West Virginia Department of Commerce Public Comments

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Public Comments

West Virginia State Energy Plan

Organization: West Virginia Energy Users Group
Date: November 5, 2012

Name: Holly C. Kauffman
Hometown: Fairmont, WV
Organization: MonPower
Title: President, WV Operations
Date: Tuesday, October 9, 2012

Name: Todd Web
Hometown: Kenova, WV
Date: Friday, September 14, 2012

I first want to thank everyone involved in moving West Virginia forward on all Energy plans especially alternative, renewable and sustainable sources. In reviewing the current discussions it seems that the most qualified and abundant Energy Source available to West Virginia which would provide an immediate impact on reducing our dependence of fossil fuels and creating jobs has been overlooked.

West Virginia's Forest industry provides jobs in every corner of our state and is already providing alternative energy in the form of Wood Pellet Fuel. Appliances are already available and being used to harness this energy in both residential and commercial settings. If our state's energy plan placed more value in the abundant resource we already have, our state could become the leader and model to reducing our country's carbon foot print while creating meaningful good paying jobs. Wood biomass can be used to provide both heat and power reducing or in some cased eliminating our dependence on fossil fuels. The Appalachian Forests are a verified sustainable resource of which the entire state of West Virginia is a part of. If the law makers reviewing this plan would put wood energy at the top of their list everyone would benefit from their wisdom.

Name: John Ackerly
Hometown: Takoma Park, MD
Organization: Alliance for Green Heat
Title: President
Date: Friday, September 14, 2012

We are often amazed how politicians can overlook the obvious: that wood and pellet stoves are the favorite renewable energy devices in West Virginia, as they are in all other states.  As a society, we seem to think that our renewable energy future has to be some new, shiny technology. 

We are a renewable energy group based in Maryland that promotes cleaner and higher efficiency stove technology.  For rural states, providing incentives for the cleanest and most efficient wood and pellet stoves is the most affordable way to help the most residents.  And, it keeps energy dollars not only in the state, but often in the community.  And West Virginia has some of nation’s top wood pellet producers: Appalachian Wood Pellets, Lignetics and Hamer Pellet Fuel.  Those are great, local businesses that would benefit if West Virginia residents heated their homes with more pellets.

We were surprised to that the draft Renewable Energy Policy for West Virginia had substantive discussions about ethanol, biodiesel, chicken litter and other uses of biomass, but nothing about the oldest and most efficient use of it: heating. 

A $2,000 wood or pellet stove can achieve 80% efficiency, double or triple the efficiency of a multi-million plant that uses biomass to make electricity. 

We also feel that the federal government and state governments, including West Virginia, too readily provide rebates and tax incentives to very wealthy families to install solar often on large homes but exclude the favorite renewable energy device of working families – the wood and pellet stove.  A wood or pellet stove can make the same amount of energy in 5 months that the typically array of solar panels make in a year.  

The only drawback of wood stoves is that the older ones are too polluting.  And the outdoor wood boilers can be too polluting so we do not recommend incentives for them.  Giving a tax credit for new wood stoves encourages families to upgrade to a far more efficient stove that uses far less wood.  There are no significant environmental drawbacks to pellet stoves.

Residential heating in West Virginia has been transforming in the last 10 years.  Heating with electricity is up 28% and as of 2010, 40% of the state heated with electricity.   Electric rates are relatively low in West Virginia but still, electricity is usually an expensive way to heat a home and many families could save by using wood and pellets as a primary or secondary heat source. Only 3.8 of residents heat with oil and 4.8 heat with propane, both very expensive fuels. 

Maryland just announced a pilot program to give rebates to the cleanest wood and pellet stoves as part of the same program that gives rebates for solar and geothermal.  Oregon and Montana also gives a tax credit for certified wood and pellet stoves and Idaho gives a generous tax deduction.

We believe the West Virginia’s draft renewable energy plan has a lot of sound advice but it omits a very important use of a very abundant local resource: wood.  We would encourage the state to consider a tax credit for the cleanest and most efficient wood and pellet stoves, just as it provides a tax credit for solar.

Name: Chris Haddox
Hometown: Morgantown, WV
Organization: Morgantown Municipal Green Team
Title: Chair
Date: Friday, September 14, 2012

On behalf of the Morgantown Municipal Green Team (MMGT), and with endorsement from the City Manager of Morgantown, let me extend my gratitude for the opportunity to respond to the three DRAFT reports that will ultimately inform the 2012-17 WV State Energy Plan.

The MMGT appreciates the complexities in creating a visionary energy plan for our state and offers the comments following comments from our September 2012 discussion:

  • The draft plan is, at this point, a collection of three different reports:  Fossil Energy Opportunities, Energy Efficiency Outlook and Renewable Energy Outlook.  While each separate document includes much good information (data), it is unclear how this data will come together to represent an overall strategy that is in line with an agreed upon long-term vision for the state.  Additionally, this individual component approach suffers from the oversight of synergistic opportunities that may be identified and capitalized upon were the subjects of each individual report evaluated in a whole-systems approach.  The MMGT requests a separate comment period on the OVERALL DRAFT PLAN that will ultimately result from the compilation of  these individual documents. 
  • The reports make mention of Integrated Resource Planning (IRP)—the requirement for utilities to utilize the least-cost resource mix for meeting demand needs.  This mix would include   incorporating both demand side (consumer energy efficiency gains) and supply side efficiencies (generation).   As stated on the American Council for an Energy Efficient Economy,  “IRP provides a common framework for balancing these traditional goals by considering all supply and demand options as potential contributors and selecting an integrated set of least-cost resources that meets expected needs.  The result is an opportunity to achieve lower overall costs than might result from considering only supply-side options. Furthermore, the inclusion of demand-side options presents more possibilities for saving fuel and reducing negative environmental impacts than might be possible if only supply-side options were considered.  An integrated resource plan should include the full range of resource options, ranging from traditional power plants to more innovative sources of electricity supply such as power purchases, independent power plants, cogeneration, demand-side management (energy efficiency and load   management), and renewable energy sources.  The MMGT strongly endorses the concept of IRP as being a critical component of the Plan.
  • The potential for utilizing solar power is under estimated.  The MMGT recommends that the plan include a more complete analysis of this sector, considering not only energy reliability/stabilization benefits of this component of distributed generation, but private sector economic benefits as well.  
  • The reports suggest the adoption of more stringent building codes aimed at increasing the energy efficiency of the all sectors of the building stock.  The MMGT strongly supports , and endorses this concept.  In keeping with the past work of the MMGT, it is recommend that the Plan adopt the most current energy codes with automatic adoption of triennial edits/changes to those codes without such adoption having to go through the legislative process. 

Thank you again for the opportunity to comment on the development of the WV State Energy Plan.

Name: Sandra Fallon
Hometown: Morgantown, WV
Organization: Interested, concerned citizen
Date: Friday, September 14, 2012

The draft documents prepared by WVU and Marshall University provide an excellent starting point for analyzing current and future energy prospects from an economic perspective. However, the economic perspective only addresses a portion of the issue. For a more thorough and sustainable approach to West Virginia’s energy future, it is equally important to conduct robust analyses of the environmental and social aspects (including public health) of all forms of energy extraction, production, distribution, and use, i.e. an analysis of the triple bottom line. In addition, an examination of West Virginia’s energy future must be made within the context and framework of climate change. This requires a clear discussion, based on sound science, regarding the need to limit carbon emissions, the specific actions required to adequately measure and reduce those emissions, and to what levels West Virginia intends to reduce them. I highly recommend that you include qualified climatologists and other climate change experts in conducting additional examinations and developing a more comprehensive and sustainable energy plan. A few states that have addressed climate change in their energy planning, and that may provide lessons learned, include California, New York, Washington, and Oregon. Thank you for the opportunity to provide comments on the WV State Energy Plan.

Name: Michael Bloodworth
Organization: Agna
Title: Vice President - State Affairs and Business Development

Name: W. Chris Shepherd
Hometown: Sissonville, WV
Organization: WVU College of Law/Center for Energy & Sustainable Development
Title: Student
Date: Thursday, September 13, 2012

The draft energy plan’s concerted focus on energy efficiency as a valuable energy resource shows true energy leadership that serves the best interests of all West Virginia citizens over the increasingly uncertain long-term. The efficiency component of the draft energy plan is excellent and accurate, particularly in its endorsement of decoupling and of an energy efficiency resource standard. The final energy plan must include those two elements if WV is to remain a true energy leader, rather than become an antiquated, high-cost reminder of an obsolete past.

