CRA Straw Proposal and Proposed Fiscal Year 2017 Budgets in the Matter of the Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for Fiscal Year 2017 Clean Energy Program, BPU Docket No. QO16040352 and in the Matter of the Clean Energy Programs and Budget for the Fiscal Year 2017, BPU Docket No. QO16040353

CRA Comments


In the Matter of the FY2017 Comprehensive Resource Analysis and Fiscal Program Budget, Office of Clean Energy Straw Proposal and Compliance Filings and Revisions to the FY2015 NJCEP Protocols; Rate Counsel's Public Statement at the Public Hearing on June 10, 2016 before the New Jersey Board of Public Utilities, at the State House Annex, Committee Room 11, 125 West State Street, Trenton, NJ

CRA Comments


Remarks of Rate Counsel Litigation Manager Brian Lipman on Bill S2276 (Establishes Solar Energy Study Commission & Modifies State's Solar Renewable Energy Portfolio), Presented at the Senate Environment and Energy Committee Meeting (6/6/16)


Petition of Public Service Electric & Gas Company To Continue Its Efficiency Economic Extension Program On A Regulated Basis (“EEE Extension II”), BPU Docket No. E014080897

PSEG EEE Extension II Initial Brief


2015 Energy Master Plan Update

Comment filed by the Division of Rate Counsel (8/24/15)

Remarks of Director on the Energy Master Plan, Presented at the NJ Board of Public Utilities Public Hearing, Newark, NJ (8/11/15); Trenton, NJ (8/13/15); Galloway, NJ (8/17/15)


Comments of the New Jersey Division of Rate Counsel on CEP-Proposed Modifications to the EE and RE Program Budget (Comfort Partners Program) (6/3/15)

Comments of the New Jersey Division of Rate Counsel (6/10/15)


Comments of the New Jersey Division of Rate Counsel Fiscal Year 2016 Renewable Electric Storage Incentive Program Straw Proposal Issued May 2015

Comments filed by the Division of Rate Counsel (5/29/15)


Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for Fiscal Year 2016 Clean Energy Program

Comments filed by the Division of Rate Counsel (5/29/15)


Comments of the New Jersey Division of Rate Counsel Board of Public Utilities Rules of Practice

Comments filed by the Division of Rate Counsel (5/15/15)


Comments of the New Jersey Division of Rate Counsel CEP Proposed Modifications to Multiple Program Budgets

Comments filed by the Division of Rate Counsel (5/6/15)


Comments of the New Jersey Division of Rate Counsel CEP Proposed Revisions to NJCEP Protocols

Comments filed by the Division of Rate Counsel (4/27/15)


Comments on the Board's Main Extension Rules, N.J.A.C. 14:3-8.1

Comments filed by the Division of Rate Counsel (1/30/15)


Rate Counsel's Comments on the Office of Clean Energy's FY2016 Comprehensive Resource Analysis (CRA) Straw Proposal and Budget at the Public Hearing before the New Jersey Board of Public Utilities (5/22/15) 


Petition of Public Service Electric & Gas Company to Continue its Efficiency Economic Extension Program on a Regulated Basis ("EEE Extension II") (1/21/15)


Clean Energy Programs and Budget for the Fiscal Year 2015, BPU Docket No. QO14050489 (6/12/14)


DRAFT Energy Efficiency Cost-Benefit Analysis Avoided Cost Assumptions (Rutgers Center for Energy, Economic & Environmental Policy (“CEEEP”) (12/8/14))

CEEEP Comments


Petition Of Public Service Electric & Gas Company To Continue Its Efficiency Economic Extension Program On A Regulated Basis (“EEE Extension II”), BPU Docket No. E014080897 (8/24/15)

PSEG_EEE_Extension_II_Initial_Brief


Public Service Electric & Gas Company ("PSE&G") to Continue its Energy Efficiency Economic Extension Program ("EE EXT II"), BPU Docket No. EO14080897.

