Environment Florida submitted comments supporting the City of St. Petersburg's draft Integrated Sustainability Action Plan:

March 15, 2019

Dear Ms. Wright, Mayor Kriseman, and City Council Members,

I am writing to provide comment on the City of Petersburg’s draft Integrated Sustainability Action Plan (ISAP) on behalf of Environment Florida and our over 4,000 supports in St. Petersburg.

First, I’d like to thank you and the Office of Sustainability & Resiliency for spearheading this effort to create a vision and plan for a healthy and sustainable St. Petersburg. Floridians need ambitious goals that match the scale of the environmental challenges our communities face, and the climate and energy goals specifically within this plan meet that bar. We encourage the city to adopt the strongest climate and energy plan possible, and would like to submit the following comments:

  • The Clean Energy Roadmap provided in Appendix C.3 specifies that nuclear energy, waste energy and natural gas will not be included in the city’s commitment to 100 percent renewable energy by 2035. Environment Florida supports this decision, given the environmental and human harms caused throughout the lifecycle of nuclear energy production -- from mining to disposal -- and the carbon emissions that waste energy and natural gas contribute to our already changing climate.

  • The Clean Energy Roadmap also lays out specific goals for improving energy efficiency -- reducing citywide energy demand 25 percent by 2025 and 35 percent by 2035. Reducing energy waste is a critical step in moving towards a 100 percent renewable energy future, and prioritizing tactics that improve efficiency will enable St. Petersburg to transition away from dirty energy sources as quickly as possible. The American Council for an Energy-Efficient Economy (ACEEE) estimates that we can reduce our overall energy usage by 40 to 60 percent below current levels by midcentury, simply by using better technologies and eliminating waste across our economy. These near-term goals both align with that potential and ensure that efficiency measures will be used as the city’s first line of defense.

  • The Clean Energy Roadmap also includes a vision for working towards a net zero energy building code for new construction. Such code improvements are increasingly popular in cities from Lancaster, California to nearby South Miami, Florida, and can be a powerful way to make renewable energy installations and efficient technologies the norm as our city grows. A recent report released by Environment Florida Research and Policy Center, found that Florida could expand its existing solar capacity over 13 fold and reduce annual carbon dioxide emissions from energy use by 7.3% of 2015 levels by 2045, if we were to require solar panels on all new homes statewide as a net zero building code would stipulate.

While Environment Florida supports the Clean Energy Roadmap’s inclusion of this long term vision and we are glad to see implementing efficiency standards and a solar-ready requirement included as steps towards that vision, we would like to see a more specific plan to transition from a solar-ready policy for new construction to a policy that solar technology be included on new construction.

  • Distributed solar energy helps combat climate change, build a more resilient local electricity grid, and provide savings to consumers. Given that value, Environment Florida encourages cities to set goals specific to locally generated distributed solar energy.  We are glad to see that the Clean Energy Roadmap includes a goal of installing 680 MW of solar energy on city facilities, homes and businesses in St. Petersburg as a necessary piece of the city’s plan to reach 100 percent renewable energy.

However, the current draft allows for the purchase of renewable energy credits (RECs) instead of adding sufficient local solar capacity, and we ask that the city commit to prioritizing solar additions above the purchase of RECs. We applaud the draft ISAP’s commitment to funding more solar co-ops and community solar projects as well as enacting PACE financing in order to expand access to solar energy, all of which will drive development. Through our Go Solar campaign, Environment Florida has produced several resources designed to help cities like St. Petersburg increase deployment of local distributed solar energy, and would love to work with the city as you move forward with implementing this plan to put additional policies and programs in place that will help the city add 680 MW of renewable energy to the local grid through solar installations.

  • Finally, the draft main report refers to planning alongside our electricity supplier, Duke Energy, to meet the energy goals defined in the Clean Energy Roadmap. Utilities are critical partners in unlocking the potential of solar energy. If Duke Energy is unwilling to support these goals, we would encourage the city to establish a public municipal utility in order to gain greater control over the city’s energy supply.

  • Environment Florida urges the Office of Sustainability & Resiliency and St. Petersburg City Council to adopt the changes outline above and approve the ISAP in full. Despite considerable progress towards a sustainable, renewable energy future for St. Petersburg, we still have a long way to go to reach our potential. Not only will these steps help get us there, but they will foster a strong local economy, vibrant community, and healthy environment in the process.

Sincerely,

Jennifer Rubiello

State Director, Environment Florida