I strongly support the passage of House Bill No. 1588. This legislation provides crucial consumer protections by limiting the frequency and timing of public utility rate increases. Frequent and unpredictable utility rate hikes place a significant burden on Virginia households and businesses. By restricting the number of increases within a year and prohibiting them during the winter months, this bill offers much-needed relief and predictability for Virginians. I urge the General Assembly to swiftly pass HB1588 and ensure that we are protected from excessive and untimely utility rate increases.

Comments Document

On behalf of the R Street Institute, I want to urge your support of HB2528. I have attached long form testimony on the proposal for your review.

Chairman Sullivan and members of the committee, My name is Robert Melvin and I am the Northeast region director for the R Street Institute. R Street is a nonprofit, nonpartisan, public-policy research organization with a mission to engage in policy research and outreach to promote free markets and limited, effective government including in relation to electric utility regulations. This is why we have an interest in HB 2436, HB 2528, and HB 2547. Currently states have adopted a variety of models for how to structure their electricity markets. Around a third of states allow for retail and wholesale competition in electricity; another third of states have maintained the vertically integrated monopoly utility system and do not participate in an organized wholesale electric market; the final third have adopted a hybrid approach, maintaining vertical integration but allowing competition in some areas. Virginia is firmly in the hybrid camp. Virginia participates in the PJM Interconnection, an organized competitive wholesale market, and while the vast majority of customers are served by monopoly generation and retail services, Virginia law does provide for several avenues for certain customers to access competition. The legislation before this committee today would not fundamentally change Virginia’s hybrid electric system. It would, however, make it easier for businesses to access competition in ways that are already provided for under Virginia law. For example, current Virginia law allows large commercial and industrial customers (over five megawatts) to access competition. Businesses that choose to do so, however, are required to give five-year advance notice to utilities if they enroll with a competitive supplier and later seek to return to utility supply. This needlessly discourages businesses from entering competition, because if it doesn’t work out, they will be trapped outside the utility for half a decade. The five-year requirement is not necessary. Nearby states such as Maryland, Pennsylvania, Ohio, and the District of Columbia require only 15 days’ notice. Similar issues exist for residential and commercial customers who would like access to renewable electricity. Current law provides a mechanism for customers to access competition to procure 100 percent renewable derived electricity. However, mass market customers, including residential, are only allowed to access competition if their utility does not have a renewable offering already. To foreclose this possibility, Virginia utilities have created their own 100 percent renewable products. While these plans offer inferior terms to what a customer could get on the open market, their existence is sufficient under current law to prevent customers from seeking a better option. The legislation before you today would help resolve these problems by reducing the advanced notice from five years to six months, allowing for easier aggregation of demand to meet the minimum use requirement for larger commercial and industrial customers, and by allowing all customers to access competition for renewable electricity. These changes will provide benefits to consumers and help Virginia’s electric markets to function in a more innovative and efficient manner. For these reasons, we urge you to give favorable consideration to HB 2436, HB 2528, and HB 2547. Thank you, Robert Melvin

Chairman Sullivan and members of the committee, My name is Robert Melvin and I am the Northeast region director for the R Street Institute. R Street is a nonprofit, nonpartisan, public-policy research organization with a mission to engage in policy research and outreach to promote free markets and limited, effective government including in relation to electric utility regulations. This is why we have an interest in HB 2436, HB 2528, and HB 2547. Currently states have adopted a variety of models for how to structure their electricity markets. Around a third of states allow for retail and wholesale competition in electricity; another third of states have maintained the vertically integrated monopoly utility system and do not participate in an organized wholesale electric market; the final third have adopted a hybrid approach, maintaining vertical integration but allowing competition in some areas. Virginia is firmly in the hybrid camp. Virginia participates in the PJM Interconnection, an organized competitive wholesale market, and while the vast majority of customers are served by monopoly generation and retail services, Virginia law does provide for several avenues for certain customers to access competition. The legislation before this committee today would not fundamentally change Virginia’s hybrid electric system. It would, however, make it easier for businesses to access competition in ways that are already provided for under Virginia law. For example, current Virginia law allows large commercial and industrial customers (over five megawatts) to access competition. Businesses that choose to do so, however, are required to give five-year advance notice to utilities if they enroll with a competitive supplier and later seek to return to utility supply. This needlessly discourages businesses from entering competition, because if it doesn’t work out, they will be trapped outside the utility for half a decade. The five-year requirement is not necessary. Nearby states such as Maryland, Pennsylvania, Ohio, and the District of Columbia require only 15 days’ notice. Similar issues exist for residential and commercial customers who would like access to renewable electricity. Current law provides a mechanism for customers to access competition to procure 100 percent renewable derived electricity. However, mass market customers, including residential, are only allowed to access competition if their utility does not have a renewable offering already. To foreclose this possibility, Virginia utilities have created their own 100 percent renewable products. While these plans offer inferior terms to what a customer could get on the open market, their existence is sufficient under current law to prevent customers from seeking a better option. The legislation before you today would help resolve these problems by reducing the advanced notice from five years to six months, allowing for easier aggregation of demand to meet the minimum use requirement for larger commercial and industrial customers, and by allowing all customers to access competition for renewable electricity. These changes will provide benefits to consumers and help Virginia’s electric markets to function in a more innovative and efficient manner. For these reasons, we urge you to give favorable consideration to HB 2436, HB 2528, and HB 2547. Thank you, Robert Melvin