Direct Testimony of Andrea C. Crane (11/7/14)

Direct Testimony of Kenji Takashi (11/7/14)


2nd Straw Proposal — Fiscal Year 2015 Energy Storage Program

2nd Straw Proposal FY15 Comments (8/22/14) 


Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for Fiscal Years 2014-2017 Clean Energy Program, BPU Docket No. EO11050324V

Clean Energy Programs and Budget for the Fiscal Year 2015, BPU Docket No. QO14050489

FY2015 RE and EE Program Comments (8/15/14) 


Petition of Fishermen’s Atlantic City Windfarm, LLC for the Approval of the State Waters Wind Project and Authorizing Offshore Wind Renewable Energy Certificates, BPU Docket No.: EO11050314V

Reply Brief by the New Jersey Division of Rate Counsel to the position paper of the Staff of the New Jersey Board of Public Utilities regarding the stipulation executed by the New Jersey Division of Rate Counsel and Fishermen’s Atlantic City Windfarm, LLC (7/12/13)


Implementation of L. 2012, c. 24, N.J.S.A. 48:3-87(d)(3)(b) A Proceeding to Investigate Approaches to Mitigate Solar Development Volatility, BPU Docket No. EO12090860V

Comments of the New Jersey Division of Rate Counsel (7/1/13)

Comments of the New Jersey Division of Rate Counsel filed with the NJ Board of Public Utilities (4/11/14)


Combined Heat and Power/Fuel Cell Working Group May 2, 2012 Request for Comments on Staff Draft Straw Proposal Combined Heat and Power (CHP) Long Term financing Incentive Mechanism-a “Smart” Portfolio Standard Revised Draft (5/15/13)

Comments of the New Jersey Division of Rate Counsel (5/30/13)


Petition of Public Service Electric and Gas Company For Approval of Extension of a Solar Generation Investment Program and Associated Cost Recovery Mechanism and for Changes in the Tariff for Electric Service, B.P.U.N.J. No. 15 Electric Pursuant to N.J.S.A. 48:2-12 and N.J.S.A. 48:2-21.1 ("PSE&G Solar 4 All Extension Petition") BPU Docket No.: EO12080721

Petition of Public Service Electric and Gas Company for Approval of a Solar Loan III Program and an Associated Cost Recovery Mechanism and for Changes in the Tariff for Electric Service, B.P.U.N.J. No. 15 Electric Pursuant to N.J.S.A. 48:2-21 and N.J.S.A. 48:2-21.1 ("Solar Loan III Petition) BPU Docket No.: EO12080726

In July and August 2012, Public Service Electric and Gas Company filed two Petitions with the New Jersey Board of Public Utilities. One of the Petitions seeks approval for a proposed "Solar Loan III" program that would allow the Company to provide $193 million in financing to its customers to develop 97.5 MW of solar capacity on the customers’ premises. The second Petition seeks approval for an extension of the Company’s Solar 4 All program, to be known as the "Solar 4 All Extension Program," that would allow invest $729.4 million in 136 MW of Company owned and operated solar projects over a five-year period. Both Petitions request authorization for PSE&G to recover the costs of the proposed programs from the Company’s ratepayers.

Rate Counsel files objections to non-unanimous Stipulation in PSE&G Solar 4 All Extension and Solar Loan III Matters (5/9/12) 

Position Paper concerning the PSE&G Solar Loan III matter submitted on behalf of the New Jersey Division of Rate Counsel (4/15/13)

Position Paper concerning the PSE&G Solar-4-All matter submitted on behalf of the New Jersey Division of Rate Counsel (4/15/13)

Surrebuttal Testimony of Andrea C. Crane, David E. Dismukes, Ph.D and Matthew I. Kahal, filed on behalf of the New Jersey Division of Rate Counsel in the "Solar Loan III" matter (3/1/13)

Surrebuttal Testimony of Andrea C. Crane, David E. Dismukes, Ph.D and Matthew I. Kahal, filed on behalf of the New Jersey Division of Rate Counsel in the "Solar 4 All" matter (3/1/13)

Direct Testimony of Andrea C. Crane and David E. Dismukes, Ph.D., with attachment and schedules filed on behalf of the New Jersey Division of Rate Counsel in the "Solar Loan III" matter (1/11/13)
 
