Comments Document

Written statement of Jigar Shah, Founding Advisory Chair of Deploy Action, a 501(c)(4) nonprofit, writing in support of HB 434.

Comments Document

My name is Jigar Shah, and I am Founding Advisory Chair of Deploy Action, a 501(c)(4) nonprofit dedicated to removing barriers to clean energy deployment at the state level. I am also a Partner at Multiplier, an advisory firm helping clean energy, cleantech, and climate tech companies accelerate their growth, and prior to that served as Director of the U.S. Department of Energy’s Loan Programs Office, the federal government’s clean energy investment vehicle. Prior to my time in government service, I co-founded and was President of Generate Capital, founded SunEdison, and was the founding CEO of the Carbon War Room. Building new transmission and distribution infrastructure is the biggest driver of cost increases to ratepayers, since those investments are capital-intensive. For example, based on utility reports to the Federal Energy Regulatory Commission, a U.S. Department of Energy (DOE) report (2024) from several national labs estimated that, as of 2021, utility investments in distribution systems nationwide exceeded $60 billion annually. This question is all the more critical at a time of unprecedented projected load growth. For example, according to Virginia’s Joint Legislative Audit and Review Commission (2024), the Commonwealth faces historic energy demand growth from a number of sources, including data centers, potentially more than tripling overall electricity usage over the next 10 to 15 years if data center expansion continues at current projections. Given the size of these grid investments and the length of time it takes to bring new infrastructure and generation online, Virginians reasonably want to make sure they know what they’re buying. Today, utilities and regulators lack consistent, transparent metrics to understand how much unused or underutilized capacity already exists on the transmission and distribution grid. Because of this, the SCC cannot effectively evaluate whether existing grid assets are used to their full potential, fully gauge whether proposed grid upgrades are necessary, or weigh alternatives that could meet the same needs at lower cost. HB 434 directly addresses that gap by requiring covered utilities to submit by November of this year standardized, transparent grid utilization metrics to assess how the grid is operating. The bill calls for identifying distribution system peak load versus total distribution capacity, load delivered to potential deliverable load, and potential losses with some granularity and on a seasonal basis. Together, these metrics can help regulators prioritize effectively using existing transmission and distribution infrastructure as part of their evaluation of new utility investments, and can provide Virginians more information about whether to defer or right-size new grid investments to reduce any unnecessary capital spending to lower long-term ratepayer costs. Grid utilization can take many forms, so let me provide some examples. The same DOE national laboratory study referenced above looked at energy demands on the distribution and transmission grid from transportation electrification in five study states. It found that a range of solutions under the broad umbrella of grid utilization – such as proactive utility planning, tariff structures, and vehicle-grid integration technologies – could help mitigate grid infrastructure investment needs by 30%.

Comments Document

Building new transmission and distribution infrastructure is the biggest driver of cost increases to ratepayers, since those investments are capital-intensive. For example, based on utility reports to the Federal Energy Regulatory Commission, a U.S. Department of Energy (DOE) report (2024) from several national labs estimated that, as of 2021, utility investments in distribution systems nationwide exceeded $60 billion annually. This question is all the more critical at a time of unprecedented projected load growth. For example, according to Virginia’s Joint Legislative Audit and Review Commission (2024), the Commonwealth faces historic energy demand growth from a number of sources, including data centers, potentially more than tripling overall electricity usage over the next 10 to 15 years if data center expansion continues at current projections. Given the size of these grid investments and the length of time it takes to bring new infrastructure and generation online, Virginians reasonably want to make sure they know what they’re buying. Today, utilities and regulators lack consistent, transparent metrics to understand how much unused or underutilized capacity already exists on the transmission and distribution grid. Because of this, the SCC cannot effectively evaluate whether existing grid assets are used to their full potential, fully gauge whether proposed grid upgrades are necessary, or weigh alternatives that could meet the same needs at lower cost. HB 434 directly addresses that gap by requiring covered utilities to submit by November of this year standardized, transparent grid utilization metrics to assess how the grid is operating. The bill calls for identifying distribution system peak load versus total distribution capacity, load delivered to potential deliverable load, and potential losses with some granularity and on a seasonal basis. Together, these metrics can help regulators prioritize effectively using existing transmission and distribution infrastructure as part of their evaluation of new utility investments, and can provide Virginians more information about whether to defer or right-size new grid investments to reduce any unnecessary capital spending to lower long-term ratepayer costs. Better data can lead to better decisionmaking in SCC’s review of utility long-term plans, including capital investment and cost recovery requests that directly affect rates. Measuring utilization is an important first step to making smarter, more cost-effective decisions about how the grid should grow to meet today’s electricity demands. HB 434 focuses on outcomes, namely better utilization and affordability, to put Virginia on a trajectory to achieving those ends. Finally, we also want to commend Delegate LeVere Bolling and Governor Abigail Spanberger for their leadership in making grid utilization and energy affordability priorities. We are excited to continue to support this legislation in the House of Delegates and to work with Senator Kannan Srinivasan on his companion bill Senate Bill 621. Thank you for your consideration of HB 434, and we urge the Subcommittee to favorably report the bill. Please feel free to contact Kyle Winslow, policy consultant at Deploy Action, at kyle@winslowpa.com, or Jennie O’Holleran at jennie@broadstreet.group, for any questions or for stakeholder discussions on the important issue of creating grid utilization metrics. Thank you for your consideration of our comments.

