COMMENTER BACKGROUND

The Georgia Conservancy is a statewide environmental education and advocacy organization, working in the areas of air, land, water, and quality growth. Energy is a topic that intersects with all of our program areas, and our comments on the plan reflect, to some extent, our priorities and work in each of these areas. We are also a founding member of the Georgia Air Coalition and have been working with the other Air Coalition partners in developing comments on the draft plan. Perhaps above all, energy production and consumption impacts the quality of the air we breathe, making this state energy planning process critical to our health and the overall quality of life in Georgia.

HIGHEST PRIORITIES

We support the Georgia Air Coalition comments that are being made during this process. We would also, however, like to take this opportunity to highlight those priorities and issues that are of particular interest to the Georgia Conservancy. The plan as a whole is comprehensive and, if implemented, will help Georgia’s energy reliability, economy, and environment. To achieve its maximum impact, it will be important for key portions of each chapter of the plan to be implemented.

First, we agree with GEFA that a key strategy is the first one, (Strategy 1.1.A – Develop a Statewide Energy Supply and Demand Assessment for All Fuels), which would develop for the first time a centralized, statewide energy supply and demand assessment for electricity and all fuels. This comprehensive energy planning is just good government—gathering information and projecting what needs to be done, highlighting any gaps, identifying opportunities for growth, and providing sufficient, reliable information for policymakers to consider in taking action. The present, decentralized approach works in a piecemeal way and does not provide the consistent, reliable information necessary for Georgia to continue to grow while also protecting its resources. This statewide approach to energy planning will also help with environmental planning, since energy issues impact all parts of the environment throughout the state. This type of planning will be a significant change, but it is a necessary step to ensure that as Georgia’s economy grows, its environment will be protected to maintain a high quality of life for all Georgians.

Second, in general, we support strategies that will help stimulate the increased use of renewable sources of energy and energy efficiency, which are preferable methods of meeting the state’s increasing energy needs. These tools will reduce the impact of transportation and energy use and production on air quality, water quality, and global warming. Two other potential strategies we recommend to help with this are in “Appendix E: Ideas for Further Consideration”. Ideas 2.A (Establish a Renewable Fuel Standard (RFS) for the State of Georgia) and 2.L (Establish a Renewable Portfolio Standard) would provide regulatory targets to further stimulate action to develop renewable sources of energy.

Third, we believe funding is key to the plan’s success. While the state should be careful with state funding and let free enterprise work as much as possible, the incentives in this draft are necessary to jump start new technologies, markets, and consumer action. A plan without these funding mechanisms will not be fully effective. In addition, there are multiple state agencies that will be involved in implementing this plan, and these agencies need adequate funding to ensure success. To this end, we support the policy options and strategies listed in Chapter 5.

Finally, we are concerned with the inadequate focus of the strategy on global warming. While current air quality, water quality, and water supply issues may appear more pressing, global warming will have more serious impacts on Georgia’s environment and economy. The current draft does not pro-actively respond to this threat. Georgia should plan for this, instead of simply reacting to initiatives at the federal level as the draft suggests. By addressing global warming now, Georgia can also help lead other states and benefit economically from those implementation strategies. Therefore, we recommend that the final draft more proactively address strategies to reduce greenhouse gas emissions.

SPECIFIC ISSUES OR ITEMS WE SUPPORT

Energy Supply

We support policies and strategies to encourage the production and use of biofuels for transportation needs and energy production. Draft #2 appropriately stresses biofuels as a way to meet supply needs rather than increased production and use of traditional fuels.

Policy Options 2.1 and 2.3 -- Increase the Production of Instate Biofuels and Encourage the Use of Biofuels: We support the increased use of non-fossil fuels for fuel use and electricity production. These will not only reduce adverse impacts to Georgia’s air quality, but will also help to significantly reduce Georgia’s greenhouse gas emissions. At the same time, this will help generate new markets and economic opportunities in Georgia. A good example of how to help encourage this is the recently announced Pine-To-Energy Coalition (P2E), an alliance of landowners, foresters, universities, environmental and conservation organizations (including the Georgia Conservancy), investors, energy developers, government agencies and other individuals. These groups are working to expedite the development and deployment of pine biomass-to-energy technology and raise public awareness and use of this valuable resource.

Strategies 2.1.B and 2.5.G – Use State Purchasing Power to Support Biofuel and Clean Electricity Production in Georgia: We agree that the State should take the lead and set an example of how these strategies can be effectively implemented. If these strategies are cost effective in the private sector, the same should hold with government. And, given the State’s large purchasing power, these strategies will likely stimulate action in the private sector, making this energy more affordable over time.