The addition of odorant to intra state gas pipelines is a critical necessity to the safety of Virginia's citizens, allowing emergency personnel as well as private citizens to be aware of gas leaks in the pipes under their feet, through their yards, and into their houses. This should be expanded to interstate pipelines as well, but at least Virginia can ensure the safety of it's own citizens against catastrophic gas fires.

Vote Yes for HB2545! Currently those forced to live near these pipelines have almost no safety protections when tasteless, odorless, colorless natural gas is forced through transmission lines. While many technologies exist that could help, nothing requires their use. Owners fly planes over pipelines to visually determine if there are changes but do not have the benefit of required stress gauges or similar remote monitoring by available technology. When gas escapes, those exposed will not know until it is too late because gas in transmission lines does not contain the odorant required in distribution lines that bring it to a home or business. Cutoff valves are often located 20 miles apart, meaning that when there is a break, a huge amount of gas must escape after the valve closes whether automatically or after a person manually closes it. Don't believe the industry when they tout the technology used. Ask how often it is used and whether it is used everywhere. Monitoring tasteless, odorless, colorless gas from a distance and even up close is extremely difficult. Today escaping gas is not even measured but accepted as normal activity. Further, the training/information provided to communities and first responders in areas with transmission pipelines is extremely general. It is not tailored to the specific community and its risk. We have no distribution lines and cannot use the gas. We heard more about what to do around distribution gas lines than about what to do around the transmission lines in our community. There are no requirements for the industry to properly train first responders to use equipment required when tasteless, odorless, colorless gas escapes - or to make sure they have the necessary equipment. No one can taste, see or smell natural gas that does not have oderant included. Currently, those unlucky enough to have a natural gas transmission pipeline in their backyard have little safety protection. We are sacrificial. This is unacceptable! We need to at least be allowed to have necessary information to protect ourselves. Without odorant in the colorless, odorless gas, we can't. The federal government finally has a new proposal for CO2 pipelines that, if adopted, might finally lead to some better safety but it has many steps before adoption and will only apply to new facilities. Until now, the industry has effectively blocked requirements for specific safety requirements in this infrastructure. The industry has maximum flexibility to hide and delay information sharing with affected people. The system is so broken that when there is erosion of dirt over a pipeline, the industry tells farmers they have to stop using their land unless they - not the company - replace eroded soil! HB2545 is a critical first step toward giving landowners and communities safety that should be a minimum provided. When land can be taken via eminent domain and landowners and communities have no say over siting, as currently exists, the least we owe people is safety. Today that is not happening. The federal government has not acted and will not for the foreseeable future. Pass HB2545 to signal to all that Virginia cares about citizens forced to live with natural gas infrastructure. Show Virginia doesn't consider us sacrificial!

I am a resident in Montgomery Co and I think I always assumed odorant was mandatory. Except for the MVP of course. It very much should be mandatory. I do not have any gas lines in my on home but I do clean houses for a living and some of those do have gas stoves. The only way I know I have accidently turned the stove knob on while cleaning is when I smell it. Then I panic briefly and cut it off. But Im grateful for that added safety measure. This is a common sense safety measure to keep people and cleaning ladies safe. Please vote YES on HB 2545. This should be one of the easiest bills and shameful for anyone who does vote NO. Thank you, Crystal

Wild Virginia strongly supports HB 2545. This measure is vital to increase the safety of residents and communities where instrastate gas pipelines are located. Including odorant in the gas is simply a common sense way to provide notice to the public and to emergency personnel to leaks and potentially catastrophic release and accidents. David Sligh, Conservation Director, Wild Virginia