Despite the draft report’s strength in focusing on efficiency as an energy resource, however, Integrated Resource Planning must also be included and endorsed in the final Energy Plan. Only by that mechanism will our state’s two utilities be required to truly serve the best interests of their captive customers (West Virginians), in ways that do not result in further 50% rate increases such as we have seen in the past several years. Because Integrated resource Planning requires that all potential, achievable energy resources be compared equally on a cost basis, our energy state citizens would be assured of an electrical supply that is truly the most efficient way to meet our needs. Instead, due to our extreme and previously unquestioning over-reliance on a single fuel supply, we are now exposed to global commodity markets, and accordingly have fallen out of the top ten for lowest retail electricity rates in the country. While West Virginia is proud to mine her coal to power America, her citizens should not be burdened with the penalty of increasing rates simply because we do not bother to require better generation planning in our electrical utilities.

Had West Virginia been its own energy leader and instituted Integrated Resource Planning, as have 26 other states, we could have prevented the rate hikes of the past. Thankfully, we can prevent them in the future, particularly if Integrated Resource Planning is combined with a decoupling mechanism.

Such a requirement of our utilities to truly serve the best interests of our citizens would reward the most cost-efficient forms of meeting our energy needs. I hope the final Energy Plan recognizes this no-brainer approach to returning to the low electric rates that our hard-working citizens have earned and deserve.

Name: Robin Wilson
Hometown: Spencer, WV
Organization: WV 350 Reversing Climate Change
Date: Thursday, September 13, 2012

Responses to climate change caused by greenhouse gases such as carbon dioxide and methane should definitely be in our five-year plan. Climate change requires us to mobilize a multifaceted response before we experienced the worst of droughts, floods, and sea level rise. This is a new challenge for us humans, as in the past we could base actions on past experience. For example, not enough food last winter, store more for this winter. To solve the problems of climate change we need to hone our ability to look at the beginning of the problem, which is occurring now, and strategize powerful responses to avert a monumental crisis.
  • Future generations will thank us for the hard work it took to build a consensus for new carbon reducing policies and practices, for new economic models that incentivize acting for the interest of people and planet before profit, and substituting a consumer society with one rich in community and caring. Denial and business as usual are not options. Either we make proactive solutions or we face unacceptable damage.
  • Specifically: we can cut back on our energy use, we can use energy much more efficiently, and we can use renewable energy and products mimicking nature with zero waste cycles. Climate solutions also include integrating solutions to population, poverty, and resource depletion. See Reinventing Fire and Full Planet, Empty Plates under resources for details about making these transitions. 
  • On a state policy level, I applaud the Energy Efficient Resource Standards and Least Cost Planning. I would add Portfolio Standards to encourage renewables like solar and wind power. For example, the state of Maryland’s standard is 20% renewable power by 2022. These changes would create jobs, improve health, and help reverse climate changes.
  • On a national or state level we could have fee-bates where people who buy efficient cars are paid a fee from those that buy environmentally damaging ones, which have proven effective. 
  • We have the capabilities for selfless service for the common good, we are capable of highly creative problem solving, and we can make big changes in a short time.
  • We need all hands on deck. We as Americans mobilized to fight WWII, to end segregation, and to go to the moon. We have the can do spirit needed for a successful sustainable energy transition! 

Resource books with details on the above solutions (available on loan from Robin Wilson):

  1. Reinventing Fire: Bold Business Solutions for the New Energy Era by Amory Lovins
  2. Full Planet, Empty Plates by Lester Brown
  3. Everything Under the Sun: Toward a Brighter Future on a Small Blue Planet by David Suzuki
  4. Storms of my Grandchildren by James Hansen 
  5. The Transition Handbook: From oil dependency to local resilience by Rob Hopkins 
  6. Earth: Making a Life on a Tough New Planet by Bill Mckibben 
  7. The Rough Guide to Climate Change: the Symptoms, the Science, the Solutions by Robert Henson 
  8. Our Choice: A Plan to Solve the Climate Crisis by Al Gore 
  9. The Post Carbon Reader: Managing the 21st Century’s Sustainability Crisis Edited by Richard Heinberg 
  10. The Weather of our Future: Heat Waves, Extreme Storms, and other Scenes from a Climate-Changed Planet by Heidi Cullen. 

Name: Tammy Stafford
Hometown: Charleston, WV
Organization: Appalachian Power
Title: EE Program Coordinator
Date: Thursday, September 13, 2012

Appalachian Power offers the following comments on the draft Energy Efficiency Policy: Outlook for West Virginia recommendations regarding utility efforts:

Establishment of stakeholder working group to provide guidance on EE program elements: Appalachian Power supports stakeholder meetings and has their first meeting scheduled for October.

Implementation of decoupling or a similar mechanism to allow for reasonable recovery of utilities lost revenues resulting from State-mandated EE programs: Appalachian Power supports the recovery of utilities lost revenue through the use of a Lost Revenue Recovery Mechanism rather than Decoupling. Appalachian Power looks forward to participating in future discussions on how to address this challenge.

Establish an Energy Efficiency Resource Standard with targeted goals for producing energy savings via EE programs: Appalachian Power believes that the Public Service Commission is in the best position to determine the appropriate level of ratepayer-funded, utility-sponsored EE considering the unique factors associated with individual utiliies, not limited to program achievement and rate impacts. Additionally, Appalachian Power believes that the draft report has not accurately represented residential household consumption patterns.

The Draft Energy Efficiency Policy Outlook for West Virginia asserts that West Virginia, has "the highest residential energy consumption per household" by incorrectly including electrical system energy losses in their calculation. To examine household energy consumption, "delivered energy" must be used, as is consistent with the EIA Residential Energy Consumption Survey (RECS). Further, using that general methodology will not yield any important insight as there are several factors, the most obvioust being climate, that will greatly overwhelm any state-to-state differences due to efficiency.

Name: Kevin Fooce
Hometown: Point Pleasant, WV
Date: Wednesday, September 12, 2012

While the authors of this report recommend staying the course, I have to ask is that what we really need to do. We can at this time continue to us our natural resources as a primary energy source, but also foster the creation of new production and markets in our state. As a prime example I have been involved with several companies which have been curious about installing solar for a variety of reasons. Some are so they can meet word wide sustainability portfolios in their factories. Other such as Patriot Coal expression of interest in installing solar on some of the old surface mine sites.

With the expansion of our energy portfolio into other markets, we actually start building to our existing workforce. At this time we have several institutions training workers for the solar installation and maintenance fields. This includes both collage and apprenticeship programs such as the ones ran by the International Brotherhood of Electrical Workers and their 6 locals and 4,200 members in WV. We are also utilizing several aluminum extrusion operations and metal fabrication facilities to make the framework which support and hold the solar panels. West Virginia also has a number of solar contractors 7 of which have primary business function as the installation and maintenance of these systems. One of these companies by itself has installed nearly 1 megawatt of capacity. This company by itself may accounts for over 100% of what this report states WV has installed.

A look at some of the maps shown in this report also shows a partial list of items surrounding states are doing to attract and grow their renewable energy markets and create jobs. These same states are seeing increase employment along with reduced long term utility cost for residential/commercial operations and local/state governments. Some institutions such as Ohio University and the University of Maryland are creating programs and installing solar and reducing cost at an alarming rate while our institutions just 100 miles away continue on the path of the last 100 years. One of our states largest utilities actually has a 7 megawatt solar farm less than 100 miles from our border near the city of Columbus Ohio. They also have solar on many of their maintenance facilities in Ohio. A 22 megawatt farm is in the final planning stages within 40 miles of Parkersburg WV but will be located again in Ohio.

With just these examples along with our growing population and the need for good high paying jobs, I ask you can we afford to continue down the dirt road we are on now, or do we need to start building a highway? Do we have a real reason to say no to starting the process to build a new economy and increase the wealth our state needs? Should we wait and let the other build the facilities that train, installs, and manufactures these products, or should we start the process of moving into the 21st century?