Strategy 2.6.J – Encourage the Development of Distributed Biomass-to-Energy (Electricity Plants) in Georgia: Efforts over the past several years to develop and encourage green power from various fuel sources have fallen short of expectations. Part of this is due to the economics involved in developing these new technologies, but part is due to an existing set of Public Service Commission (PSC) rules that can impede the development and use of alternate fuels. We support this strategy, but encourage more specificity on the implementing steps and timeframes.

Energy Demand

We support transportation strategies that would encourage cleaner vehicles and technology, the development of additional transit options, and comprehensive land use planning, and we support electricity-related energy efficiency measures, all of which will help us reduce the amount of energy we consume and, therefore, need to produce . The following strategies are of particular interest:

Strategies 3.1.A and 3.1.B – Create Incentives to Increase the Adoption of Efficient Vehicles and Vehicle Technologies and to Establish Purchasing Criteria for the State of Georgia to Increase the Use of Efficient Vehicles in Its Fleet: Both of these strategies can help create incentives and markets for more efficient vehicles. These will not only reduce emissions that adversely impact air quality and global warming, but will also ultimately reduce total fuel costs to consumers.

Strategy 3.3.H – Encourage Mixed Use, Multi-Modal Development through Incentives, Training and Education: We fully support this strategy and have been working for years to advance this type of development. A more comprehensive statewide approach to land use planning can have a significant contribution to reduced vehicle and building energy use, land conservation, economic development, and environmental improvement.

Policy Option 3.4 -- Increase the Availability of and Access to Public Transportation and Transit Options
Strategies 3.4.I and 3.4.J – Continued Support and Funding for Public Transit Systems and Encourage Integration of Local and Regional Transit Systems: These strategies are important to support the types of mixed use, multi-modal developments encouraged in Strategy 3.3.H, and to help reduce fuel use in private vehicles and emissions that adversely impact air quality, health, and global warming.

Strategy 3.5.K – Create Incentives to Increase the Adoption of Efficient Building
Technologies and Practices: While there are many good examples of new building construction with more energy efficient technology, too many are still being constructed without these technologies, largely due to business reasons. Creating these types of incentives will be important and necessary to ensure that these technologies are used more widely and consistently.

Strategy 3.5.L – Establish Energy Reduction Goals for Public Facilities: We agree that wherever possible the State should take the lead and set an example of how these various strategies can be effectively implemented. Only by setting specific goals, though, can the state track its progress.

Strategy 3.5.O – Develop More Effective Building Energy Code Enforcement Strategies: This is a good example of why adequate resources will be needed to implement this overall plan. Georgia’s existing energy efficient building codes are now not being enforced due to lack of local resources. More efficient buildings will save consumers and businesses money and will reduce impacts on the environment, but local governments need help to make these codes effective.

Strategies 3.6.P and 3.6.Q – Continue Incentives to Increase the Adoption of Efficient Appliances and Products and to Establish Minimum Energy Performance Criteria (i.e., ENERGY STAR) for All Appliance and Equipment Purchases: More efficient appliances will save consumers and business owners money and will reduce impacts on the environment. Continuing incentives to increase market penetration makes sense. And as we have stated before, wherever possible, the State should take the lead and set an example of how these various strategies can be effectively implemented.

Policy Option 3.7 -- Support the Increased Involvement of Electric and Natural Gas Utilities in Promoting and Implementing Energy Efficiency: This policy option and the proposed implementing strategies are very important to ensure that energy efficiency strategies are given the high level planning and regulatory attention they deserve.

Strategy 3.7.R – Encourage Achievement of a Voluntary Energy Efficiency Target for Electric and Natural Gas Utilities: Developing this target in a statewide stakeholder process, as described in this proposed strategy, would provide an excellent forum for discussion of the various technical, economic, and regulatory issues related to energy efficiency.

Strategy 3.7.S – Consider Alternative Utility Regulation Strategies that Allow Utilities to Recover Investments in Energy Efficiency: We agree that current utility regulations should be reviewed and changed to ensure that there are no impediments to the policies and strategies in this plan related to energy efficiency.

Economic Development

Policy Option 4.4 -- Encourage Development of Emerging Clean Energy Industries
Strategy 4.4.D – Support Development of the Biomass Fuel Industry, with Particular Emphasis on Georgia’s Agricultural and Forestry Resources: The greatest opportunity to support this energy strategy, to help minimize environmental impacts, and to spur economic development lies in the use of Georgia’s agricultural and forestry biomass resources for energy production. The state should take advantage of this opportunity to address Georgia’s energy issues by focusing state resources on the development of these emerging industries, as the Pine-To-Energy Coalition is working to do.

