by John F. Seymour
On June 26, the Arlington County Board held a public work session to review a staff draft of the Community Energy Plan (CEP) Update — Arlington’s planning document establishing energy goals and policies for a sustainable county through the next decades. Following two hours of discussion and debate, the Arlington County Board rejected the county staff’s recommendation. The staff had proposed an emissions target of 1 metric ton of carbon dioxide per capita annually by 2050 — a 92% reduction in the county’s prior target of 3 metric tons per capita annually set only five years ago. Instead, the County Board directed the staff to plan to achieve a more aggressive target of net zero — no net carbon dioxide emissions from the county by 2050.
In fact, the County Board directed the staff to plan for a trifecta of zeros, including two new goals not addressed in the draft CEP Update at all — a new target of 100% renewable electricity for county government operations no later than 2025 and a third target of 100% renewable electricity for the county as a whole by 2035. In light of the frequency with which it was mentioned during the work session, a letter submitted to the Board by the county’s Environment and Energy Conservation Commission (E2C2) (posted by BlueVirginia on June 23), played no small role in the Board’s decision. (I served on E2C2 for the past three years, ending my term earlier this spring. I did not serve on E2C2’s Environment Committee, which reviewed the staff work product and prepared the Commission’s critique and I offer these comments only as a long-time Arlington resident).
Despite reservations raised by staff about the practical difficulties of achieving each of the three goals, the County Board remained committed to net zero. Several Board members did express misgivings about the target, amid concerns for “overpromising” and unresolved issues of technological feasibility, marketplace and regulatory realities, and energy equity. And even the Board members most supportive of “net zero” acknowledged that the targets might be fairly deemed “political” rather than data-driven. Nevertheless, they maintained that, in the absence of serious federal and state leadership, localities must take strong action to address the exigencies of global warming. The Board also opined that highly aggressive and frankly aspirational targets might, by themselves, stimulate energy conservation measures and promote earlier adoption of renewable energy. At the end, the entire Board was clear in its message to staff — the county’s goal is net zero and the staff is charged with planning to achieve it. The staff accepted the policy guidance with good grace and pledged to revise the draft Update accordingly.
What is the CEP? The Code of Virginia requires all governing bodies in the Commonwealth to prepare a written “Comprehensive Plan.” The plan is intended to guide and develop growth in accordance with the “present and probable future needs and resources” of residents and must be updated every five years. Although the enabling legislation is purposively vague about the contents and scope of the required Plan, Arlington has — given its penchant for careful planning — implemented the legislative direction with its customary energy and care. When first established by Arlington in 1960, the Arlington Comprehensive Plan had five general elements. It was amended most recently in 2015 with the addition of the Affordable Housing Master Plan and now has 12 elements. The CEP was added in 2013 and, via statute, is due for an update.
The overall goal of the CEP is to serve as a blueprint for an environmentally-sustainable county. Key to the overall policy objective is the establishment of greenhouse gas reduction targets and strategies needed to reach those targets. The original 2013 goal was to reduce Arlington’s current carbon emissions from the measured 2007 baseline of 13.4 metric tons of carbon per capita per year to 3 metric tons by the year 2050. CO2 emissions were deemed a reasonable proxy for overall energy consumption and the target established a reduction — over 2007 levels — of more than 70%. For county operations, it proposed a modestly higher target — a 76% reduction in CO2 emissions by 2050.
The 2013 CEP was quite frank about the obstacles it faced. Nearly 2/3rds of the energy Arlington uses is in the form of electricity delivered by a single utility — Dominion Energy. Much of the remainder is in the form of natural gas, delivered by another utility — Washington Gas. Unlike many jurisdictions which have established and control their own utility, Arlington has no control over Dominion or Washington Gas or the “cleanliness” of the energy it receives through their distribution systems. The CEP and its accompanying detailed Implementation Plan also emphasized that their goals “cannot be achieved in a vacuum.” Because energy systems have local, regional and national dimensions, the Plan cautioned that existing state and federal laws and policies presented significant barriers to the Plan’s goals. The CEP lamented the absence of long-term and permanent state and federal incentives for renewable energy, the lack of authority in Virginia to enter for Power Purchase Agreements to allow third-party investors to install and own large-scale photovoltaic systems, the absence in Virginia of a Mandatory Portfolio Standard (requiring regulated utilities to develop renewable power) to serve as a catalyst for renewable energy projects, among a host of other obstacles.