What I would recommend is simple; give incentives to the residential market such as increased cap on tax credits for home owners. Give tax credits for building multi-unit dwellings that use renewable energy. Tax credits for businesses that use renewables for power, heating, day lighting, etc. Create a technology transfer program that utilizes our universities to develop the ideas and our business community to produce the products our young scientist and business leaders come up with. Allow our communities to utilize their waste water and trash to produce energy and sell it. Create a program to install solar on the roofs of any and all local, county, and state buildings to reduce the cost of power to the tax payers of the state while increasing our employment base.

We need to start to move ahead and not fall behind. Just last quarter the US installed enough solar to replace a mid-sized power plant. We need to look to the future now, not 30 years from now.

Below is a list of problems just in the solar portion of the renewable energy paper.
  1. 1: Page 8 figure 1 shows the amount of renewable energy produced in the US in 2010. It is well worth noting the amount of renewable energy produced in the US in 2011 is now 13% or 5% higher than the chart shows. This is a major increase in just 1 year and show the growth of the industry. http://www.eia.gov/energy_in_brief/renewable_electricity.cfm
  2. 2: Page 9 figure #2 notice the sharp increase in the use of renewable resources in the 2000-2010 sectors. With this in mind we can come to a conclusion that renewable energy is a source of jobs and energy we should not ignore.
  3. 3: Page 12 Conclusion 3 economic value of solar is less. Economic impacts should be considered on a megawatt per megawatt bases instead of what the state has now. As an example a 1,300 megawatt coal fired power plant employees in the neighborhood of 150 people, transportation of fuel to the plant employees another 15 to 20 and mining of this fuel will employ between 25 to 35 people in a deep mine setting surface mine less. This brings the total number of people employed directly producing electricity and fueling this plant to about 200, or ration of 6.5 megawatts per person employed. Solar on the other hand will require 7 people per megawatt for upkeep and maintenance. Solar in the end when taking into account wages and highest available tax rate revenues (personal income taxes) would be a much better source of income to the state along with decreasing unemployment and welfare programs. This could go a long way in saving the state money.
  4. 4: Page 12 Conclusion 4 price hedge. Every long and short term forecast for fuel cost show all sources rising as far as they can project. http://www.blackgoldglobal.net/upload/CLSA%20Nov%2010%20Full_report.pdf http://www.be.wvu.edu/bber/pdfs/BBER-2011-12.pdf
  5. Page 20 map. Notice we have no solar marked on this map. We do however have several large installation in our state some are notable. Such as a 77kw on the R. C. Byrd Federal Court House in Charleston, 21kw at the Hurricane Waste Water Treatment Plant, several buildings in the WVU system, Morgan County Court House, along with many other institutions.
  6. Page 38 notices the map and WV has no incentives, this means no jobs in this field.
  7. Page 43 Paragraph 1 states in 2011 2,500 megawatts of solar was installed when in fact we had a little more than that installed in 2010, 2011 should actually read we had 4,383 megawatts of large scale solar installed with a possible 3,500 more coming on line in 2012. I used Wikipedia on this one since the authors of this paper seemed to like it. http://en.wikipedia.org/wiki/Solar_power_in_the_United_States
  8. Page 43 Notice that WV has nearly 70% of the potential that the best location listed in the chart has and nearly 87% of the potential cities such as Austin TX has which we would all consider a good location for solar.
  9. Page 44 figure 11 shows WV only had around 660 kW of installed large solar in early 2012. In early 2012 Mountainview solar installed one solar array that is a little over 350kw by itself, the RC Byrd Federal Court House in Charleston has a 77kw array, and the Hurricane Waste Water Treatment Plant has a 21kw array these figures place a question mark on this 660kw figure. http://www.mtvsolar.com/blog.php?id=14&p=&search http://www.wvgazette.com/News/201104041235 http://www.solardock.com/content.php?page=Government&parent=25  
  10. Page 44 figure 1 for some reason forgot to also include New Jersey on the list. This state alone has 306 megawatts installed in 2011 with another 132 megawatts expected to be installed in 2012. With installed numbers this puts this one state installed capacity larger than the installed capacity of all others listed in the chart. http://en.wikipedia.org/wiki/Solar_power_in_New_Jersey 
  11. Page 44 figure 1 amount of solar in Pennsylvania. The Keystone State has 6,700 of its residents working in the solar jobs sector, second only to California. With 600 state businesses currently working on installing solar energy systems — with and a total of 130 MW of solar energy set to be installed in Pennsylvania by the end of 2011 — expect that number to rise. http://www.getsolar.com/blog/pennsylvania-makes-big-quick-strides-in-solar-energy/14695/ 
  12. Page 46 2 trending states the price for panels are at $2 and not expected to fall much. A recent price sheet from a major supplier of panels has some listed at $.58 per watt. This is about a 75% decrease over what is quoted. http://www.sunelec.com/ 
  13. Page 46 Table 3 is a massive disservice to anyone who is getting paid to do this report and should be thrown totally out of this paper. I just did a quick search for Pennsylvania and found several newer facilities with many more that are old news now. http://www.communityenergyinc.com/about-us/press-releases/press-release-detail/article/community-energy-will-build-largest-solar-power-project-in-pa/ http://www.conergy.us/Utility-scale-Solar.aspx 2 farms from this company http://www.earthtechling.com/2012/02/solar-powered-mushroom-farm-pops-up-in-pa/ http://www.earthtechling.com/2010/11/pennsylvania-pretzel-king-goes-solar/ 
  14. Page 47 figure 12 it is important to note that actual plant investment decisions are affected by the specific technological and regional characteristics of a project, which involve numerous considerations other than the levelized cost of competing technologies. A related factor is the capacity value, which depends on both the existing capacity mix and load characteristics. Policy-related factors, such as investment or production tax credits for specified generation sources, can also impact investment decisions. Finally, although levelized cost calculations are generally made using an assumed set of capital and operating costs, the inherent uncertainty about future fuel prices and future policies, may cause plant owners or investors who finance plants to place a value on portfolio diversification. EIA considers all of these factors in its analyses of technology choice in the electricity sector. When looking at the above facts one cannot simply assume the levelized cost as anything more than one of many items we need to look at when implementing a utility power project. http://www.eia.gov/oiaf/aeo/electricity_generation.html 
  15. Page 48 paragraph 1 this is why we need a consistent policy to support and grow all resources regardless of type. 
  16. Page 48 paragraph 2 with the use of solar as noted in this paragraph it will not do away with our current energy sources but simply add to the mix. As stated not all power will be reduced by an equlivant amount of another energy source but it will reduce at some rate other than unity. 
  17. Page 48 paragraph 2. We need to read the conclusion of the paper instead of a summary of the paper. If PV becomes economically attractive enough to be deployed at large scale, intermittency is likely to be matched with dispatch able power, storage, and/or demand response. It may be argued that the intermittency of solar PV is not an integration issue because wind is also intermittent and has been integrated at scale. In systems with relatively large fractions of wind, control issues are generally solved by fast-ramping assets either within the control area or through an interconnection.13 such compensation has economic costs. Knowledge of the character of the intermittency can be used to minimize the costs. As argued previously for the case of wind, 6 an ensemble of generators, energy storage, and demand response would likely be a more economically efficient solution to match the linear region observed in the power spectrum of PV array output power than a source with a single ramp rate. http://www.clubs.psu.edu/up/math/presentations/Curtright-Apt-08.pdf 
  18. Page 48 paragraph 3 real-time power quality has been a problem with the grid since we started using switching power supplies in our electronics and lighting. This problem is now being solved with the next generation of PV inverters on small scale systems. 
  19. Page 48 paragraph 4 one to one. What is missed on this topic is no two power sources are ever a one to one ratio on the amount of fuel one will save when bringing on a second source. This has been known for years in the power industry either on generator systems such as large hospitals with a multi generator back-up supply or utilities. 
  20. Page 48 Future Prospects has already been answered in Page 46 2 Trending. 
  21. Page 49 paragraph 1 lower insolation has been addressed previously, some of the papers sighted are now more than 5 years old, and considering that so much of the situations in this paper are from 2010 the next few years have now arrived. 
  22. Page 52 Figure 13 shows WV is behind the curve and will continue to fall behind all our surrounding states if we do nothing. 
  23. Page 54 the reason to expand any resource is to stay competitive and create jobs. Without expanding WV will continue to fall behind surrounding states, loose tax revenue and never gain jobs in new fields so we can diversify our workforce and create a more stable state economy.

