it. The commission issued a well-thought-out report replete with excellent suggestions. The report was put on a shelf and admired for a while, until Governor McDonnell found out about it. He acted swiftly, taking down the Commission’s web page lest anyone think he believed in rising sea levels and flooding and predictions about the dire consequences of global warming—you know, the sort of thing you can actually see going on now in Hampton Roads, the second-largest metropolitan area in Virginia.

Governor McAuliffe, on the other hand, not only “believes in” climate change and the risks it poses to Virginia, but also believes there are huge job and growth opportunities to be had by taking action in response. He has made it clear he does not want his commission to start from scratch, but rather to pick up where the Kaine commission left off.

McAuliffe’s Energy Plan must also take account of carbon emissions in a way the McDonnell plan never tried to. On June 2, EPA issued a proposed rule to address carbon pollution from existing electric generating plants, intended to reduce overall emissions nationwide by 30% by 2030. Although the rule won’t be final for a year, and states will then have as long as two years to implement it, and there will be lawsuits trying to block it from ever being implemented—still it means no one can ignore carbon now.

If you want to weigh in on the carbon rule, EPA will be holding hearings around the country, including in Washington, DC on July 30, or you can email your comments.

The proposed rule is not simple. Each state has been given a carbon budget for all its electric generating plants combined, expressed in pounds per megawatt-hour, and arrived at by some still-rather-opaque notion of what a given state is capable of. The cleanest states are thought to have policies in place to get even cleaner, so their targets are more ambitious than those of the dirtiest states. The dirty, coal-intensive states, having done so little to clean up in the past, are thought incapable of making a whole lot of progress now, and so are rewarded by being graded on a curve. Interestingly, it is not the clean states crying foul, but the dirty ones.

Virginia’s carbon target falls in the middle, but achieving it will require improvements of 37.5% over 2012 levels. This sounds harder than it is, given that we have several natural gas plants under construction that will presumably count towards lowered emissions as they dilute the coal in the state’s power mix. EPA also assumes that existing plants can operate at higher efficiencies that will reduce emissions per unit of energy produced.

The carbon rule also contains what seems to be a freebie of 6% of existing nuclear power, a provision intended to encourage the continued operation of nuclear plants that still have time remaining on their licenses but are no longer economic. In Virginia’s regulated market, our nuclear plants don’t have to compete on the open market and so aren’t in danger of being shut down for economic reasons, but apparently we get the freebie anyway.

Beyond that, however, the carbon rule will clearly put a thumb on the scale in favor of energy efficiency and carbon-free power sources. The EPA is right to think we have plenty of those to call on. A few years ago, ACEEE released a study showing Virginia could readily achieve energy efficiency savings of almost 20% cost-effectively, and much more if we really rolled up our sleeves. Since then, the few utility programs that have addressed energy efficiency have barely moved the needle. This means the low-hanging fruit still clings there, only now it’s really, really ripe.

Add in offshore wind (which can provide about 10% of state energy needs just from the initial lease area that Dominion Power bought rights to), some land-based wind (a few more percentage points) and solar energy (estimated to be able to produce 18-25% of our demand), and we know we can blow right through the EPA target.

As we also know, though, Dominion CEO Tom Farrell has his heart set on a new nuclear plant, which would suck up all the money that might otherwise go to renewables and dampen the utility’s interest in efficiency. Given nuclear’s high cost, the need for taxpayer and ratepayer subsidies, and the public safety risks involved, the free market isn’t on his side. But with captive ratepayers and the legislature on the company payroll, Farrell’s dream remains a possibility in Virginia.

As I say, it’s going to be an interesting year.