The Work Session. County staff in the Office of Environmental Management and Sustainability, the Arlington Initiative to Reduce Emissions (AIRE Program), and the Department of Environmental Services (which manages the AIRE Program), presented Arlington’s draft CEP Update. They first summarized Arlington County’s impressive progress in reducing greenhouse gas emissions since publication of the original CEP. Staff, and the County Board, are justifiably proud of the county’s early adoption and aggressive promotion of innovative energy conservation measures. Only last year, Arlington was named the first “Platinum Level Community” by the U.S. Green Buildings Council in recognition of the county’s “long-time commitment to environmental sustainability.”
During the session, staff summarized the county’s implementation of the tools and strategies recommended in the 2013 CEP and demonstrated that it has, in fact, reduced its greenhouse gas emissions significantly. As of 2016 — the most recent year for which modeling is available — Arlington has reduced its emissions to 9.1 metric tons of carbon per capita. Arlington’s successes were large due to increased energy efficiency efforts — innovation in building codes and discretionary site plan options and incentives, together with modest growths in the solar co-op. The Update also summarizes the assumptions underlying its much more aggressive target for overall CO2 emissions proposed in the Update. Instead of the 2013 target of 3 metric tons of carbon dioxide per capita per year, it proposed a new target of 1 metric ton of carbon dioxide per capita per year by 2050. Staff characterized the new target as highly ambitious but, with increasingly favorable market trends, reasonably foreseeable technological developments, and new state and federal regulatory initiatives promoting renewable development, also reasonably achievable.
Questioning some of the staff’s recommendations, County Board members examined a number of issues raised in the draft Update — whether the targets lagged behind those proposed by other jurisdictions and were inconsistent with Arlington’s long-term leadership on energy sustainability issues; whether Arlington could implement more on-site solar than proposed; whether Arlington Could enhance its own investments in electric vehicles; and whether the county could invest in carbon off-sets, renewable energy certificates, or use other available regulatory and market mechanisms to achieve net zero carbon emissions where other options failed.
Is the staff’s recommendation too timid? County Board members pointed out that, as the staff itself acknowledged, other jurisdictions had proposed more aggressive energy targets, including “net zero” — a goal by which a state, county or municipality committed to reduce its net energy consumption to zero by 2050, or even earlier. In response to the County Board’s question about how other jurisdictions were achieving those policy objectives, Greg Emanuel — the practically-minded Director of Arlington’s Department of Environmental Services — noted that staff had, in fact, a “number of conversations” with local jurisdictions about precisely that issue. He was careful to affirm that his Department would, of course, implement whatever policy guidance the County Board would establish, but stressed that “implementation is what really matters.” When other jurisdictions were asked about their plans for achieving their own jurisdictions’ aggressive new energy goals, Mr. Emanuel said, they replied simply “we have no idea.” They indicated that “it was a political goal that was set and we’ll figure it out.”
Following up, Demetra McBride, Chief of Arlington’s Office of Sustainability and Environmental Management, pointed out that some jurisdictions with net zero goals had advantages Arlington lacked, including publicly-owned utilities that were subject to the political will, rather than investors’ imperatives. Other localities with aggressive goals — such as New York and Boston — also benefited from state support and progressive legislatures committed to renewable energy, where targets were embodied in legislative mandates and received significant direct investments. The staff’s written presentation only underscored that concern. The staff had been asked to characterize roughly the overall level of “County Control” that could be exercised over the many assumptions underlying the new target of 1 metric ton/capita/year. Of the major assumptions identified on its chart, staff characterized Arlington’s level control as “none” or “low-moderate,” or “market-based,” based for each of the assumptions assumptions, with a “high” level of local control identified only for predicted reductions in transportation-related emissions.
The relative lack of serious local government planning to meet greenhouse gas emissions is a concern raised by others as well. In their review of the 2013 CEP, researchers at Virginia Tech University examined the climate policies and planning conducted by Arlington and eight of its regional neighbors and concluded that Arlington’s plan represented the “gold standard when it comes to energy planning.” The plans of other jurisdictions, if they existed at all, were characterized as far less detailed and gave far less practical guidance to policymakers. Those reviewers, too, highlighted that, as a Dillon Rule state, Arlington and other local jurisdictions needed express statutory authority from Richmond to pursue some of the CEP’s recommendations and that such authority was frequently lacking.
Others, trying to drill down into the Sierra Club’s “Ready for 100” list of 90+ cities that have committed to net zero, encountered similar problems. They find no lack of exhortations to action, rhetorical references to moral imperatives, and resolutions of support. But it is much more difficult to find detailed plans with realistic strategies to achieve net zero. As one solar advocate cautioned in his review of state net zero promises, “there’s only one problem: all of the states that have passed 100% clean and/or renewable energy mandates to date have done so with Democratic party control of both houses of the state legislature and the governor’s office.”