Name: Chris Haddox
Hometown: Morgantown, WV
Date Wednesday, September 12, 2012

Thank you for the opportunity to submit my comments on the draft documents that will inform the 2012-17 WV State Energy Plan. 

While I find each of the DRAFT documents to contain many piece of valuable information, I feel they are lacking in overall vision.  I suppose the Plan will ultimately be some sort of compilation of these DRAFT documents, so it makes commenting on a Plan a bit of a guessing exercise.  Considering the three topic areas separately marginalizes the opportunity to find synergies among the topics, in much the same way that a linear approach to the design of a building often leads to eventual problems with the actual construction.   It is my hope that there will be opportunities to address this shortcoming and to look at the overall plan in a more holistic fashion.As my area of interest and expertise lies primarily with the built environment, my main commentary on substance is in support of more stringent building codes, names the ICC suite of codes, and more specifically the International Energy Conservation Code.  I support the adoption of the 2012 IECC and the automatic adoption of new codes as they are produced on the 3 year cycle.  According to the Energy Information Administration and US Census Data, West Virginians use more energy per capita than most other citizens of the United States.  Inefficient building stock is a primary driver of the high usage.  Demand side efficiency measures are by far the most economical sources of "new" energy and West Virginia should be mining these efficiencies.   I also support Integrated Resource Planning as a way to fully identify and prioritize these efficiency opportunities.  As economic opportunity seems to be of concern, I would argue that having a State Energy Plan calling for business development related to energy efficient products and materials could be a catalyst for attracting and developing small businesses involved in that particular sector.  My utility provider, First Energy, offers many more incentives for becoming more energy efficient to its customers in our neighboring states than it does to West Virginia customers and I feel the State Energy Plan should call on all energy utility providers to be required to first think, and act, in terms of long-term efficiency measures as opposed to focusing on supply side issues.  Distributed generation via solar opportunities is given a wash in the draft documents.  There are economic opportunities, as well as energy security and stability opportunities with solar that are being overlooked.  In addition, the proliferation of small photovoltaic businesses has economic implications that are not fully explored in the draft documents.    I am against the notion of CTL as research indicates it is a net energy loser and has an significantly larger carbon footprint  than conventional petroleum fuels.  In the absence of climate protection policies, I can see where CTL would make sense from a purely economical (cost of fuel) perspective. 

As our country recognizes climate issues, but seems flummoxed about how to deal with them, CTL might make short term sense. Long term CTL production, however, is sure to not make sense in light of climate regulations that will most certainly have to be implemented.   Thank you.Chris Haddox

Name: Maryellen York
Hometown: Inwood, WV
Date Wednesday, September 12, 2012

Why doesn't the states' study of renewable energy include micro hydro power? With all the creeks and rivers in the area, if homes along those waterways used micro hydro power, it would be a real help.

Also, I think grid-connected home systems should be allowed to make more than the energy to supply the home and donate the additoinal energy to Churches and schools. Then, Churches and schools could negotiate for group discounts for their members to have solar, wind or micro-hydro power installed for their constituency. It would be a win-win for everybody but the greedy power companies.

Name: Will Castle
Hometown: Granville, OH
Date Tuesday, September 11, 2012

On page 9 of the Draft Plan, the residential household consumption figures are completely wrong. The numerator includes "losses" associated with the production of electricity and thus greatly inflates household consumption figures. Because producing electricity is only 50% (or worse) thermally efficient, states that use a greater percentage of electicity relative to other fuels will fare worse in this (valueless) comparison, even though households are being equally efficient. This occurs because a large percentage of the population uses electricity to heat their homes (instead of natural gas). This is a question of geography and not something that can be solved with efficiency. Thus, West Virginia has not "fallen behind" other states and households do not use 19% more energy than the average US home - something that on closer inspection should have been obvious to the report's authors. Do not base any policy solely or in part on this fundamental misuse of data.

Name: David Umling
Hometown: New Creek, WV
Date Monday, September 10, 2012

I oppose the development of Industrial Wind Energy to satisfy the State's future energy needs. Industrial wind production is inherently unpredictable and variable over short periods of time. It creates unpredictable instability in energy supplies and cannot serve as supply of reliable or useful electricity. West Virginia needs to depend on reliable electricity and Industrial Wind has not shown that it can meet that demand. Other sources of electricity should be pursued and industrial wind energy should be dismissed. Its environmental impacts on the state's valuable forest resources are too great to justify its use.

Name: Brad Stephens
Hometown: Morgantown, WV
Organization: Allegheny Highlands Alliance
Title: Executive Director
Date Thursday, September 6, 2012

The Allegheny Highlands Alliance, Inc. (“AHA”) is a nonprofit organization which seeks to advance public knowledge and understanding of the cultural and environmental significance of the major ridgelines that comprise the Allegheny Highlands, and to preserve and protect areas of particular importance in this region. AHA’s membership is comprised of residents of the states of West Virginia, Pennsylvania, Maryland, Virginia and North Carolina. AHA would like to thank the Division of Energy for the opportunity to comment on the draft energy plan.

AHA generally endorses the policies proposed in the document Energy Efficiency Policy Outlook for West Virginia, and concurs with the assessment of this section of the energy plan set forth in the comments submitted by Energy Efficient West Virginia on August 30, 2012. AHA also supports the legislative adoption of integrated resource planning for the state’s electric utilities. Although AHA opposes coal mining utilizing mountaintop removal and is greatly concerned about the impacts of Marcellus shale development on the highlands’ water resources, the organization understands that coal and gas will continue to play a role in West Virginia’s energy picture, as set forth in Fossil Energy Opportunities for West Virginia.

AHA supports a shift to cleaner energy sources, but not regardless of the social or environmental costs imposed. Thus, because AHA is primarily focused on slowing the proliferation of utility-scale or “industrial” wind energy facilities in the Allegheny Highlands, AHA submits comments narrowly tailored to address the conclusions and recommendations set forth in Chapter IV of the document Renewable Energy Policy Outlook for West Virginia. As a point of clarification, AHA uses the label “industrial wind” to signify the industrialization of our mountain landscapes, which results from the construction of the massive wind turbines used in such projects, as opposed to smaller-scale models utilized by individual households and businesses.

AHA commends the authors of this document for eschewing a repackaging of industry propaganda and instead presenting a largely even-handed assessment of the limitations of wind energy in the broader electricity generation picture. As noted in the report, according to estimates prepared by the U.S. Department of Energy’s National Renewable Energy Laboratory, perhaps half of the marketable industrial wind energy capacity on private land in West Virginia has already been utilized. Further, because electric generating units in West Virginia access transmission facilities and participate in wholesale power markets controlled by a regional transmission organization (“RTO”), wind energy’s actual contribution to and dependence upon this regional grid system must be considered.

As a federally-sanctioned RTO, PJM Interconnection oversees the high-voltage transmission of electricity and manages a wholesale power market across all or parts of 13 states and the District of Columbia. Under PJM rules, any grid-scale wind facility commencing commercial operation in West Virginia is eligible to participate in the RTO’s capacity markets, but only to the extent of 13% of its peak or “nameplate” generating capacity. This figure was derived from historical summer operating data from wind units in PJM, and reflects the mean of all recorded capacity values for those units; therefore, it is an accurate measure of what can be expected going forward for a wind project.

Applying the 13% standard to the approximately 700 MW of remaining wind energy capacity in the state (cited in the report) results in a total “capacity credit” of only 91 MW, which represents only a small fraction of the capacity afforded by any major baseload power plant in West Virginia and only a tiny sliver of the capacity needed to serve native customer load in West Virginia, much less across the entire PJM footprint. Perhaps more importantly, as conceded in the report, the wind resource in West Virginia pales in comparison to the potential in various Midwest states, which, AHA would add, include Illinois and Indiana—two states with a heavy stake in the PJM grid and its associated markets. All of this context should be seriously considered, in addition to the balancing and backup complications induced by the intermittent output of wind facilities, which are discussed in the report.