Hello, My name is Richard Caperton and I am the Vice President for Public Policy at SPAN. I am writing in support of House Bill 434 offered by Del. LeVere Bolling. We commend the Delegate and the Governor for supporting this effort. SPAN is a manufacturer of smart electric panels and grid-edge hardware and software solutions. Smart panels, such as those developed by SPAN, serve as a direct replacement of the traditional residential electrical breaker box. The panel includes intelligent hardware that can enable whole-home electrification, including the installation of rooftop solar, backup battery, heat pump HVAC, hot water heaters, induction cooking, and EV charging without the need for expensive service upgrades and additional upstream investments to the distribution system. Grid utilization is an emerging concept in utility regulation that prioritizes effectively using existing transmission and distribution infrastructure over additional utility investments. Today, utilities and regulators lack consistent, transparent metrics to understand how much unused or underutilized capacity already exists on the transmission and distribution grid. Ratepayers are paying for the entire grid but receiving only a small percent of the value in most circumstances. HB 434 brings a new way of measuring existing grid utilization and assessing the true need to build, or defer building, new transmission and distribution infrastructure – which is the biggest driver of cost increases to ratepayers. By better utilizing existing assets, the Commonwealth can defer or right-size new grid investments, reduce unnecessary capital spending, and lower long-term ratepayer costs. The bill gives the State Corporation Commission (SCC) the tools it needs to measure whether utilities are taking actions to unlock the full value of their existing infrastructure before asking Virginians to pay for more. The legislation focuses on outcomes, namely better utilization and affordability, not prescriptive mandates, and opens the door for any technology, resource, or other non-wire alternative that will deliver better utilization – allowing utilities the flexibility to determine how best to improve utilization, subject to SCC oversight We urge the subcommittee to favorably report the bill. We look forward to continuing to work with your office, the Committee on Labor and Commerce, and other stakeholders in Virginia, including our utility partners, on this important legislation. Thank you for your consideration.

Hello, My name is Will Baker. On behalf of Renew Home, I am writing in support of House Bill 434 offered by Del. LeVere Bolling. We commend the Delegate and the Governor for supporting this effort. Renew Home delivers personalized, comfort-aware adjustments to smart devices—beginning with Google Nest thermostats—that help customers save energy effortlessly throughout the day. Energy Shift Capacity (ESC) can be scheduled more frequently than traditional DR, reach more homes, and result in fewer opt-outs, ultimately providing greater reliability and flexibility for energy providers and grid operators. Utilities can specify when Energy Shifts are needed to address real-time grid needs. Personalization is key to increasing savings and ensuring a reliable energy resource while protecting customer comfort and control. Renew Home Energy Shifts are increasingly personalized to account for weather, home performance and personal preferences, and are often so subtle they aren’t noticeable. Concurrently, grid utilization is an emerging concept in utility regulation that prioritizes effectively using existing transmission and distribution infrastructure over additional utility investments. Today, utilities and regulators lack consistent, transparent metrics to understand how much unused or underutilized capacity already exists on the transmission and distribution grid. Ratepayers are paying for the entire grid but receiving only a small percent of the value in most circumstances. HB 434 brings a new way of measuring existing grid utilization and assessing the true need to build, or defer building, new transmission and distribution infrastructure – which is the biggest driver of cost increases to ratepayers. By better utilizing existing assets, the Commonwealth can defer or right-size new grid investments, reduce unnecessary capital spending, and lower long-term ratepayer costs. The bill gives the State Corporation Commission (SCC) the tools it needs to measure whether utilities are taking actions to unlock the full value of their existing infrastructure before asking Virginians to pay for more. The legislation focuses on outcomes, namely better utilization and affordability, not prescriptive mandates, and opens the door for any technology, resource, or other non-wire alternative that will deliver better utilization – allowing utilities the flexibility to determine how best to improve utilization, subject to SCC oversight We urge the subcommittee to favorably report the bill. We look forward to continuing to work with your office, the Committee on Labor and Commerce, and other stakeholders in Virginia, including our utility partners, on this important legislation. Thanks for your consideration.