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Stakeholder group urges environmental-justice tracking and faster interconnection for distributed energy resources
Summary
The Solar & Environmental Law Center told the Virginia PBR stakeholder group that the Commonwealth should expand environmental‑justice analysis, track service disconnections, target energy‑burden programs in fence‑line communities and speed distributed energy resource interconnections with clearer penalties and valuation for grid services.
At the December 12, 2024 Performance Based Regulation stakeholder meeting, the Solar & Environmental Law Center urged regulators to integrate environmental‑justice goals into utility planning and to use PBR‑informed changes to expand distributed energy resource deployment in disadvantaged communities.
"The Environmental Justice Act … creates an affirmative duty on agencies of the Commonwealth to ensure that it's carried out," said Josepha Solomon, speaking for the Solar & Environmental Law Center. She summarized the group's view that environmental‑justice reviews currently occur on a project‑by‑project basis and recommended broader tracking, planning and community engagement.
Why it matters: Solomon said regulators should measure where customers face the highest energy burdens and aim PBR incentives at programs that reduce those burdens—for example, expanding the state’s low‑income programs and tracking utility service disconnections by location. "Tracking service disconnections by locale, trying to minimize service disconnections, especially in the environmental justice and fence line communities," she told participants.
Distributed energy resources and interconnection Solomon also urged faster interconnection and better valuation for distributed energy resources (DERs) such as behind‑the‑meter solar, storage, smart controls, heat pumps and managed EV charging. She said the code and regulations include interconnection timelines of "30 and 68" (days, as listed in code and regulation materials presented), but that utilities have been allowed to issue waivers without penalty when they miss those targets. "Doing something to try to minimize those interconnection times" and adding penalties or other enforcement, she said, would encourage DER deployment.
Solomon noted the Clean Economy Act’s small‑project carve‑out and RPS requirements and recommended that carbon emissions be reported clearly and directly rather than only as carbon intensity metrics, to make actual emissions reductions easier to track.
Other points from the presentation - The speaker said existing retail net‑metering policies and a 1% carve‑out for projects 1 MW and under (in the Clean Economy Act) help deployment but that interconnection delays and regulatory barriers remain for some developers. - Solomon emphasized the need to value location‑ and time‑specific grid services provided by DERs, and to consider grid enhancing technologies to avoid unnecessary transmission and distribution buildouts.
Ending Stakeholders at the meeting asked clarifying questions about enforcement and whether current programs were delivering for disadvantaged communities; Solomon said the SCC and other dockets are actively evaluating interconnection and DER issues and that some compliance (for example with the RPS carve‑out) is monitored in annual RPS proceedings.