AHA remains unconvinced that any significant, lasting and positive economic benefits from industrial wind have been realized in the state, particularly given that development threatens to impose negative economic impacts in the form of diminished values of surrounding real estate and reduced appeal of the state’s natural areas to tourists. To date, most studies addressing economic impacts of wind energy development have either been commissioned by industry trade groups or have otherwise been unduly biased in favor of results favorable to wind developers.

AHA further disagrees with the report’s assessment that siting of wind facilities in the state is “very difficult.” It is true that substantial documentation must accompany a wind developer’s application to the Public Service Commission (“PSC”) for a siting certificate. AHA is aware of only one project application out of many, however, for which the PSC declined to issue a siting certificate. Notably, the PSC’s denial of that developer’s application was essentially due to critical elements missing from the application, not from the Commission’s balancing of competing interests based on the substance of the application. Moreover, regardless of the volume of information presently required by the state’s regulatory processes, the PSC lacks the internal expertise necessary to make a serious evaluation of the impacts of wind energy facilities, and no other state agency is required to or otherwise is afforded an opportunity to participate in the siting certificate process.

Based on the above, AHA cannot concur with the report’s recommendation that current policies regarding grid-scale wind energy should be maintained. AHA believes serious reforms to the PSC’s siting certificate process, and more importantly, the applicable statutory structure, are long overdue. Wind energy enjoys an embarrassment of riches when it comes to subsidies, and the present economic incentives embodied in West Virginia law do not bring us closer to a more stable and efficient energy future.

AHA does agree, though, with the recommendation that results of studies concerning the integration of variable energy resources should be closely monitored. While the organization is skeptical that such studies will produce a “fix” for wind energy’s many weaknesses as a source of reliable electricity, the fruits of these efforts may indeed serve to enlighten both policymakers and the state’s citizenry as to the technology’s limitations.

Finally, AHA urges the Division of Energy to include an honest and critical assessment of industrial wind in the final version of the Energy Plan—one long on substance and free of misleading industry propaganda. Trade group buzz words such as “clean” and “green” appeal superficially to the emotions, but they do not provide the foundation for a meaningful energy strategy for the future. Massive wind turbines on Appalachian ridgetops kill untold numbers of bats and birds every year, blight the splendid viewsheds of the highlands, and diminish the character of rural mountain communities, while doing nothing to offset environmental degradation imposed by other sources of electricity. AHA submits that industrial wind should have no place in West Virginia’s energy plan.

Name: Bill Howley
Hometown: Chloe, WV
Organization: Coalition for Reliable Power
Title: Chairman, Steering Committee
Date Thursday, September 6, 2012

The Coalition for Reliable Power is a coalition of citizens, businesses and organizations working together to create an electrical system in West Virginia that is reliable, affordable and sustainable. Because our focus is on our state’s electrical system, our comments will focus on this aspect of the 2013 – 2017 Draft Energy Plan.

We were generally encouraged by the energy efficiency analysis and recommendations included in the Draft Plan. Increased energy efficiency, as the Draft Plan states, will continue to be the lowest cost electricity resource throughout the five year plan period. There are substantial opportunities for electricity savings through energy efficiency, because West Virginia is currently among the highest per capita residential energy use states in the US.

Throughout these comments, we will refer to the draft report Fossil Energy Opportunities for West Virginia as “the fossil energy section,” the draft report Energy Efficiency Policy Outlook for West Virginia as “the EE section,” and the draft report Renewable Energy Policy Outlook for West Virginia as “the renewables section.” We will refer to the overall draft of the Division of Energy’s 2013 – 2017 Energy Plan as “the Draft Plan.”

West Virginia Needs an Integrated Energy Plan We were disappointed that the Draft Plan was broken into three discreet sections, with no attempt to integrate them into unified policy goals and recommendations. The true value of having a state energy plan is created only when we identify economic trends and design a comprehensive, flexible plan that allows West Virginia businesses and energy users to respond to change. While it is important to isolate trends and characteristics of different choices, we only create value with an integrated analysis that helps us weigh those choices and make good decisions among them.

West Virginia clearly has had extensive coal and natural gas reserves. These fuels will continue to play a large role in the state’s energy future. As the fossil energy section points out, however, fuel based electrical generation is subject to the vagaries of commodity markets and adverse production conditions, and has significant adverse health impacts. Over the past ten years, almost all of the significant increase in electric rates for all West Virginia consumers has been caused either directly by higher coal fuel costs or investment in physical plant designed to reduce dangerous coal exhaust emissions. Since 2007, residential electric rates have risen over 33% for FirstEnergy’s West Virginia customers and over 50% for AEP’s West Virginia customers. Natural gas is the cheaper fuel at the moment for electrical generation, but price swings are inevitable. Keeping West Virginia’s electric power generation tied so closely to the cost of fuel, coal or gas, is not a sensible long term policy goal. There are two sources of electrical power capacity that are not vulnerable to shifting fuel costs, namely renewable generation, particularly photovoltaic and wind power, and gains resulting from increasing energy efficiency. West Virginia needs a flexible and diversified electricity portfolio to provide the diversity and flexibility required to increase the reliability and a lowest cost electrical system for our state.

Integrated resource planning (IRP) is used in twenty six states to build cost-benefit analysis into public service commission processes and state energy policies across the US. IRP requires power companies to identify electricity needs and provide a cost-benefit analysis of all possible means of providing the capacity to meet those needs. As the efficiency section points out, investment in efficiency savings is always the lowest cost source of meeting electrical need, by a significant margin. West Virginia’s new Energy Plan should advocate for the immediate implementation of IRP at the West Virginia Public Service Commission.

Renewable Power in West Virginia

The renewables section provides an overview of photovoltaic generation in West Virginia and the surrounding region, but the authors fail to note important aspects of small scale solar power development:
  • There is passing reference to enhanced system reliability from distributed generation. The fact that the authors give this impact short shrift seems odd in light of the fact that West Virginia has experienced two major collapses of its electrical distribution system in the last three years.
The costs of insuring the reliability of the current centralized generation/distribution system in West Virginia were not analyzed in the Draft Plan. The repair costs for the 2009 and 2012 blackouts will likely total over $100 million. The West Virginia Public Service Commission has already deferred rate recovery for the 2009 costs, resulting in additional rate increases for power company interest costs. It is likely that when utilities submit their repair costs for the 2012 blackout, these costs, plus resulting interest costs, will be deferred as well.

In the WV PSC investigation of the 2009 blackout, Senior PSC Engineer James Ellers testified that West Virginia was one of only sixteen states in the US that had no reliability performance standards for electric utilities. Ellers also testified that while the WV PSC had allowed Allegheny Energy (now merged with FirstEnergy) to raise rates to generate cash flow for distribution system maintenance and repair, by the time of the 2009 blackout, Allegheny had not spent the funds it had collected as promised. Allegheny’s subsidiaries subsequently spent the balance of their repair and maintenance account on emergency repairs. The WV PSC is in the process of developing reliability performance standards. In the first order in the case, the Commissioners opined that instituting these standards would lead to more rate increases.

