Public Comments for: HB746 - Energy efficiency programs; definitions, incremental annual savings.
Last Name: Lewis Organization: The Nature Conservancy Locality: Charlottesville

The Nature Conservancy strongly SUPPORTS HB746. Virginia's energy demand is growing, and energy efficiency can help balance the impact of that growth. Helping customers reduce demand means reducing ALL the impacts of new energy generation on our air, water, land, and climate. Virginia's existing Energy Efficiency Resource Standard (EERS) gives utilities the same return on equity from energy efficiency as they do on building new generation. HB746, The SAVE Act, strengthens our existing EERS policy. It is a win for ratepayers, for utilities, and for nature. The current method of determining cost-effectiveness of utility energy efficiency programs is cumbersome, opaque, and outdated. Of greater concern, passing the current cost-effectiveness tests leads to energy efficiency programs being watered down, rather than strengthened. The SAVE Act would initiate a process of the SCC developing one new cost-effectiveness test that fits Virginia and would result in greater cost-effective energy savings achieved through utility energy efficiency programs. The SAVE Act would require the SCC to follow a nationally recognized best-practice process outlined in the National Standards Practice Manual. This manual does not dictate what the cost-effectiveness test should be. IT GUIDES THE PROCESS of the SCC developing the test with utility and stakeholder input, FOLLOWING 8 PRINCIPLES listed below. I cannot think of a reasonable objection to any of these principles. 1. Treat Energy Efficiency as a Resource. 2. Align With State Policy Goals. 3. Ensure Symmetry Across Costs and Benefits. 4. Account for Relevant Material Impacts. 5. Conduct a Forward-Looking, Long-term Analysis. 6. Avoid Double-Counting Impacts 7. Ensure Transparency. 8. Conduct Benefit Cost Analyses Separate from Rate Impact Analyses.

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