Direct Testimony of Andrea C. Crane and David E. Dismukes, Ph.D., with attachment filed on behalf of the New Jersey Division of Rate Counsel on the "Solar 4 All" matter (1/18/13)

Public Hearing Statement given by Paul Flanagan, Litigation Manager in New Brunswick, NJ (11/27/12)


Comments of the New Jersey Division of Rate Counsel Regarding Aggregated Net Metering Rules Pursuant to N.J.S.A. 48:3-87(e)(4)
 
Comments
of the New Jersey Division of Rate Counsel (2/22/13)


Combined Head and Power/Fuel Cell Working Group January 31, 2013 Request for Comments
 
Comments
of the New Jersey Division of Rate Counsel (2/22/13)


Rate Counsel Testimony regarding Fisherman's Atlantic City Wind Farm. BPU Docket No. EO11050314V

Direct Testimony of David E. Dismukes, PH.D. on behalf of the New Jersey Division of Rate Counsel.

Attachment B: Updated Assessment of the Net Economic Benefits of the Proposed Fishermen’s Atlantic City Windfarm


Implementation of L.2012, c.24, the Solar Act of 2012, BPU Docket No.: EO12090832V
The Board of Public Utilities sought comments on the numerous new standards and programs outlined by the New Jersey Legislature in L. 2012, c. 24, also know as the Solar Act.
 
Comments of the Division of Rate Counsel (11/21/12)


Staff Draft Straw Proposal NJCEP 2013 through 2016 Funding Level Now the NJCEP 2014 through 2017 Funding Level Comprehensive Energy Efficiency and Renewable Energy Resource Analysis, BPU Docket No.: EO10050324V (8/22/12)
 
Board Staff issued a Straw Proposal for the purpose of developing program funding levels and funding allocations for the Office of Clean Energy for calendar years 2013 through 2016.

 
Comments
of the Division of Rate Counsel (10/26/12)


Offshore Wind Renewable Energy Rules - Proposed Readoption with Amendments to N.J.A.C. 14:8-6, BPU Docket No.: EX12050466

Comments of the Division of Rate Counsel (10/19/12)


Renewable Energy and Energy Efficiency Proposed Amendments: N.J.A.C. 1:8-1.2, 2.9, 4.1, 4.2, 4.3 and 5.2. BPU Docket No.:EX11120885V, Proposal No.: PRN2012-099

Comments of the New Jersey Division of Rate Counsel (10/5/12)


"New Jersey Energy Efficiency Market Potential Assessment" (EnerNOC report, dated August 31, 2012)
 
The New Jersey Board of Public Utilities sought comments on EnerNOC's energy efficiency market assessment study for New Jersey, entitled "New Jersey Energy Efficiency Market Potential Assessment" dated August 31, 2012.

 
Comments
of the Division of Rate Counsel filed (9/20/12)


New Jersey Clean Energy Program - Draft Revisions to the July 2011 Protocols (issued April 2012).
 
Comments
submitted by the New Jersey Division of Rate Counsel (5/1/12)


General Questions Posed by Board Staff Regarding the Implementation of an Act Permitting Credits Against the Societal Benefits Charge (P.L. 2011, c216; A2528/S2344
 

Comments of the Division of Rate Counsel (3/16/12)


In the Matter of the Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for 2009-2012: 2012 Programs and Budgets Compliance Filings, BPU Docket No. EO1110631V

The Office of Clean Energy is proposing a total Renewable Energy budget of $28.282 million of which $18.383 million included carry-overs from prior year Customer On-Site Renewable Energy ("CORE") rebate dollars ($4.15 million) and Renewable Energy Incentive Program ("REIP") funds ($14.233 million).
 
