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Comments to NJBPU on the Development of Natural Gas Utility Emission Reduction Plans

The New Jersey Board of Public Utilities is examining how to reduce greenhouse gas emissions from the state's natural gas sector in line with New Jersey's economy-wide emissions reduction goals. Policy Integrity submitted comments focused on the planning process and solutions needed to responsibly transition away from natural gas usage.

The key points made in the comments are:

  • Natural gas currently accounts for a significant share of New Jersey's emissions. Reducing its climate impacts will require careful planning to avoid stranded assets
  • Rigorous state oversight of gas system planning is essential, both because business-as-usual practices that drive the buildout of in-state gas infrastructure are misaligned with New Jersey’s pollution reduction goals and because the Federal Energy Regulatory Commission declines to provide meaningful oversight of interstate pipeline development. 
  • The Board must establish a clear framework that requires gas utilities to engage in a transparent, standardized planning process. The resulting process must include a requirement that gas utilities obtain Board approval before entering into firm transportation contracts supporting new gas capacity for long durations.
  • The gas system planning framework should incorporate the most current science and economics, including an up-to-date valuation of the social cost of greenhouse gases.
  • A Clean Heat Standard may be useful, but it is not a substitute for comprehensive gas system planning. 
  • Analysis of proposals to rely on alternative fuels such as renewable natural gas and hydrogen must be carefully examined, with particular attention to lifecycle emissions impacts, costs, and feasibility at scale.