In the Matter of the Provision of Basic Generation Service for the Period Beginning June 1, 2024, BPU Docket No. ER23030124

NJDRC Final Comments on the Provision of Basic Generation Service for the Period Beginning June 1, 2024, BPU Docket No. ER23030124 (10/6/23)

NJDRC Initial Comments on the Provision of Basic Generation Service (BGS) For the Period Beginning June 1, 2024, BPU Docket No. ER23030124 (9/5/23)


S2356/ A3671 (Extends prohibition on certain utility discontinuances for certain customers)

NJDRC Letter of Support to the Senate Law & Public Safety Committee on S2356/A3671 (Extends prohibition on certain utility discontinuances for certain customers)(3/18/22)


ZEC 2 Appeal - Brief for Appellant Division of Rate Counsel (Public Version), BPU Docket Nos. ER20080557, ER20080558, ER20080559, Superior Court of New Jersey, Appellate Division Docket No. A-002518-20

NJDRC's Reply Brief on the ZEC 2 Appeal, BPU Docket Nos. ER20080557, ER20080558, ER20080559, Superior Court of New Jersey, Appellate Division Docket No. A-002518-20 (3/14/22)

NJDRC's Appeal Brief (Public Version) on the ZEC 2 Case with the Appellate Court, Appellate Docket No. A-002518-20 (10/12/21)


IMO Provision of Basic Generation Service for the Period Beginning June 1, 2022, BPU Docket No. ER21030631

NJDRC Comments, BPU Docket No. ER21030631 (9/3/21)


IMO 2021/2022 Annual Compliance Filings For Changes in the Statewide Electric and Gas Permanent Universal Service Fund (“USF”) and Lifeline Rates within the Societal Benefits Charge Rate, BPU Docket No. ER21060939

NJDRC Comments, BPU Docket No. ER21060939 (9/2/21)


Implementation of L.2018, C. 16 Regarding the Establishment of a Zero Emission Certificate Program for Eligible Nuclear Power Plants, BPU Docket No. EO18080899

NJDRC Petition for Certification with the Supreme Court, Supreme Court Docket No. 085640, BPU Docket No. EO18080899 (4/19/21)


Applications of PSEG Nuclear, LLC And Exelon Generation Company, LLC for the Zero Emission Certificate Program - Salem Unit 1, 2 and Hope Creek Unit Docket Nos. ER20080557, ER20080558, ER20080559

NJDRC's Brief (Redacted), BPU Docket Nos. ER20080557, ER20080558, ER20080559


The New Jersey Board of Public Utilities' Response to the COVID-19 Pandemic, BPU Docket No. AO20060471

Comments of the Division of Rate Counsel on the NJ Board of Public Utilities Response to the COVID-19 Pandemic (3/1/21)


Applications of PSEG Nuclear, LLC And Exelon Generation Company, LLC for the Zero Emission Certificate Program - Salem Unit 1, 2 and Hope Creek Unit, BPU Docket Nos. ER20080557, ER20080558, ER20080559

Direct Testimony of Mr. Maximilian Chang (Redacted), BPU Docket Nos. ER20080557, ER20080558, ER20080559 (1/29/21)

Direct Testimony of Ms. Andrea Crane (Redacted), BPU Docket Nos. ER20080557, ER20080558, ER20080559 (1/29/21)


I/M/O the 2020/2021 Annual Compliance Filing For a Change in the Statewide Electric and Gas Permanent Universal Service Fund Program Factors within the Electric and Gas Societal Benefits Charge Rate Pursuant to N.J.S.A. 48:2-21 and N.J.S.A. 48:21.1, BPU Docket No. ER20060392

Comments filed by the Division of Rate Counsel, BPU Docket No. ER20060392 (9/8/20)


I/M/O the BPU Investigation of Resource Adequacy Alternatives - Rate Counsel’s Reply Comments, BPU Docket No. EO20030203

NJDRC Reply Comments - BPU Investigation of Resources Adequacy Alternatives Response to Staff Request, BPU Docket No. EO20030203 (6/24/20)


In the Matter of the Provision of Basic Generation Service for the Period Beginning June 1, 2021, BPU Docket No. ER20030190