Comments of the Division of Rate Counsel (11/10/11)


In the Matter of the Petition of Fishermen's Atlantic City Windfarm, LLC for the Approval of the State Waters Project and Authorizing Offshore Wind Renewable Energy Certificates, BPU Docket No. EO11050314V
 
On May 19, 2011, Fishermen's Atlantic City Windfarm LLC ("FACW") filed a  revised Petition with the New Jersey Board of Public Utilities requesting permission to build a state waters offshore windfarm project.  FACW originally proposed to use six (6) 4 MW turbines generators for a total project capacity of 24 MW.  Currently, FACW is proposing to use six (6) 5 MW turbines supplied by Xiangtan Electric Manufacturing Group.  FACW is proposing to locate the windfarm 2.8 miles offshore from Atlantic City beaches and, if built, will be the first offshore wind farm in the United States.

 
Public Testimony of David Dismukes, Ph. D. and Report filed on behalf of Rate Counsel (2/3/12)


Re: Solar Transition Working Group-Comments on OCE's Proposed Options to Revise the Solar Renewable Portfolio Standards dated January 5, 2012

The New Jersey Board of Public Utilities sought comments on two solar transition proposals offered by the Office of Clean Energy.  Both options would purportedly address the volatility in the Solar Renewable Energy Certificate ("SREC") market while maintaining downward pressure on SREC prices.

Comments of the Division of Rate Counsel (1/25/12)


Re: New Jersey Clean Energy Program Renewable Energy Committee - Request for Comments on Staff Solar Transition White Paper
 

Comments of the Division of Rate Counsel filed on September 14, 2011


Re: On the Developer Proposals for the Development of an Offshore Wind Renewable Energy Certificate ("OREC") Program Offshore Wind Working Group and Offshore Wind Economic Development Act, N.J.S.A. 48:3-49 et seq. ("OWEDA") Comments, BPU Docket No. Pending.
 

The Board of Public Utilities sought comments on the proposed OREC funding mechanism offered by the group of offshore wind developers over the course of the past three months at the offshore wind working group meetings.
 
Comments, of the Division of Rate Counsel filed on September 12, 2011. 


In the Matter of Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for 2009-2010 Clean Energy Programs: 2011 Programs and Budgets: Compliance Filings Proposed Extension of Promotional Incentive Increases (HPwES), BPU Docket No. EO07030203 and EO10110865.
 

The Board of Public Utilities sought comments on the proposal to extend increases in certain 2011 Clean Energy program incentives.
 
Comments of the Division of Rate Counsel filed on September 12, 2011.


In the Matter of Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for 2009-2012 Clean Energy Program: 2011 Programs and Budgets: Compliance Filings, BPU Docket No.: EO7030203 and EO10110865

The Board of Public Utilities sought comments on the proposed changes to the 2011 Clean Energy Program, Energy Efficiency Program budget which were circulated to stakeholders for comment by the Applied Energy group on behalf of the office of Clean Energy.
 
Comments
of the Division of Rate Counsel filed on September 8, 2011.


In the Matter of Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for 2009-2012 Clean Energy Program: 2011 Program and Budgets: Compliance Filings, BPU Docket Nos. EO07030203 and EO010110865

The New Jersey Board of Public Utilities recently sough comment on the proposed changes to the Board-approved 2011 Clean Energy Program and energy efficiency program budget which were circulated to stakeholders for comments by the Applied Energy Group on August 11, 2011.
 
Comments of the Division of Rate Counsel filed August 25, 2011.


New Jersey Clean Energy Program Net Metering and Interconnection Working Group-Comments on Solar Alliance and Interstate Renewable Energy Council Interconnection Rule Proposals
 
Following a July 22, 2011 meeting of the Net Metering and Interconnection Standards Working Group, the Board's Office of Clean Energy requested comments on the Solar Alliance and Interstate Renewable Energy Council proposals.

 
Comments
of the New Jersey Division of Rate Counsel filed August 16, 2011.


In the Matter of Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for 2009-2012: 2011 Program and Budgets: Compliance Filings Fuel Cell Incentive Proposal, BPU Docket Nos.: EO07030203 and EO10110865


The Board requested comments on the proposed modifications to the 2011 Clean Energy Program incentives for fuel cells which were submitted to stakeholders for comment by the Office of Clean Energy in an e-mail notice issued July 20, 2011.  The OCE has requested comments on its proposal to (1) institute a new incentive for fuel cells without heat recovery and (2) modify the current incentive for fuel cells with heat recovery.

