Loudoun Energy Strategy: a call for focus and avoidance of unintended consequences

You may or may not be aware of it but there’s a pretty serious issue coming before the Loudoun County Board of Supervisors this week. The issue at hand is the matter of advancing a proposal to the US Department of Energy (DoE) pursuant to getting federal grant money for the purposes of implementing some energy efficiency and conservation projects. That sounds rather mundane and, indeed, it is. It’s one of those things local governments do on a regular basis – take advantage of programs put in place by state and federal government agencies so as to acquire funding for various projects of local concern.

Now, as you might imagine the DoE doesn’t just cut a check to anyone who calls up asking for one. The money (which is designated for Loudoun County by a formula used to parcel out federal funds to local governments) must be used for certain purposes and before the DoE will send the cash, they’d like to know what the local government intends to do with it. That’s perfectly reasonable. The local government puts together a written proposal detailing exactly that, with specific information and data points given to answer the DoE’s proposal requirements. If the proposal is deficient, in some way, the locals get the chance to redo it and correct the problems.

Loudoun’s attempt to answer those requirements began several months ago when the BoS, allegedly at the insistence of Potomac Supervisor Andrea McGimsey, contracted with Peter Garforth, a “Strategic Energy Planning Consultant”, to produce a proposal. What was produced, instead, was a 182-page “strategy” document seeking to “guide” Loudoun’s energy policies out for 30 years. In the words of the consultant himself, the document goes far beyond anything any other locality has done in response to the proposal requirements. It suggests the implementation of a variety of regulations and “voluntary” assessments that have not been explained to the residents of Loudoun County in any meaningful way.

In my industry, there’s a well-known problem among system architects where a given engineer will start off a project with specific requirements and then fall into the trap of attempting to create the “ultimate design.” They tend to get lost in the effort to produce a design that will accommodate not only the requirements, but any number of future technologies. This results in over-engineering and can not only run up the costs significantly but introduce unintended problems for other parts of the existing or proposed project. It’s well-meaning, but it’s the result of a lack of focus on the task at hand in favor of some grand vision.

This past Thursday Broad Run Supervisor Lori Waters advanced an alternative proposal that draws heavily on the consultant’s strategy guide but removes anything not explicitly involved in answering the DoE’s requirements. That proposal weighs in at just 39 pages as opposed to the 182-page monster suggested earlier. Waters’ proposal seeks to re-focus the effort at 1) specifically answering the DoE requirements only to the level necessary to get that task done and 2) keep the projects detailed in the proposal aimed squarely at energy efficiency and conservation in county buildings and property.

The deadline for the proposal is in January. Given the already short timeline, and the fact that this is the holiday season when most of Loudoun’s citizens have their minds on family and the birth of Christ, there is simply insufficient time to allow the public to adequately digest all of the ramifications of the larger strategy. If the purpose of this proposal is answer the DoE’s requirements so that we may get the money to perform certain specific tasks, then a more focused proposal is the prudent move.

The wide-cast net of the larger strategy also moves this beyond the scope of county properties and into private property. While the document and its supporters say this is just a “guideline” there is far too much wiggle-room in it to keep future regulations from making requirements out of voluntary “suggestions.” Again, there has been insufficient time to debate this. The fact that this is being pushed for passage on a short time line is a reason for concern. Prudence demands we answer the requirements now and consider the larger strategies over more time.

I have genuine concerns about the larger strategy and quite a number with the presumptions used to create it. The author’s hype over how much energy per capita Loudoun uses versus various European localities misses some critical context, I think, and needs to be discussed more fully. I am also concerned about how this “strategy” will be used to guide regulation and what companies stand to benefit from the creation of a market in energy audits and “building labels”. Given Supervisor McGimsey’s history in this particular field, I would also want some very careful consideration and observations so as to avoid any impropriety or outright corruption issues. A more focused approach now with more careful debate over the larger strategy over the next several months would certainly allay any such concerns, as any attempt to “fast-track” this strategy would exacerbate them.

The BoS is having their last real comment period on this matter on Monday, 14 December. You might want to be there.

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2 comments

  1. Excellent piece Ric. I’ve seen many good questions on other blogs as well and I hope there are a handful of well-informed citizens there Monday night.

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