I'm writing to ask that you please support this commonsense safety measure for those living along pipeline paths as well as for rural emergency response crews. When I was renting a home in the city of Salem, there were two instances when I was able to detect a methane leak by smelling the odorant, and the gas company came quickly and made the repairs necessary to keep us safe. That was in a tiny (by comparison) line coming into my home, and as scary as that potential was for my family and neighborhood, that risk pales in comparison to a transmission line, an explosion from which would cause catastrophic harm to every creature and structure in a much wider path. This simple change could make an enormous difference in pipeline safety as well as offering some reassurance to landowners who may currently feel they have no protections or recourse. Many rural landowners have very close ties to their property, and may walk them daily to check livestock or monitor other features. Odorant would give them the means to help avert major disasters along pipeline routes, saving the lives of their families and neighbors as well as those of emergency response crews. Please support House Bill 2545. Thank you.

I am writing to support House Bill 2545. I am a land owner in Giles County, living on my family farm in the blast zone of the MVP transmission pipeline. I have researched the safety measures in place now that the pipeline is in service. There are none. I attended an emergency management seminar paid for by MVP. It did not address measures prior to or after an explosion, in fact the word "explosion" was never spoken. I have had 25 years of experience through the USG with emergency exercises and this was the worst effort I have ever witnessed. Although transmission pipelines are large and high pressure and when they fail can cause catastrophic damage, I discovered that transmission pipelines only require one (1) inspection per year. These inspections are sub-contracted and paid for by the pipeline company. The inspections are visual (fly-overs, vehicles and foot traffic). It is therefore clear that inspection and protection against pipeline failure is left to those of us living next to it. Unfortunately, the only tool we have to ensure our safety is visual inspection which may be too late. An odorant would at least give us something to detect and give us a chance to evacuate the area. The choice is clear. The only reason NOT to support this bill is to save pipeline companies money. Supporting this bill will give Virginians at least one useful safety tool.

I live 5 minutes away from the Mountain Valley Pipeline and I support House Bill 2545. It will strengthen gas pipeline safety. I would feel much better with this bill in place knowing that my community has some protection. This bill deserves support because it makes pipelines safer. Requiring odorization in intrastate lines provides a vital early warning system, allowing residents and first responders to quickly detect leaks and prevent potential disasters. This is crucial for protecting lives, property, and the safety of first responders who are often the first on the scene.

A farmer who has a Mountain Valley Pipeline right-of-way running through his cow pasture noticed a sinkhole right above the pipe which could have been created by leakage from hydrostatic testing. Before he could get a PHMSA person to check it out, MVP came and filled it in. Obviously, he is worried that gas could leak there and cause a fire in the grassy right-of-way. If the gas had odorant in it, he would be aware that a leak existed, since he regularly goes out there to check on his cows. Many landowners live even closer to gas pipelines and would be at great risk if a leak caused an explosion or a fire. Adding odorant to a gas pipeline could not be anywhere near as costly as compensating a landowner for an explosion or fire. Virginia has a responsibility for the safety of its citizens. Please put HB2545 into law to ensure our safety.

I support House Bill 2545 and believe it will strengthen gas pipeline safety. Expanding SCC oversight closes dangerous regulatory gaps, protecting communities. Requiring odorization in intrastate lines provides a vital early warning system, allowing residents and first responders to quickly detect leaks and prevent potential disasters. This is crucial for protecting lives, property, and the safety of first responders who are often the first on the scene. This bill is a significant step towards safer pipelines and deserves support.

I’m writing in support of House Bill 2545. This commonsense safety measure would require that odorant be added to any intrastate transmission pipeline in Virginia and correct a glaring safety deficiency in the transportation of highly pressurized methane gas. With the addition of odorant, residents and emergency personnel living, working and serving our communities in close proximity to methane pipelines could detect a leak and alert the pipeline operators and appropriate authorities. This would help prevent disaster and protect the lives of fire emergency responders who are often all-volunteer squads living directly in the communities they serve. Please honor the sacrifices that emergency responders make every day by giving them one more essential tool to protect lives and homes. Thank you.