 
Comments
of the New Jersey Division of Rate Counsel filed July 29, 2011.


I/M/O New Jersey Clean Energy Program net Metering and Interconnection Work Group-Staff Draft/Straw Proposal for Amendments to net Metering Regulations
 

The Board of Public Utilities sought comments to the "Staff Draft/Straw Proposal for amendments to the Board's Net Metering regulations, N.J.A.C. 14:8, that were circulated to the Renewable Energy Committee and Net Metering and Interconnection Standards Working Group by e-mails dated July 19, and July 21, 2011.  At the July 22, 2011 meeting of the Net Metering and Interconnection Standards Working Group Staff invited comments on the Straw Proposal to be submitted no later than July 29, 2011.
 
Comments submitted by Rate Counsel on July 29, 2011.


Office of Clean Energy ("OCE") Straw Proposal, Solar Alternative Compliance Payment Rate Schedule ("SACP") (2017-2025).
 

Comments of Division of Rate Counsel regarding the OCE straw proposal to extend the current eight-year SACP schedule to a 15-year schedule, filed on July 8, 2011.


New Jersey Clean Energy Program - Draft Revisions to the September 2010 Protocols (May 2011)

Comments of the New Jersey Division of Rate Counsel filed June 15, 2011.


In the Matter of Comprehensive Energy Efficiency and Renewable energy Resource Analysis for 2009-2012: 2011 Program and Budgets: Proposed Changes to CORE and REIP Extension Policy and Proposal for Large Energy Users Pilot Incentive Program, BPU Docket Nos.: EO07030203 and EO10110865
 
On May 3, 2011 the Office of Clean Energy ('OCE") issued a notice requesting comments on two issues, (1) whether to allow OCE to use ratepayer funds to continue certain American Recovery and Reinvestment Act (ARRA") programs after ARRA funds are exhausted; and (2) whether $5 million should be re-allocated from the Renewable Energy Program budget to the Comfort Partners low-income weatherization program.

 
Comments of the New Jersey Division of Rate Counsel filed on May 10, 2011.


New Jersey's Renewable Portfolio Standard Rules 2010 Annual Report.
 
Comments of the New Jersey Division of Rate Counsel filed on May 31, 2011 on the Office of Clean Energy's Draft 2010 Annual Renewable Portfolio Standard Rules Report.


In the Matter of Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for 2009-2012: 2011 Programs and Budgets: Compliance Filings - Revisions to Previously Approved Budget, BPU Docket Nos.: EO07030203 and EO10110865.
 
In a notice issued May 12, 2011, the Office of Clean Energy requested comments on modifications for the 2011 Clenn Energy Program on two issues (1) proposed changes to the Home performance with ENERGY STAR budget and programs; and (2) proposed changes to the ENERGY STAR Products Program budget.

 
Comments of the New Jersey Division of Rate Counsel filed on May 20, 2011.


In the Matter of Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for 2010-2011: 2011 Programs and Budgets: Compliance Filings: Transitions within the Clean Energy Program, BPU Docket No. EO07030203

Comments of the New Jersey Division of Rate counsel on the Transitions within the Clean Energy Program filed on December 3, 2011.  


EDC Long-Term SREC Contracting Programs, BPU Docket Nos. EO06100744, EO08100875, EO08091840 and EO09020097

Initial Comments of the New Jersey Division of Rate Counsel on proposed modifications to the EDC Long-Term SREC contracting programs filed on November 19, 2010.


I/M/O the Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for 2010-2011:2011 Program and Budgets Compliance Filings: Transitions within the Clean Energy Program. BPU Docket No. EO07030203

Comments filed by the New Jersey Division of Rate Counsel to the Office of Clean Energy on November 17, 2010 on Proposed Budgets for 2010 Energy Efficiency Programs and Renewable Energy Programs.


In the Matter of the Offshore Wind Rebate Program for the Installation of Meteorological Towers, BPU Docket Nos. EO08121062 and EO08121064  

Comments
 of the Division of Rate Counsel regarding the Off-Shore Wind Rebate Program for the Installation of Meteorological Towers. 


