EMA Comments on New Jersey’s Staff Straw Proposal on Defining the Clean Energy Act of 2018’s Statutory Cost Caps

Re: EMA Comments on New Jersey’s Staff Straw Proposal on Defining the Clean Energy Act of 2018’s Statutory Cost Caps

Dear New Jersey Board of Public Utilities and Staff:

The Environmental Markets Association (“EMA”) is pleased to help inform the design of New Jersey’s solar transition as required by P.L. 2018, c.17 (the “Clean Energy Act”). EMA recognizes and appreciates the immense challenge that the New Jersey (“NJ”) Board of Public Utilities (“BPU”) has been assigned with in the implementation of the CleanEnergy Act, particularly around the issues of the cost cap and the desire to promote solar growth in the State, while cost-effectively achieving a 50% renewable portfolio standard (“RPS”) by 2030.

EMA is comprised of local, regional, and national member companies that have participated in NJ’s Class I renewable energy certificate (“REC”), Class II REC, and solar renewable energy certificate (“SREC”) market programs since inception, including early engagement in the actual setup and implementation of the original renewable portfoliostandard (“RPS”) and NJ SREC program. EMA Members have worked extensively to achieve the program’s targets and continue to interface with the RPS in multiple ways (e.g., as retail electricity suppliers, basic generation service providers, REC traders, REC brokers, REC marketplaces, REC aggregators, and as renewable energy project developers and investors).

Thank you for your consideration of our comments attached in Appendix A. EMA’s answers here are limited solely to item #3 and discuss our rationale as to why we strongly discourage the BPU from taking any actions to reform or restructure the existing NJ SREC market since this will undermine the market’s integrity and result in significant contractual and financial damages for New Jersey’s clean energy industry. Previous comments filed by the EMA may also offer the BPU useful guidance on this proceeding. The EMA is ready to offer any additional assistance as needed by the BPU as New Jersey moves toward its clean energy future.

View the Full Comments Here