NJEC EMP Comments

8/4/2019 NJEC EMP Comments

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NJ EnergyCoalitionNew Jersey Energy Coalition

On the 2011 Draft NJ Energy Master Plan

On behalf of the members of the New Jersey Energy Coalition, thank you f or the opportunity to providecomments on the 2011 Dra ft New Jersey Energy Master Plan (EMP). As background, the New JerseyEnergy Coalition (Coalition) is a broad-based advocacy group whose membership includes over 100business, industry and labor organizations and policy leaders from across New Jersey. Some of our moreprominent members include: NJ SEED, NJ State Chamber of Commerce, NJ Business and IndustryAssociation, Chemistry Council of New Jersey, NJ Alliance for Action, Southern New Jersey DevelopmentCouncil, NJ AFL-CIO and NJ IBEW. Our Advisory Board is comprised of a number of the Statesdistinguished citizens including former congressmen, state legislators, mayors, and utility regulators.Our mission is simple: raise public awareness and generate public support for the increased productionand distribution of clean, affordable and reliable energy in our state. Since it was founded in 2007, theCoalition has been actively engaged in promoting these objectives and commented on the 2008 EMP.Our leadership and staff possess vast experience in public policy issues in New Jersey and provenenergy expertise that make the NJ Energy Coalition uniquely qualified to provide comments and feedbackto the Christie Administration on the 2011 Draft EMP.As a matter of policy, the Coalition supports the five overarching goals of the NJEMP:

Drive down the cost of energy for all customers. Promote a diverse portfolio of new clean in-state generation. Reward energy efficiency, conservation and reduce peak demand. Capitalize on emerging technologies for transportation and power production. Maintain support for RPS of 22.5% by 2021.

We salute the Christie Administration for its forthright, balanced approach to charting the critical coursefor our States energy needs. Because it is often one of the largest expenses for business and industry,the Coalition believes that energy can be a major driver to improve economic conditions. It also provideshigh-paying long-term employment and other financial benefits through its ripple effects on the economy.Therefore, it is incumbent upon policymakers to create a climate where adequate supplies of clean,reliable electricity and natural gas enable businesses to thrive and prosper. The Coalition also believesthat the environment must be protected. We support a balanced approach that assigns reasonablequantifiable energy targets and sets goals that will not harm New Jerseys quality of life or the rich natural

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NJ EnergyCoalitionwith the build-out of renewables, distributed generation, energy efficiency programs and electric vehiclesas directed in the EMP.

8. The Coalition supports the BPU providing more incentives for capital improvements to electricand gas distribution systems.Maintaining and improving our electric and natural gas infrastructure is as important as having reliableand sufficient energy supply. Without an energy delivery system that meets 21t century standards, thegoals of this EM P cannot be met. The Coalition supports the BPUs evaluation of providing additionalincentives to EDCs for capital improvements to their electric and gas delivery systems as theseimprovements will reduce cost of capital, lower project cost and ultimately reduce the burden onratepayers in the long-term. The Coalition also notes that the Federal Energy Regulatory Commissionrecently released its long awaited Order No. 1000, a final ru le to reform its transmission-planning andcost-allocation requirements, which should facilitate the development of new transmission facilities andlower the costs of transmission services.9. The Coalition supports energy efficiency and conservation as a primary tool in New Jerseys

energy toolkit.The old adage that the best kilowatt is the one that isnt produced is true. New Jersey must strengthen itsbuilding codes and regulations to promote efficient use of energy. Encouraging lower use, particularly atthe time of peak demand, is an important policy that must be mandated. The Coalition also believes thatadministration of energy efficiency programs funded by ratepayers should be performed by the electricand gas utilities, given their natural link to the end-use customer. Costs of program administration shouldbe minimized and recovered through rates, balanced with requirements for lowering energy usage. Wesupport specific measurable targets for energy efficiency and clear accountability for achieving thosereductions. We would urge the Christie Administration and the BPU to quickly determine what deliverymechanisms and incentives are best for achieving the goals set out in the EMP fo r energy efficiency.10 . The Coalition supports renewable energy that can be cost justified such as CHP and biomass.The Coalition supports the development of cost effective renewable energy. For example, the Coalitionsupports the creation of community solar projects that benefit indigenous New Jersey entities andresidential energy users that may no t be able to undertake such a project on their own. The Coalitionagrees with the Christie Administration and does not support the development of large-scale solar thatdoes not directly benefit ratepayers. We also agree that farmland should not be util ized for renewableenergy projects.


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NJ EnergyCoalitionIn line with the EM Ps directive to lower the cost of solar incentives on nonparticipants, and as a furtherrefinement to its renewable cost benefit analysis, the Coalition would propose that the BPU prioritizeaccess to solar PV for those entities that derive the most benefit for our citizens, particularlygovernmental, educational and healthcare facilities (i.e. schools, colleges, hospitals). Enabling theseentities to install solar PV provides the greatest value, since lower energy costs are passed along directlyto taxpayers and ratepayers.It is important to note that the Global Warming Response Act, P.L. 2007;c.1 12, requires measures toreduce the emission o f GHG, and as such a further analysis o f t hi s p la n is necessary to ensureachievement of the targets set forth in the law.

-207 Bogden Boulevard, Suite D I Miliville, NJ 08332 I 856.308-3656 I www.njeneroadon.org

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NJEC EMP Comments