Unless the two Ohio-based companies that own our state’s electric utilities make significant investment in rebuilding their fifty year old distribution systems, paid for by further rate increases, West Virginia rate payers will face more and more blackouts from less and less severe weather events. Increased blackout frequency will also place more and more burden of the costs of lost food and business on West Virginians, in addition to the resulting rate increases.
  • The renewables section also fails to include any calculation of the benefits of increased solar generation to improving public health by reducing various emissions from fossil fuel combustion. The US Environmental Protection Agency lists West Virginia as the state with the highest rate of premature deaths (at 14.7 per 100,000 adults in 2010) from fine particulate matter whose primary source is coal-fired power plants.
  • There is also no mention in the renewables section of the relatively speedy deployment of small scale solar installations compared with the much longer construction times for gas and coal fired plants. Because PV deployment occurs in very small increments, new capacity can also be calibrated to meet shifts in capacity needs in very short time periods. This relatively rapid scalability of PV power has been demonstrated in a number of states, particularly California and Vermont. Given the recent capacity problems generated by West Virginia subsidiaries of FirstEnergy and AEP, it would seem that our state is in need of the kind of flexibility that small scale solar deployment provides.
  • In discussing various incentive systems for promoting investment in solar power generation, the renewables section’s authors point out that solar carve out and SREC systems require some new administrative overhead. However, the extensive use of these management systems throughout the PJM region indicates that these administrative costs are not a problem in states with a commitment to increasing solar power generation. If simplicity is a goal of policy makers, a number of countries and US localities have demonstrated that a feed in tariff, graduated to phase out as capacity targets are met, is probably the simplest solar incentive system.
  • The authors of the renewables section used a levelized cost analysis to compare costs of investment in grid scale solar generation with other types of power generation. This analysis must make assumptions about fuel cost trends for fossil source energy. The uncertainty of fuel price trends does not apply to solar power investment, where, once the initial capital investment is made, fuel costs are zero. In the past month, FirstEnergy made the claim that expanding its coal-fired generation capacity in West Virginia will provide long term rate stability, despite the fact that coal is a more expensive fossil fuel choice at the present time. The real long term cost stability of renewable power is not factored into the Draft Plan’s comparison on solar power to other power sources. Solar power’s zero fuel costs are the ultimate price hedge, particularly when the cost of delivered coal rises 70%, as it did between 2000 and 2009.
  • Even a small fraction of the hundreds of millions of West Virginia rate payer dollars spent on coal cost increases and equipment to manage coal’s health impacts over past ten years, would have provided a significant incentive for homeowners and small businesses to invest in aggressive energy efficiency investments and solar power development. These investments would have provided real long term solutions to fuel cost risk and damage to West Virginians’ health caused by current generation technologies.
Levelized generation-only cost comparisons with solar power under-estimate the rate savings in avoided reliability costs, personal savings in healthcare costs and future cost stability hedging benefits provided by distributed solar generation. The Draft Plan should have gone beyond a generation-only comparison in its analysis of renewable power costs and benefits.

The authors of the renewables section correctly spent little time discussing the 2009 Alternative and Renewable Portfolio Standard, because this legislation will have no impact whatsoever on investment in renewable power in West Virginia.

Recent Electrical Industry Trends Ignored in the Draft Plan The West Virginia electrical system has experienced three major trends over the past five years that receive little or no mention in any of the three sections of the Draft Plan:
  1. Unprecedented consumer rate increases, due primarily to coal price increases and the negative health impacts of burning coal,
  2. Two major collapses of the West Virginia electrical distribution as a result of weather events and reduced investment in maintenance by West Virginia’s Ohio-owned electric utilities which indicated the need for costly monitoring of and investment in distribution system performance, and
  3. Recent attempts by both AEP and FirstEnergy to shift the costs of more expensive coal-fired generation capacity into the West Virginia rate base from Ohio, largely as a result of deregulation of Ohio electricity markets.
  4. Coalition for Reliable Power Recommendations Development of a fully integrated planning process that prioritized reliability, flexibility and long term investment in lowest cost power resources, on both the demand and supply sides, should be the basis for any plan for West Virginia’s energy future.
The Coalition for Reliable Power makes the following policy recommendations to be included in the 2013 – 2017 Energy Plan:
  1. The Coalition strongly supports the Draft Plan’s endorsement and energy efficiency standard for West Virginia. The Coalition also strongly supports the Draft Plan’s endorsement of decoupling of base rate cost recovery from electric rate setting to protect utilities from under-recovery of overhead and capital costs from loss of power sales due to efficiency improvements.
  2. The Coalition would like to see support in the 2012 – 2017 Energy Plan for legislation to require the West Virginia Public Service Commission to establish an Integrated Resource Planning process for our state’s electric utilities to insure that West Virginia rate payers have access to the lowest cost electricity resources.
  3. The Coalition believes, contrary to the opinions expressed in the Draft Plan, that investment by West Virginia rate payers in a solar power incentive system in West Virginia is justified by the benefits created by diversification of our state’s energy portfolio, increases in the speed at which marginal capacity can be ramped up, and the benefits to overall system reliability. The Coalition believes that either a solar carve out and SREC market or a feed in tariff program would be equally appropriate tools for achieving this incentive, if properly designed and implemented.

As the authors of the renewables section pointed out: 
“There are benefits to getting experience with an emerging technology such as PV systems. Individuals and households who install PV systems will come to understand the attributes of the technology and can participate in future adoption as technology improves. Local installers also develop valuable capacity regarding utilization of the resource.”

These human capital benefits, as well as the new jobs and businesses created, are essential if West Virginia is to remain competitive with innovative efficiency, renewable power and microgrid technologies that are maturing in other states.

Thank you for this opportunity to participate in building West Virginia’s energy future.

Submitted by:
Coalition for Reliable Power
Steering Committee:
Bill Howley
Keryn Newman
Patience Wait
John Christensen

*U.S. Department of Energy, The Potential Benefits Of Distributed Generation And Rate-Related Issues That May Impede Their Expansion, 2007
*Perez, Zweibal, Hoff, ”Solar Power Generation in the U.S.: Too Expensive or a Bargain?” University of Albany/George Washington University, 2011 *Farrell, J., “Democratizing the Electrical Sector” ILSR, 2011 *Ban‐Weiss G. et al., “Solar Energy Job Creation in California”, University of California at Berkeley.
*M. Wei et al., “Putting renewables and energy efficiency to work: How many jobs can the clean energy industry generate in the US” University of California at Berkley *Sawin, Flavin et al. “The American Path to Energy Security” World Watch Institute. Washington DC

Name: Aaron Sutch
Hometown: Morgantown, WV
Organization: The Mountain Institute
Title: Energy Program Manager
Date Thursday, September 6, 2012

Thank you for this opportunity to comment.

I am requesting that the authors of the Draft Report reconsider their characterization of solar energy to accurately reflect current data on its ability to enhance electric grid infrastructure, benefit ratepayers and empower local job creation.

The report’s economic analysis of solar energy in West Virginia is very limited and does not take into account the following factors:

    • Solar produces most during times of peak electricity demand. This obviates the use of less-efficient and more costly peak power plants.
    • Provides grid security against blackouts and terrorist attacks while improving overall grid reliability
    • For this reason the U.S. military uses solar in domestic and international operations
    • Saves on transmission and distribution losses which are typically 8%
    • Provides hedge against rising electricity based on fuel price volatility (WV electric rates have increased by 50% over the last 5 years due to the increasing cost of coal)
    • Enables private subsidization of electricity generation assets without passing on costs to ratepayers via the guaranteed rate of return that the PSC guarantees investor-owned utilities for expansion of generation assets
    • Increased grid reliability benefits ratepayers by lessening the instances of blackouts and brownouts which decrease business productivity and threaten family safety
    • July 2012 blackout left a majority of West Virginians without power for days and even weeks while costing millions and threatening lives
    • Data indicates that solar and other renewables create more jobs per unit than fossil fuel electricity
    • Solar has the highest incidence of jobs created per unit of energy
    • The solar industry employs more than 100,000 Americans with numbers increasing every year. 
    • Our neighboring state, Pennsylvania, ranked fourth in the nation last year in solar jobs with nearly 5,000. This is in spite of weaker solar resources than West Virginia
    • West Virginia averages 4-4.5 kWh per square meter of solar resource
    • This is much more than Germany (the world’s leader in solar capacity) and similar to parts of Northern Spain 
    • Slightly better than New Jersey which is the East Coast leader in solar installations

*U.S. Department of Energy, The Potential Benefits Of Distributed Generation And Rate-Related Issues That May Impede Their Expansion, 2007
*Perez, Zweibal, Hoff, ”Solar Power Generation in the U.S.: Too Expensive or a Bargain?” University of Albany/George Washington University, 2011 *Farrell, J., “Democratizing the Electrical Sector” ILSR, 2011 *Ban‐Weiss G. et al., “Solar Energy Job Creation in California”, University of California at Berkeley.
*M. Wei et al., “Putting renewables and energy efficiency to work: How many jobs can the clean energy industry generate in the US” University of California at Berkley *Sawin, Flavin et al. “The American Path to Energy Security” World Watch Institute. Washington DC