On-Site Solar: The Update’s recommendations for solar are, at least to some, most difficult to parse. Although attaining the Update’s new more ambitious energy target would inevitably require a massive commitment to solar energy, the goal for on-site solar within Arlington (160 megawatts) is identical to the goal contained in the original 2013 CEP — solar energy sufficient to meet the peak power needs of about 40,000 households. According to the staff draft, Arlington residents will need to satisfy 95% “of their electricity needs that are not already met by on-site generation with contractual purchases of renewable power.” Although County Board members were concerned about the very modest penetration of solar into Arlington’s market and the need to do more to install solar on Arlington’s rooftops, there was no County Board or staff discussion of the vast off-site purchases of renewable power contemplated by the Update.
John Morrill, Arlington’s long-time Energy Manager, acknowledged that Arlington’s current on-site solar energy production was negligible — a tiny portion of 1% of total energy consumption — but insisted that there was “nothing small” about the 2050 goal for on-site solar of 160 megawatt. Although county studies had shown that Arlington’s total building rooftop acreage — commercial and residential — could accommodate more solar, GIS studies of rooftop acreage represented, to many, a rather slender reed upon which to project solar acceptance and future energy production.
Both Arlington’s Natural Resources Management Plan and Urban Forestry Master Plan highlight the importance of trees in establishing and maintaining a healthy urban eco-system, both to reduce heat islands and air-conditioning costs, and for their stormwater and aesthetics benefits. As Mr. Morrill noted, shade trees in residential neighborhoods often thwart solar installation but that Arlingtonians “love our trees” and Arlington has also abided by the principle that “trees trump solar.” Although commercial properties also have considerable acreage that could accommodate on-site solar, commercial rooftops also house other “valuable amenities,” such as pools, gardens, and critical infrastructure. The staff’s projection of on-site solar implementation throughout the next decades was described as highly optimistic, and heavily reliant on continued technology improvements and pricing improvements, and the development of permanent and stronger financing options and incentives. The technical, legal, and fiscal implications of Arlington’s purchases of large quantities of off-site utility-scale solar were not discussed at all.
Transportation: The draft CEP Update also set forth very aggressive targets for carbon reduction from the transportation sector — from a baseline of 3.7 metric tons of carbon per capita annually in 2007 to 0.5 metric tons by 2050. Because Arlington is already blessed with mature mass transit alternatives and has implemented an impressive menu of well-developed multi-modal transportation options, nearly all of the proposed reduction in greenhouse gas emissions projected in the staff draft is based on a predicted wholesale replacement of internal combustion engines with all-electric vehicles.
County Board members inquired about the possibility of bettering the projected goals, including more rapid electrification of the county’s fleets. DES Director Emanuel sounded a cautionary note in defending the relatively modest progress made by Arlington on electrification. Of the county’s 1287 sedans, SUVs and similar small vehicles, only 7 are electric — well under 1%. Mr. Emanuel reminded the Board that Departmental decisions about technology adoption were constrained both by budgets and operational needs. He indicated that “we are all waiting for breakthroughs in battery technology” and that the Department has found it difficult to justify the price premiums now charged for electric vehicles. Moreover, Mr. Emanuel cautioned, a rapid move to electric vehicles is constrained by the limited existing and foreseeable charging infrastructure, which can be extraordinarily expensive to install and maintain.
Dennis Leach, the county’s Deputy Director of Transportation, was even more cautious in his remarks about electrifying Arlington’s ART buses. With a dogged and earnest searching for common understanding (reminiscent of the studied patience my grandson displays when teaching me how to use Skype), Mr. Leach emphasized to the Board that energy was simply one factor entering into the county’s transportation decisions. The key metric for effective transportation policy, according to Mr. Leach, was very simple — the number of “automobile trips not taken.” The county’s goal has always been to operate its ART buses to complement its multi-modal transportation planning and to use every possible transportation mechanism to encourage residents to leave their cars at home. An effective and efficient county bus fleet was one that was affordable and, most important, reliable. Although the county is closely monitoring the evolution of electric bus technology, electric buses continue to raise significant reliability and maintenance questions. If buses are not at the bus stops when needed, then the “vehicle trips not taken” metric will rise significantly and the county’s energy goals will be compromised.
Carbon off-sets and renewable energy credits. For at least some observers, the discussion of how Arlington would “net” out its emissions was perhaps most disappointing. Both the staff and the County Board readily acknowledged that, even with the most aggressive strategies for greenhouse gas emission reductions, Arlington County could not rely on on-site renewables or a cleaner grid to satisfy its targets. The energy grids, supplied overwhelmingly by energy produced from fossil fuel plants, will continue to supply “dirty electrons” to the County. Dominion’s own 2017 Integrated Resource Plan indicated that the company expected to see its carbon dioxide emissions actually increase over the next 25 years. Was it nevertheless feasible, the Board asked, for Arlington to purchase offsets or engage in other financial transactions to reduce the County’s carbon footprint by “netting out” its carbon footprint?