Request for Comments Regarding Comfort Partners Program Budget

Comments
submitted by the Division of Rate Counsel pursuant to a request circulated by the Office of Clean Energy on August 12, 2010.


2010 Budget for Renewable Energy and Energy Efficiency Programs. 

Comments submitted on behalf of the Division of Rate Counsel on June 15, 2010, regarding the straw proposals for 2010 Energy Efficiency and Renewable Energy budget and program revisions.


Renewable Portfolio Standards ("RPS") Stakeholders Working Group

Comments
filed by Rate Counsel on June 9, 2010 on the proposed rules and topics of discussion at the May 25, 2010 RPS Stakeholders Working Group Meeting.


In the Matter of Comprehensive Energy Efficiency and Renewable Energy Resource Analysis for 2009-2010: 2010 Programs and Budgets:  Compliance Filings - Revisions to Previously Approved Budget, BPU Docket No.:EO07030203 

Comments on the 'Straw Proposal" for modifications to the 2010 Clean Energy Program budget submitted to stakeholders, filed on March 25, 2010.


Benefit-Cost Analysis of the Proposed Energy Efficiency Utility Programs Associated with the New Jersey Economic Stimulus Plan (CEEEP Draft Report dated December 15, 2009)

Comments of the Department of the Public Advocate, Division of Rate Counsel, filed on March 3, 2010. 


Comments on the 2010 Budget and Program Proposals and Compliance Filings Submitted by the EE and RE Market Managers and Others

The Market Managers and others for the New Jersey Clean Energy Program 2010 program drafted proposals and compliance filings.  As input to drafting its own overall proposal, the New Jersey Office of Clean Energy has invited comments on the several draft proposals submitted to date.

Comments of the Public Advocate, Division of Rate Counsel filed on November 13, 2009.


In the Matter of Revisions to New Jersey's Clean Energy Program December 2007 Protocols to measure Resource Savings, BPU Docket No. ER09070460

Pursuant to the schedule set forth in the Order dated October 10, 2009, the New Jersey Office of Clean Energy sought comments addressing the New Jersey Clean Energy Program Protocols to Measure Resource Savings dated December 2008.

Comments of the Public Advocate, Division of Rate Counsel filed on November 13, 2009.


Revisions to the Renewable Portfolio Standard Regarding Solar Energy RPS Requirements, Solar Interconnection Requirements, SREC Registration, and Solar Metering Requirement. 

On September 30, 2009 the New Jersey Board of Public Utilities issued a Request for Public Comment on draft revisions to the current RPS Rule (N.J.A.C. 14:8-2).

Comments of the New Jersey Department of the Public Advocate filed on October 15, 2009.


Community-Based Renewable Energy Program - EA-07110885
 
Rate Counsel supports the development of a community-based renewable energy program that can assist smaller-scale customer in pooling their resources to attain the cost and efficiency benefits of larger-scale renewable energy projects currently limited to only larger customer classes.
 
Comments filed by Rate Counsel on July 14, 2009.


Revised Straw Proposal - New Jersey's Offshore Wind Renewable Energy Certificate ("OREC") BPU Docket No: EX08100930
 

An integral part of the Energy Master Plan has been the call for a minimum of 1,000 megawatts of offshore wind capacity to be developed by 2012, and a minimum of 3,000 MW of offshore wind capacity by 2020.  The Office of Clean Energy in its revised straw proposal proposes to establish an offshore wind set-aside or "carve-out" within New Jersey's Renewable Portfolio Standard.

Supplemental Comments filed by Rate Counsel on  April 1, 2009. 

Comments filed by Rate Counsel on March 26, 2009.


Net Metering and Interconnection Rules, BPU Docket No. EX08070548 

The Board of Public Utilities proposed modifications to its rules regarding Net Metering and Interconnections.  The two areas addressed were (1) the annualized period to be used in the determination of the annual true-up for customer-generations whose renewable energy exceeds their own electricity usage and (2) the current 2 MW cap on the capacity of each renewable generating unit.

Comments filed by Rate Counsel on December 5, 2008