Recent Projects

The New Jersey Board of Public Utilities (BPU) requested public input on its 2022 Progress Report on New Jersey's Resource Adequacy Alternatives, part of its continuing investigation into achieving New Jersey's resource adequacy and clean energy objectives. We submitted comments identifying specific recommendations for the BPU regarding the implementation of the proposals sets forth in the Progress Report. Among other recommendations, we encouraged the BPU to continue exploring the possibility of indexing renewable energy credits and clean energy attributes to the emissions intensity of displaced generation, identified various challenges associated with its proposal to introduce a market for clean capacity credits, and encouraged the BPU to carefully consider the preemption risk associated with its clean capacity credits market proposal.

In 2018, New Jersey established a Zero-Emissions Credits (ZECs) program, which provides subsidies to the state’s nuclear power plants for reducing carbon emissions in the energy sector. Our amicus brief explains how the Social Cost of Carbon is the best available estimate for valuing harms caused by carbon dioxide emissions. We also argue that the ZECs program should account for the benefits of avoided emissions both inside and outside of New Jersey.

The New Jersey Board of Public Utilities (BPU) released a straw proposal for its Solar Successor Program. We submitted comments addressing a question about solar projects' potential benefits to environmental justice (EJ) communities. Our comments encourage BPU to consider the inclusion of an environmental justice adder and reommend that BPU explore an adder that would deliver material benefits to EJ communities. 

The New Jersey Board of Public Utilities (BPU) asked for comments on its straw proposal for the benefit-cost test that BPU would employ pursuant to the 2018 Clean Energy Act, which requires energy efficiency and peak demand reduction programs to satisfy a benefit-cost test. We submitted comments encouraging BPU to include avoided greenhouse gas emissions among the non-energy benefits it credits to energy efficiency and peak demand reduction projects. We also suggest that BPU adopt a tool and methodology for assessing the benefit of avoided local air pollutants that is more sensitive than those identified in the proposal. 

The New Jersey Bureau of Public Utilities (BPU) requested public input on its investigation of resource adequacy alternatives. We submitted comments encouraging the New Jersey BPU to recognize important uncertainties affecting the proceeding, consider a broad range of costs of pursuing a Fixed Resource Requirement, and explore the possibility of a carbon pricing program in addition to participation in the Regional Greenhouse Gas Initiative.

Several states have determined that ensuring the viability of zero-emission electricity generation from nuclear power is critical to mitigating the impacts of climate change especially in the short term while states work to meet aggressive new clean energy goals. Through comments and amicus briefs, we’ve been involved in those efforts in both New York and New Jersey.

New Jersey’s 2019 Energy Master Plan (EMP) outlines how the state can achieve its emissions reduction target of 80% below 2006 levels, as well as 100% clean energy, by 2050. We submitted comments applauding improvements to the draft EMP and making further suggestions. Our comments encourage the state to establish a technology-neutral policy framework to achieve its emissions reduction goal, compensate distributed energy resources in a way that reflects their full social value, and implement reforms to advance related technological and regulatory frameworks. We also submitted comments last October, during the EMP scoping phase, that made suggestions on grid resilience, rate design, and energy storage incentives.

Peter Howard and Denise Grab both provided testimony at an April 25 New Jersey State Legislature hearing on climate change mitigation and what the state can do to address greenhouse gas emissions. They discussed how New Jersey can contextualize and weigh climate impacts by using the social cost of greenhouse gases.

New Jersey is proposing a new state carbon emissions trading program, which means it will rejoin the Regional Greenhouse Gas Initiative (RGGI). RGGI is a cooperative effort among northeastern states to reduce carbon emissions from the electric power sector through allowance trading. New Jersey previously left the initiative in 2011. RGGI expansion promises several benefits, such as improved market efficiency, increased competitiveness, and lower carbon reduction costs. We submitted comments to both RGGI and New Jersey on how to best reintegrate the state.

New Jersey is revising its Energy Master Plan (EMP) for 2019. In advance of the first draft of the plan, the New Jersey Board of Public Utilities, along with other state agencies, formed a committee to engage with stakeholders on the contours of the new plan. We submitted comments to the EMP Committee with a number of recommendations. Specifically, in drafting the 2019 EMP, we advise the Committee to consider grid resilience in a holistic manner and apply cost-benefit analysis to resilience plans and investments; adopt a granular approach to rate design, rather than use net metering; and design an incentive structure for energy storage operators to ensure that the use of energy storage systems reduces greenhouse gas emissions. These recommendations draw upon several of our recent publications on electricity policy, including reports on grid resilience and energy storage, and an academic article, also on energy storage. The first draft of the EMP is scheduled to be released this winter.