The significance of this question can hardly be overstated. The Update itself proposed that significant indirect investments in off-site utility-scale renewable projects would be needed to achieve the staff’s own more modest target. Given very limited legal authority in Virginia granted counties to purchase electricity from a source other than Dominion, however, the regulatory path forward is not clear. The staff proposal apparently relies on various forms of “Virtual Power Purchase Agreements” that have received some attention recently, under which municipalities and others contract for the output of a renewable energy project, with the electricity being sold into the wholesale market rather than being delivered directly to the locality. These unconventional mechanisms remain largely untested and create uncertainties, particularly for municipalities unversed in the fluctuation of energy prices on the wholesale market.
The new targets set by the Board raise the stakes considerably. In response to the Board’s inquiry about how the County might achieve 100% renewable electricity for Arlington County’s operations by 2025, the staff prepared a pie chart setting forth options. The largest slice of the pie (by far) — constituting 84% of Arlington’s electrical needs — were projected from the contractual purchase by Arlington of renewable energy from out-side sources. Responding to the same request by the County Board to reach 100% renewable electricity County-wide by 2035, the staff noted that the target would require the purchase of renewable energy certificates to satisfy 25% of the county’s needs, as well as an additional 30% obtained from contractual purchase of off-site renewable energy.
All of these mechanisms are complex, in principle and in implementation, and present significant financial, technical, and legal questions that were wholly unexplored in the work session. The County Board did inquire about the availability of carbon offsets as an option to reach net zero, and the discussion was not heartening. John Morrill was skeptical of the existence of a robust and serious carbon offset market in which Arlington could participate, although he agreed that such a market might eventually emerge over time. Board members themselves acknowledged the existence of a “chaotic” offset market but also asked Mr. Morrill to include, in the next iteration of the staff draft, an analysis of what carbon pricing might look like and how it would affect the staff’s modeling. Mr. Morrill demurred, saying that “I don’t know that I have that crystal ball.”
Mr. Morrill cautioned further about the moral hazard of financial off-sets, warning that “there is the risk of thinking, well, we can just write a check and we’re done.” Board Chair Christian Dorsey, drawing on his experience as an economist with the Economic Policy Institute, echoed that concern. He found proposals to “essentially pay off” the gap in the two energy targets “less appealing” because there was no evidence that it would lead to a more fair or equitable future. He found net zero attractive as a political goal, but questioned whether it was the right decision for municipalities, or whether it frees policy-makers from the hard work of driving down their own emissions locally and taking responsibility for the emissions for which they are responsible. He also questioned, as many others have done, whether investments in offsets and renewable energy certificates may cause greater inequality between wealthier municipalities and those less well off. He also implied that there may be a reputation risk to Arlington where, as a wealthy community, it can buy the right to pollute from others.
That’s not to say that carbon offsets, renewable energy certificates, and investments in the wholesale energy markets can’t be designed to fairly and sensibly off-set a locality’s emissions — particularly when other options are not available. But where off-sets and renewable energy certificates operate in a purely voluntary market, their price often falls well below the true social cost of the avoided emissions. At the very least, their use calls for a careful examination to ensure that they are fairly and sensibility designed and implemented, and that both the County Board and residents understand their implications for real, verifiable carbon emission reductions, as well as their fiscal implications for both utility rates and the county’s budget. From the work session discussion, no one could possibly derive such comfort.
Conclusion: The staff’s task is not an enviable one. Beginning in early 2018, it began work on the CEP Update and developed an energy model, conducted market research, and engaged in broad community outreach. As a result of all of that work, it developed a highly ambitious target for carbon reduction. The County Manager expects to advertise the proposed CEP Update at a County Board meeting in mid-July with County Board approval expected in mid-September. To meet that schedule, however, the staff must now revise the Update, consistent with the County Board’s directive, and incorporate entirely new targets — unmoored from the modeling and market research conducted over the past year — and develop specific strategies and tools to implement them.
More fundamentally, however, the factual underpinnings for the Board’s directive — at least to some — remain unclear. The real problem with the climate denial community is not that they reject the findings of science research. The problem is that they reject the entire idea — embodied in the values of the Enlightenment — of honest and frank scientific inquiry. Instead of engaging in the back-and-forth serious work of truth-seeking, they find refuge in ideological and partisan purity. Board member Libby Garvey touched on this issue, from a different political pole, in warning during the work session that “you get beat up if you don’t say zero” and constituents ask “what kind of aspirational leader you are.” She has learned, she cautioned, that it is always better to “be honest with the public and ourselves” when formulating public policy.
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