Chairman Sullivan and members of the committee, My name is Robert Melvin and I am the Northeast region director for the R Street Institute. R Street is a nonprofit, nonpartisan, public-policy research organization with a mission to engage in policy research and outreach to promote free markets and limited, effective government including in relation to electric utility regulations. This is why we have an interest in HB 2436, HB 2528, and HB 2547. Currently states have adopted a variety of models for how to structure their electricity markets. Around a third of states allow for retail and wholesale competition in electricity; another third of states have maintained the vertically integrated monopoly utility system and do not participate in an organized wholesale electric market; the final third have adopted a hybrid approach, maintaining vertical integration but allowing competition in some areas. Virginia is firmly in the hybrid camp. Virginia participates in the PJM Interconnection, an organized competitive wholesale market, and while the vast majority of customers are served by monopoly generation and retail services, Virginia law does provide for several avenues for certain customers to access competition. The legislation before this committee today would not fundamentally change Virginia’s hybrid electric system. It would, however, make it easier for businesses to access competition in ways that are already provided for under Virginia law. For example, current Virginia law allows large commercial and industrial customers (over five megawatts) to access competition. Businesses that choose to do so, however, are required to give five-year advance notice to utilities if they enroll with a competitive supplier and later seek to return to utility supply. This needlessly discourages businesses from entering competition, because if it doesn’t work out, they will be trapped outside the utility for half a decade. The five-year requirement is not necessary. Nearby states such as Maryland, Pennsylvania, Ohio, and the District of Columbia require only 15 days’ notice. Similar issues exist for residential and commercial customers who would like access to renewable electricity. Current law provides a mechanism for customers to access competition to procure 100 percent renewable derived electricity. However, mass market customers, including residential, are only allowed to access competition if their utility does not have a renewable offering already. To foreclose this possibility, Virginia utilities have created their own 100 percent renewable products. While these plans offer inferior terms to what a customer could get on the open market, their existence is sufficient under current law to prevent customers from seeking a better option. The legislation before you today would help resolve these problems by reducing the advanced notice from five years to six months, allowing for easier aggregation of demand to meet the minimum use requirement for larger commercial and industrial customers, and by allowing all customers to access competition for renewable electricity. These changes will provide benefits to consumers and help Virginia’s electric markets to function in a more innovative and efficient manner. For these reasons, we urge you to give favorable consideration to HB 2436, HB 2528, and HB 2547. Thank you, Robert Melvin

I support HB2547.

Though I'm not clear how this bill could actually be implemented, I certainly support the intention for APCo customers to have options to the costly power provided to APCo's captive customers. I hope this will give us ratepayers some options.

Chairman Sullivan and members of the committee, My name is Robert Melvin and I am the Northeast region director for the R Street Institute. R Street is a nonprofit, nonpartisan, public-policy research organization with a mission to engage in policy research and outreach to promote free markets and limited, effective government including in relation to electric utility regulations. This is why we have an interest in HB 2436, HB 2528, and HB 2547. Currently states have adopted a variety of models for how to structure their electricity markets. Around a third of states allow for retail and wholesale competition in electricity; another third of states have maintained the vertically integrated monopoly utility system and do not participate in an organized wholesale electric market; the final third have adopted a hybrid approach, maintaining vertical integration but allowing competition in some areas. Virginia is firmly in the hybrid camp. Virginia participates in the PJM Interconnection, an organized competitive wholesale market, and while the vast majority of customers are served by monopoly generation and retail services, Virginia law does provide for several avenues for certain customers to access competition. The legislation before this committee today would not fundamentally change Virginia’s hybrid electric system. It would, however, make it easier for businesses to access competition in ways that are already provided for under Virginia law. For example, current Virginia law allows large commercial and industrial customers (over five megawatts) to access competition. Businesses that choose to do so, however, are required to give five-year advance notice to utilities if they enroll with a competitive supplier and later seek to return to utility supply. This needlessly discourages businesses from entering competition, because if it doesn’t work out, they will be trapped outside the utility for half a decade. The five-year requirement is not necessary. Nearby states such as Maryland, Pennsylvania, Ohio, and the District of Columbia require only 15 days’ notice. Similar issues exist for residential and commercial customers who would like access to renewable electricity. Current law provides a mechanism for customers to access competition to procure 100 percent renewable derived electricity. However, mass market customers, including residential, are only allowed to access competition if their utility does not have a renewable offering already. To foreclose this possibility, Virginia utilities have created their own 100 percent renewable products. While these plans offer inferior terms to what a customer could get on the open market, their existence is sufficient under current law to prevent customers from seeking a better option. The legislation before you today would help resolve these problems by reducing the advanced notice from five years to six months, allowing for easier aggregation of demand to meet the minimum use requirement for larger commercial and industrial customers, and by allowing all customers to access competition for renewable electricity. These changes will provide benefits to consumers and help Virginia’s electric markets to function in a more innovative and efficient manner. For these reasons, we urge you to give favorable consideration to HB 2436, HB 2528, and HB 2547. Thank you, Robert Melvin

