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VEIC’s Contributions to the 2015 Update to the Vermont Comprehensive Energy Plan

Karen Glitman -

The Vermont Public Service Department recently posted its draft of the Vermont 2015 Comprehensive Energy Plan. This update of Vermont’s existing Comprehensive Energy Plan is scheduled for completion by the end of 2015, following a public review period that is open now through November 9, 2015.

VEIC responded on July 20th to the Department’s request for “open comments” and “framing questions” it posed on its website. We offer these comments as context for others seeking different perspectives in their own responses during the public review period.

VEIC’s key themes were:

  • Vermont should not retreat from its goal of 90 percent of all energy use coming from renewable sources by 2050, nor slow down on rigorous energy planning. Meeting the 2011 Comprehensive Energy Plan (CEP) goal of 90 percent renewables by 2050 is possible. And the urgency of meeting this goal and the interim goals laid out in the 2011 Plan has increased.
  • CEP goals should support—and be consistent with—other State goals (both executive branch and statutory): land use, greenhouse gas (GHG) reductions, vehicle miles traveled, and health.
  • The CEP goals and the Efficiency Vermont goals should be aligned, as they fluctuate across the term of the CEP
  • New utility structures are needed. Achieving significant GHG reductions with benefits to all will require new thinking about utility structures.
  • A “total energy” perspective is important for effective energy planning. This perspective breaks down siloes among electric, thermal, and transportation efficiency, and shifts energy planning thinking toward how energy is actually supplied and used.
  • Planning decisions should be about outcomes to be achieved, not just about goals to be met. Examples: GHG emission reductions, job creation, other economic development, reductions in vehicle miles traveled, and health impacts. This applies to all energy suppliers and the energy efficiency utilities (EEUs).
  • Societal impacts. Low-income populations must become a priority population for services, and no longer be treated as an adjunct to other programs that might be extended to low-income ratepayers. Reducing the energy burden on low-income populations saves lives. Vermont should not assume that because federal low-income programs exist, they take care of all low-income needs. Low-income considerations should not be relegated to the end of the line, as a charitable consideration of energy planning.
  • Carbon pricing. Putting a price on carbon—whether via a tax, a cap and trade program, or a low-carbon fuel standard (LCFS)—offers a very strong mechanism for reducing the use of fossil fuels. It is critical for the State to ensure that the regressive character of a fixed carbon tax (which would add to the energy burden of low-income populations) is remediated. VEIC recommends that Vermont pursue one of these options:
  • Complementary policies, such as an LCFS, could augment carbon pricing as a good way to reduce GHG emissions in sectors other than electricity generation. Policies like Vermont’s recently adopted Renewable Energy Standard also reduce GHG emissions and can complement carbon pricing and an LCFS.
  • The success of implementing any of these options will be determined by careful program design. Effective administration, regulation, monitoring and evaluation, and the ability to make adjustments will be critical to the programs’ success. For an LCFS, taking into account carbon intensity of fuels, based on their lifecycle analysis, will make the program more accurate and effective.
  • We need a new mechanism for funding transportation infrastructure.

To read the Public Review Draft of the 2015 Comprehensive Energy Plan and for steps on submitting feedback to the Public Service Department during the public comment period, visit http://publicservice.vermont.gov/publications/energy_plan/2015_plan.

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