NJDRC Final Comments on the 2021 Basic Generation Service Filings, BPU Docket No. ER20030190 (10/5/20)


New Jersey Energy Efficiency Transition Stakeholder Process - LED Streetlight Conversion and Tariffs

Comments filed by the NJ Division of Rate Counsel on the LED Streetlight Conversion and Tariffs (2/21/2020)


I/M/O the Board’s Proposed Amendments and New Rules Concerning Discontinuance and Restoration of Utility Service, N.J.A.C. 14:3-3A.1.1, -3A.2 and -3A.4, BPU Docket No. AX19060729

Comments filed by the NJ Division of Rate Counsel on the proposed Rules Concerning Discontinuance and Restoration of Utility Service (1/31/2020)


In the matter of the Adopted Amendment to N.J.A.C. 14:1-5.12 (Tariff Filings or Petition which Propose Increases in Charages to Customers), BPU Docket Nos. AX1750469, AX17050468, AX17111144, Appellate Docket No. A-003621-18

In the matter of the Adopted Amendment to N.J.A.C. 14:1-5.12 (Tariff Filings or Petition which Propose Increases in Charages to Customers), BPU Docket Nos. AX1750469, AX17050468, AX17111144, Appellate Docket No. A-003621-18 (12/11/19)

CTA Appeal - Brief for Appellant Division of Rate Counsel (9/12/19)


In the Matter of the Provision of Basic Generation Service for the Period Beginning June 1, 2020, BPU Docket No. ER19040428

Initial Comments filed by the Division of Rate Counsel on September 4, 2019 (9/4/19)


I/M/O the Implementation of L.2018, C. 16 Regarding the Establishment of a Zero Emission Certificate Program for Eligible Nuclear Power Plants, BPU Dkt. No. EO18080899

ZEC Appeal - Reply Brief for Appellant Division of Rate Counsel, BPU Docket Nos. EO18080899, EO18121338, EO18121339, EO18121337, Superior Court of New Jersey Appellate Division Docket No. A-003939-18 (1/27/20)

ZEC Comments filed on behalf of the New Jersey Division of Rate Counsel, BPU Docket No. EO18080899 (9/30/19)

ZEC Appeal - Brief for Appellant Division of Rate Counsel, BPU Docket Nos. EO18080899, EO18121338, EO18121339, EO18121337, Superior Court of New Jersey Appellate Division Docket No. A-003939-18 (9/18/19)

Notice of Appeal and Case Information Statement, filed by the Division of Rate Counsel on the establishment of a Zero Emission Certificate Program for Eligible Nuclear Power Plants, BPU Docket No. EO18080899, Appellate Docket No. A-003939-18 (5/15/19)

Response Letter of the New Jersey Division of Rate Counsel on the Establishment of a Zero Emission Certificate Program for Eligible Nuclear Power Plants, BPU Dkt. No. EO18080899 (3/8/19)

Comments of the New Jersey Division of Rate Counsel on the Zero Emission Certificate Program (Public Version) (1/31/19)

Zero Emission Certificate Program, Certification of Andrea C. Crane on behalf of the New Jersey Division of Rate Counsel (Public Version) (1/31/19)

Zero Emission Certificate Program, Joint Certification of Bob Fagan and Maximilian Chang on behalf of The New Jersey Division of Rate Counsel (Public Version) (1/31/19)

Establishment of a Zero Emission Certificate Program for Eligible Nuclear Power Plants, BPU Dkt. No. EO18080899 - Rate Counsel Letter Secretary Camacho-Welch (12/06/18)

Establishment of a Zero Emission Certificate Program for Eligible Nuclear Power Plants, BPU Dkt. No. EO18080899 - Rate Counsel Comments (10/22/18)

Establishment of a Zero Emission Certificate Program for Eligible Nuclear Power Plants, BPU Dkt. No. EO18080899, Stefanie Brand, Director, Division of Rate Counsel Statement at Public Hearing, Hackensack, NJ (10/4/18)

Establishment of a Zero Emission Certificate Program for Eligible Nuclear Power Plants, BPU Dkt. No. EO18080899, Rate Counsel's Ltr. To BPU and Attorney General dtd. (9/21/18)