Name: Richard and Bettina Dennis
Hometown: Morgantown, WV
Date Wednesday, September 5, 2012

Thank you for the opportunity to submit these comments on the WV 2013 energy planning process and the associated reports from Marshall University and West Virginia University. Our comments, seven in total, are submitted below.
  • The three reports do a very good job of summarizing the current market and business potential of various energy systems including renewable energy, fossil energy, and energy efficiency technologies and approaches.
  • The Energy Efficiency report is excellent and should be incorporated into a West Virginia State Energy Plan and Policy. Energy efficiency planning and resources management at the power generation utility scale should be strongly encouraged as a tool to bring about lower energy rates for WV citizens. It is strongly recommend that integrated resource planning be used as a strategy to ensure utilities invest in cost-effective energy efficiency technology and ensure that our utilities are making investment decisions in the long-term public interest.
  • The titles of two of the reports by the Marshal University (MU) CBER are inappropriate. The University CBER does not formulate or publish policy for the state of WV. The titles of these two reports should be changed. CBER can assess business and market potential for energy related technology and supply this information to the state, essentially this is what the reports do, and the titles of these reports should be changed to reflect this content.
  • The MU CBER on renewable energy at times seems to take so called market making policy as an objectionable tool for shaping markets. This position seems highly biased. Policies that “shape markets” are tools used by policy makers to bring about a vision.
  • It is unfortunate that sub section (q) of state law SS 5B-2F-2 does not address the support for improving an end-use energy efficiency improvement approach. Energy efficiency end use improvement (demand side efficiency improvement) is well documented to be, by significant margin, the most power full tool for addressing energy related issues; in particular global climate change issues.
  • The state of WV should conduct a proper energy policy planning process. These reports only address part of this process. Simply put this would be to state a long term vision and a 5-year mission and then conduct a proper assessment of the strengths, weaknesses, opportunities, threats (SWOT) and externalities to bring about this vision through the mission of a 5-year plan. The three reports made available to the public for comment provide a reasonable basis for conducting a SWOT analysis. However more information is still needed with regard to externalities and how the state’s energy policy interacts with bordering states, regions and environmental issues.
  • Nowhere in these reports is the concept of global climate change mentioned as an externality or driving force in energy planning and or policy consideration. This certainly underscores the need for further consideration of externalities and the requirement for additional information as the state embarks on formulating energy policy.
In conclusion we are very pleased that the state of WV is embarking in an energy planning process and seeking public comment. The three reports provide a good basis for conducting further analysis on how to realize a vision for the public good through energy planning. We hope our comments are seriously considered and addressed.


Richard and Bettina Dennis
197 Upper Cobun Creek Road
Morgantown WV 26508

Name: Carl Irwin
Hometown: Morgantown, WV
Organization: Industries of the Future - West Virginia
Title: Director
Date Wednesday, September 5, 2012

Comments to WVDE – Morgantown, WV – September 6, 2012 Summary Report on U.S. DOE Funded Workshop on State-Level Standard Offer Programs held August 21, 2012 in Charleston, WV The Workshop was a deliverable on a U.S. DOE funded project to investigate the use of a “Standard Offer Program” as a state-level policy tool to:
  • Increase supply side EE
  • Promote investment in the state and create jobs
  • Diversify energy supply
  • Provide environmental benefits
  • The time is imminently right for such a program:
  • Both major utilities in WV are short on generation capacity to meet peak loads
  • Power generation resources are in transition - natural gas is cheap – fossil energy resources are under environmental pressures 
  • Recent Executive Order to accelerate industrial EE and investment in CHP – goal of 40 GW in a decade. U.S. Departments of Energy, Commerce, Agriculture, and EPA are to provide policy and technical assistance to states
  • Recent FERC decisions show an interest in promoting DG actions at to the state level
  • Unprecedented computational power, sensors and controls – i.e., smart grid technologies – can handle integration of numerous distributed small generators into the grid WV is missing out on investment opportunities – 3 examples from the workshop:
  • A WV company wanted to burn a biomass by-product waste stream to generate heat and power – using 6 MW of about 20MW generated – project did not progress due to lack of commitment for purchase of the excess 14 MW 
  • A WV company has applied to the PSC to invest $19 million in a resource recovery facility at a Berkley Co landfill. The facility would be powered by a solar energy farm to be built near the landfill. State utility regulations currently prevent a power sales agreement between the two parties
  • Recycled Energy Development (RED) has completed engineering design and financial planning for a waste heat recovery project at WV Manufacturing in Alloy, WV. The project would generate up to 60 MW of clean power, enable plant production to increase by 20%, create jobs, and be an economic boon to southern WV. The project has not gone forward due to lack of access to customers for the power.

Workshop recommendations:
  • Laws should be changed to enable non-utility generators to sell power to customers or have scenarios where utilities purchase the power at a reasonable cost (i.e., profitable for them while not increasing relative rates for other ratepayers)
  • Power purchase agreements/contracts should be long term – 8 to 10 years – to create stability not only in long-term prices but also for banks to fund investment
  • Utilities should be required to issue an RFP for acquiring new generating capacity that may be needed when demand exceeds their own generating capacity
  • Power prices (excluding any “green” premium pricing or renewable energy credits) should be at or below avoided costs – this makes it legal under PURPA
  • Could have some type of efficiency goal that power projects must achieve (e.g. 60%) – utilities could achieve this through CHP
  • Utilize RED and U.S. EPA databases to catalog the best opportunities in WV for WHR and CHP projects.
  • The WV Legislature should pass a Study Resolution for the WVDE, IOF-WV, or other entity to convene a working group with representatives from utilities, the PSC, the Legislature, industry, and other key stakeholders to draft a SOP for WV that enables third party power projects meeting certain pre-specified conditions to qualify for multi-year power sales contracts.

Name: Regan Quinn
Hometown: Charleston, WV
Organization: Climate Reality Project
Date Tuesday, September 4, 2012

Thank you for the opportunity to comment on the WV Department of Energy Five Year Plan.

While there are many excellent features of the Plan, such as the provision for a K-12 School Building Energy Program, and the encouragement of industrial energy efficiency, I am sorry to see there is little explicit acknowledgment of the risk of global climate instability caused by sustained and increasing CO2 emissions.

I recently viewed the newest version of the “Inconvenient Truth” slide show, and saw images of jet wheels sunk into melted tarmac, and heat buckled railroad ties from this summer’s extraordinary heat wave; images illustrating the unexpected fragility of the country’s infrastructure in the face of increasingly severe heat waves. This is in contrast to this summer’s broad-based failure of the Midwest corn crop due to heat and drought. Drought is a predicted outcome in global warming scenarios. In either case, these are not normal events and they are just the beginning. Inevitably, the physical properties of green house gases assure that with a continued upward course of CO2 emissions, global warming will worsen.

A Union of Concerned Scientists report has stated, “Many of the changes to the world around us are unfolding faster than scientists projected just a few years ago… indeed we may be very close already to triggering natural amplification mechanisms that could cause irreversible change with catastrophic consequences.”

Therefore, I would ask that the Plan acknowledge the grave and immediate risks presented by global climate instability due to man-made green house gases, and attempt a quantitative assessment of the potential for each of the elements of the Plan to reduce carbon emissions. Such assessment could eventually permit prioritizing state investment in accordance with the CO2 reduction efficacy of each program.

This might mean less emphasis be placed on coal but the outlook for coal has been dimmed anyway for economic reasons. See the August 14, 2012 Charleston Gazette editorial “Future? Coal mining outlook” and the Union of Concerned Scientists Report “A Risky Proposition: The Financial Hazards of New Investments in Coal Plants.”  There have been no successful commercial trials of carbon capture, although the Weizmann Institute in Israel has experimentally succeeded in using concentrated solar energy to chemically transform CO2 from coal combustion to hydrogen and carbon monoxide, both of which can be used as fuel sources according to the investigators.