Costco Wholesale Corporationstrongly supports HB 2547 because it allows needed flexibility for Costco to continue to participate fully in the aggregation pilot being offered under Va. Code § 56-577.1. Currently Costco’s participation is set based on the accounts included in its 2018 pilot petition. Costco’s accounts have been adjusted in the 6 years since the 2018 petition was filed, and HB 2547 would allow Costco’s participation to reflect such adjustments rather than being frozen at the list of account in 2018, as long as Costco’s participation otherwise meets the requirements of the aggregation pilot being offered under Va. Code § 56-577.1. In essence, HB 2547 provides a common sense approach to how Costco and other eligible companies participate in the aggregation pilot. Thank you Shay Reed, Assistant General Merchandise Manager/Buyer for Energy, Utilities, and Environmental Reporting Certified Energy Manager Costco Wholesale Corporation

Greetings Labor and Commerce Subcommittee, I'm writing in support of HB2101, HB2755, and HB2578. I live in Loudoun County, where we have over 200 data centers. In our county, data centers are being built near residences, malls, bike trails, parks, pretty much all over the place including where people don't want them. Many of them are pretty loud if you're near them, and I expect that louder data centers are coming because there isn't enough energy, so some art starting to turn to on-site natural gas generation for base-load, non-emergency power. We have one such data center with 8 natural gas turbines. I've heard from friends that live fairly close that they can tell by the sound not just whether or not the gas turbines are on, but how many. The recent JLARC study paints a picture of an industry that has grown out of control, is burdening its neighbors, and is completely unsustainable. While some in my counties Board of Supervisors and Planning Commission seem completely captured by this industry, others are trying to address the problems that we're having as a result of data centers, but are unable to do much due to lack of local authority, and so I must ask the General Assembly for help. As burdened as the public is by data centers in Loudoun County, we need better regulation specific to that industry. These 3 bills would go a long way to improving the situation, specifically: HB2101 Electric utilities; data center cost allocation: This is needed to ensure that all of us ratepayers aren't paying for infrastructure that would not be needed except for this one industry. HB2578 Retail Sales and Use Tax; exemption for data centers, reports: This bill is needed to provide incentives for data centers to adhere to best practices regarding air pollution from on-site generation. Considering the high levels of particulate pollution that some generators emit, this is a public health concern in my county. HB2755 Underground transmission lines; qualifying projects: Loudoun county is being forced to tolerate additional electric infrastructure on huge towers. These lines should be built underground rather than on towers in order to minimize impact on local residents, such as myself. Thank you, -Chris Tandy

Dear Members of Subcommittee #4: I am writing you to ask that you vote HB2101, Electric utilities: data center cost allocation out of the subcommittee and onto the full Labor and Commerce committee for action. This bill would protect ratepayers from increases in their utility bills which would pay utility costs of infrastructure expansion to power data centers. Data Centers need to pay their fair share of utility such costs. I do not wish to subsidize data center utility use. Aditional, I'm asking that you vote to bring HB2755 before the full committee. This bill would fund a pilot program for underground transmission lines qualifying projects. There must be ratepaer fairness in the utility grid system. Thank you, Rev. Dr. Jean Wright, Ashburn, VA 20147

I am writing in support of these three bills.

I am a resident and business owner in Loudoun County where above ground power lines are destroying property values and our quality of life. The main thrust is that this bill provides a framework that permits energy to be delivered to high energy use customers without destroying existing residential and commercial neighborhoods that would otherwise be severely impacted by massive overhead power lines. I speak in favor of this bill.

Please oppose HB2780. As the climate crisis continues to worsen, with severe flood damage from heat-powered Hurricane Helene occurring in Damascus, VA, in Del. O'Quinn's home county, we simply cannot afford to roll back the essential climate protections that the General Assembly enacted in 2020. HR 2780 should be defeated. This bill would halt Virginia’s progress in transitioning from climate-altering fossil fuels to clean, renewable energy. The 2020 Virginia Clean Economy Act (VCEA) requires that large electric utilities phase out fossil-fuel power plants by 2045. HR2780 would exempt fossil-gas power plants from this provision, creating a huge loophole, eviscerating the VCEA. Additionally, vague and confusing language in this bill appears to also exempt certain coal power plants from phaseout if they have carbon capture and storage (CCS) systems (CSS), without necessarily requiring that the CSS capture all of the plant’s carbon emissions.