Incentives and Program Resources

Strategy 5.1.A – Create Georgia Renewable Transportation Fuels Advancement Fund
Strategy 5.1.B – Evaluate Comprehensive Clean Energy Income Tax Credit Program Strategy 5.1.C – Evaluate a Georgia Clean Energy Fund/Public Benefits Fund
Strategy 5.1.D – Develop Program Resources Necessary to Support the Goals of the State Energy Strategy: The numerous economic development strategies in Draft #2 highlight the point that this overall plan will be good for Georgia business and the overall state economy. We support all of these incentives, especially the policies that encourage development of emerging clean energy industries, like using agricultural and forestry resources for energy production. This makes good economic sense and will help the environment by reducing impacts on air and water quality and by reducing Georgia’s greenhouse gas emissions.

These and other strategies to support Policy Option 5.1 will be critical to the success of this statewide energy strategy. Some of these strategies may be more or less feasible, given fiscal constraints. However, it is appropriate to thoroughly evaluate all of them to determine how they could influence implementation of these strategies and how such incentives would affect the overall state budget and economy.

Energy and the Environment

All of the policies and strategies in this section point out the pressing need to develop centralized statewide energy planning that is integrated with statewide environmental planning. This integrated planning system will take time to develop and so must start soon. The ongoing Statewide Water Planning process, for example, will likely be completed in the absence of the information necessary to address energy generation and its impacts on Georgia’s water resources.

Statewide energy planning to be implemented in Strategy 1.1.A can help support future water, air quality, and solid waste management plans and can also provide information on sources and trends of Georgia greenhouse gas emissions.

Policy Option 6.1 -- Incorporate Energy Strategies into Air Quality Plans
Policy Option 6.2 -- Develop Innovative Approaches to Deliver Air Quality Improvements
Policy Option 6.3 -- Reduce the Impact of Atmospheric Deposition Resulting from Energy Production on Water Quality
Policy Option 6.4 -- Minimize Water Supply and Water Quality Impacts of Energy Production in the State
Policy Option 6.5 -- Increase the Role of the State in Managing Natural Resources: We support Policy Options 6.1, 6.2, 6.3, 6.4, and 6.5 and their implementing strategies as ways to lessen the impacts of our energy production and use on our environment.

Policy Option 6.6 -- Prepare for Potential Federal Climate Change Policies: While Draft #2 cites strong scientific evidence of global warming and the resulting adverse environmental and economic impacts in Georgia from global warming, Policy Option 6.6 does not take the next step to also acknowledge that Georgia should do more pro-active planning to help minimize those impacts. While national and international action will be the ultimate solution to this problem, state action is needed now to focus attention on the issue and identify strategies to reduce Georgia’s greenhouse gas emissions.

Strategy 6.6.H – Develop And Publish a Greenhouse Gas Inventory for the State Every Three Years: Developing a regular inventory of greenhouse emissions is necessary and achievable.

Strategy 6.6.I – Consider a Greenhouse Gas Registry: We agree that the current national variation in greenhouse gas registries should be evaluated so that whatever approach Georgia takes will be consistent and will support whatever national and international policies emerge. Ultimately, a Georgia Greenhouse Gas Registry will be necessary to track changes and help businesses implement changes.

Strategy 6.6.J – Work With Georgia Local Governments and Set Targets to Reduce
Carbon Emissions: This is a laudable strategy but, if local governments are doing proactive planning, that approach should be expanded to a more statewide approach.

Three other potential strategies to help address global warming are in “Appendix E: Ideas for Further Consideration” and should be included in the final draft:
Idea 6.J – Develop a Long-Range State Climate Mitigation and Adaptation Plan
Idea 6.N – Initiate Activities to Assist in Developing a Southeastern Regional Climate Action Plan Involving Other States, Particularly Those with an Atlantic or Gulf Coastline
Idea 6.O – Revise the Integrated Resource Plan to Account for and Reduce Global Warming Emissions and Encourage Carbon Sequestration Opportunities

Energy Education

We support the policies and strategies identified in the plan to provide the public education needed to transition Georgia to new sources of energy and reduced energy usage.

Future State Energy Planning and Tracking

We fully support an ongoing planning process to ensure that the final strategies are implemented, that the plan is modified as needed, and that new issues are addressed.

CONCLUSION

Implementing the strategies in this draft plan will improve health and air and water quality, lead to better solid waste management, and have a significant impact on global warming by reducing Georgia’s greenhouse gas emissions. We support the plan for these reasons, but we remain concerned that global warming is not addressed more directly. We again urge that the state incorporate strategies into this plan that will result in direct action by the state to address global warming.

GEFA has done a good job of guiding this process forward in a short amount of time. Draft #2 is a comprehensive plan that needs key components of all of its parts in order to work effectively. The Georgia Conservancy stands ready to assist as the final plan is implemented.

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