Major renewable energy technologies have the potential to produce many times the current US power demand. The Plan acknowledges that, “solar energy represents conceivably the single largest source of energy” (p 24). Because of the urgency of the climate instability problem, it is probably inadvisable to wait for the 5-10 years estimated before solar is as cheap as fossil fuel, a course the Plan appears to suggest. Financing options to encourage earlier adoption of solar and other renewable technologies should be addressed in the Plan. Ted Boettner’s concept of a permanent trust fund for economic diversification is an excellent one. Similar trust funds have been successfully established elsewhere. Wyoming was the fourth state to establish such a fund, around 1974, and the fund is now worth $5 billion.

Regarding more short-term financing options, could the Plan express reasons why the State of WV should not take advantage of two billion dollars in federal funding available for energy efficiency and renewables projects via Qualified Energy Conservation Bonds issued under the Better Buildings Challenge?

In relation to the School Building Energy Program, articulated in the Plan: it would be nice to see as a medium or long term goal the construction of net-zero school buildings. Such highly energy efficient buildings use no more energy than they produce via on-site renewable geothermal, wind and photovoltaics. Such buildings have reduced operating costs and can be constructed for less than a conventional school building costs, when energy savings are factored in. Examples include the Richardsville Elementary School in Warren County Kentucky The facts re this school are that a state grant for $3 million helped pay for PV panels, and the projected savings over the next ten years, thanks to energy efficiency and PV, is $8.6 million.

Thank you for your kind reception of these comments.

Name: Olga Gioilis
Hometown: Sutton , WV
Date Monday, August 30, 2012

I endorse the recommendations to the Energy Efficiency section of the WV Energy Plan. I believe we need to improve our energy use and reduce it efficiently. We need to consider alternative energies and evaluaate how to use and integrate them.

Name: Ted Boettner
Hometown: Charleston, WV
Organization: WV Center on Budget and Policy
Title: Executive Director
Date Monday, August 30, 2012

West Virginia stands at a crossroads. We are now facing a natural gas boom similar to that of the coal industry in the last century.

But the experience of 100 years has taught us that shared prosperity and natural resources extraction don’t necessarily go hand in hand. Without a plan for the future, we are likely to continue to experience a lack of economic diversity, endless cycles of boom and bust, and poor economic outcomes.

Rather than repeat the past, the West Virginia Center on Budget and Policy asks that the DOE propose to move forward by creating the West Virginia Future Fund, similar to funds created by several other mineral-producing states.

The Future Fund will be created from a portion of natural resources severance taxes and will turn a one-time source of revenue into a permanent source of wealth for our state.

We propose that the principal of such a fund should be untouchable and allowed to grow.

It should be prudently invested and wisely managed so that the income gained will provide an ongoing stream of revenue to meet the challenges of the future and help build a more prosperous and secure economy.

If we do not include a Future Fund in our state's energy plan, than the mineral resources will disappear and the state will be more vulnerable in the future.

Name: Cathy Kunkel and Stacy Gloss
Hometown: Naoma, WV
Organization: Energy Efficient West Virginia
Title: Coordinator
Date Monday, August 29, 2012

Energy Efficient West Virginia is a statewide non-profit coalition dedicated to improving energy efficiency across all sectors in West Virginia.  We appreciate the opportunity to comment on the draft of the state's 5-Year Energy Plan.

We strongly endorse all of the recommendations of the Energy Efficiency section of the Plan. The Plan provides a thorough and well-researched analysis of the status of energy efficiency policies and incentives in West Virginia and surrounding states.  We concur with the Plan's overall finding that energy efficiency is a low-cost and underutilized energy resource for West Virginia.

With regard to utility energy efficiency policy, the report highlights that West Virginia's utility-funded energy efficiency programs are weaker than many programs in surrounding states, including programs offered by other AEP and FirstEnergy companies.  We agree that establishing an Energy Efficiency Resource Standard (EERS) is critical to facilitating the development of stronger programs in West Virginia.  By setting interim and long-term goals for energy savings, an EERS would spur greater utility investment in efficiency, ensure a long-term market in energy efficiency services, and reinforce the concept of energy efficiency as a resource.

EEWV further recognizes the need to re-align utility financial incentives to put supply-side and demand-side energy resources on an equal footing.  We agree that decoupling offers the best approach to eliminating utilities' financial disincentive to promote energy efficiency.

We also support the Plan's recommendations to ensure that the state adopts up-to-date building energy codes and to provide for more effective enforcement of such codes.  As the plan notes, West Virginia lags behind many other Appalachian states in adoption of residential and commercial building energy codes.  Promulgating and enforcing up-to-date energy codes is one of the most effective steps that the state can take to promote energy efficiency.

While the Plan does mention the benefits of co-generation, waste heat recovery, and combined heat and power (CHP) in its industrial opportunities section, we are disappointed that recommendations to facilitate the development of such projects were left out of the draft energy Plan.  Co-generation, in which the waste heat from electricity generation is used as industrial process heat, is a highly efficient form of power generation.  Producing electricity and heat separately has a typical combined efficiency of 45%, whereas co-generation can achieve a combined thermal efficiency of 80%.  Nationally, co-generation contributes 9% of electricity capacity; in West Virginia, it is only 2.3%, despite West Virginia's position as an industry-intensive state.  Benefits of CHP include the potential to use in-state natural gas resources, increased efficiency of fossil fuel use, and grid stability benefits such as reactive power support and reduced line losses.  West Virginia has no policies to encourage co-generation, and at least one large project has stalled due to an inability to guarantee a long-term contract for power sales to the grid. We believe the Division of Energy should play an important role in analyzing the barriers to CHP development in West Virginia and developing policy to promote CHP as a means of enhancing industrial competitiveness and energy efficiency.

More broadly, we are disappointed that the plan does not address the need for integrated resource planning in West Virginia.  Integrated resource planning, which has been adopted by more than half of U.S. states, would require West Virginia's utilities to submit long-term plans to the Public Service Commission explaining how they can meet future electric demand at the lowest cost. Crucially, a rigorous integrated resource planning analysis would evaluate supply-side and demand-side resources on an equal footing to show how much our utilities should be investing in energy efficiency.

Currently, both of West Virginia's investor-owned utilities are short on capacity and are proposing to purchase additional coal capacity. Although both utilities claim that their proposal is the lowest-cost option for their customers, there is no integrated resource planning process in place to require a transparent evaluation of alternatives. With a robust IRP process, the identification of capacity shortages in an integrated resource plan should trigger a requirement for the utility to issue an RFP for additional capacity. This would allow for open competition between gas plants, coal plants, renewables, co-generation facilities and demand-side resources to meet the capacity need. Acquiring coal capacity is a significant investment with long-term implications for customer rates, yet our utilities were allowed to develop their proposals without being required to fully evaluate alternatives or issue a formal RFP for additional capacity.

In summary,
1. We strongly endorse the recommendations of the energy efficiency section of the state's Energy Plan, and we urge the Division of Energy to advocate for the adoption of an Energy Efficiency Resource Standard.
2. We urge the Division of Energy to support policies that would lead to greater development of co-generation, or combined heat and power, as a strategy to enhance industrial competitiveness and improve efficiency of fossil fuel use.
3. We urge the Division of Energy to recommend integrated resource planning as a strategy for ensuring that West Virginia's utilities invest in all cost-effective energy efficiency and to ensure that West Virginia's utilities are making investment decisions that are in the long-term public interest.  

Name: Mary Ellen Cassidy
Organization: Wheeling Jesuit University
Title: Research Associate and Adjunct Faculty
Date Monday, August 27, 2012

I would like to strongly encourage stronger community incentives for energy efficiency for homes,small businesses and schools.  Although there are limited tax incentives, a significant obstacle to energy audits and upgrades for buildings is the upfront costs. Allowing the homeowner and small business to finance upfront costs through their utility bills  or other innovative energy performance type contracting.  Letting homes and small businesses finance energy efficiency (like larger entities through EPC) without upfront costs would allow more people to enjoy the savings from energy efficiency and also help communities expand construction, HVAC, auditor and create additional  job demands.  Energy efficiency developed on this community level is a great job creator and develops local wealth in a sustaining environment.  Along with financing incentives, I would also strongly encourage our state to ask the PSC to tell utilities to incorporate “least-cost pricing” that has been proven to lower demand and increase efficiency.