Infrastructure Investment and Recovery Proposed Amendment:  N.J.A.C. 14:3-2A, BPU Docket No. AX17050469

Infrastructure Investment and Recovery Proposed Amendment: N.J.A.C. 14:3-2A, Rate Counsel Comments, BPU Docket No. AX17050469 (10/6/17)

Infrastructure Investment and Recovery Proposed Amendment: N.J.A.C. 14:3-2A, Attachments A thru D, BPU Docket No. AX17050469


Provisional Rate Increase Implementation Proposed Amendment:  N.J.A.C. 14:1-5.12, BPU Docket No. AX17050468

Provisional Rate Increase Implementation Proposed Amendment: N.J.A.C. 14:1-5.12, Rate Counsel Comments, BPU Docket No. AX17050468 (10/6/17)

Provisional Rate Increase Implementation Proposed Amendment: N.J.A.C. 14:1-5.12, Exhibit A Utility Base Rate Data, BPU Docket No. AX17050468


In the Matter of the Provision of Basic Generation Service (BGS) For the Period Beginning June 1, 2018, BPU Docket No. ER17040335

In the Matter of the Provision of Basic Generation Service (BGS) For the Period Beginning June 1, 2018 - Final Comments filed by the Division of Rate Counsel, BPU Docket No. ER17040335 (10/13/17)

In the Matter of the Provision of Basic Generation Service (BGS) For the Period Beginning June 1, 2018 - Initial Comments filed by the Division of Rate Counsel, BPU Docket No. ER17040335 (9/6/17)


In  the  Matter  of  the  Proposed  Rule  Making  for Infrastructure Investment Programs – N.J.A.C. 14:3-2A.1, et seq., BPU Docket No. AX17050469

Division of Rate Counsel's Comments on Board of Public Utilities Announcement of Stakeholder Process Infrastructure Programs - Straw Proposal, BPU Docket No. AX17050469 (5/12/17)


In the Matter of the Proposed Amendments to N.J.A.C. 14:1-5.12, et seq. – Tariff Filings or Petitions which Propose Increases in Charges to Customers, BPU Docket No. AX17050468

Division of Rate Counsel's Comments on Board of Public Utilities Announcement of Stakeholder Process Straw Proposal for the Implementation of Provisional Rates, BPU Docket No. AX17050468 (5/12/17)


In the Matter of the Board’s Review of the Applicability and Calculation of a Consolidated Tax Adjustment, Appellate Docket. No. A-1153-14T1

NJDRC Letter (N.J.A.C. 14:1-5.12) to Secretary Camacho-Welch, BPU Docket No. AX17050468 (8/21/18)

Division of Rate Counsel’s Initial Brief (Public Version)

Division of Rate Counsel's Reply Brief (Public Version)


In the Matter of Third Party Suppliers - N.J.A.C. 14:4-7 - The Board’s Review of Consumer Protection Provisions of its Rules Concerning Third Party Suppliers, BPU  Dkt. No. EX14060579 and In the Matter of the Implementation of the Special Rule Adoption In Compliance with L. 2013, C.263, BPU Dkt. No. EX14060610

Rate Counsel Comments dated August 1, 2014

EX14060579 & EX14060610 Rate Counsel comments on BPU Consumer Protection Rules for TPSs Exhibits A-C

EX14060579 & EX14060610 Rate Counsel comments on BPU Consumer Protection Rules for TPS


In the Matter of the Provision of Basic Generation Service for the Period Beginning June 1, 2015, BPU Docket No. ER14040376

Final Supplemental Comments filed by the Division of Rate Counsel (10/29/14)

Supplemental Comments filed by the Division of Rate Counsel (10/22/14)

ER14040376_BGS_June_1__2015_RC_Crv_Ltr (9/3/14)

ER14040376 BGS_June_1_2015_Rate_Counsel_Initial_Comments (9/3/14)


I/M/O the Provision of Basic Generation Service for the Period Beginning June 1, 2015, BPU Docket No. ER14040370

By Order dated May 21, 2014, the New Jersey Board of Public Utilities directed New Jersey's four Electric Distribution Distribution Companies to file their BGS proposals no later than July 1, 2014 addressing how to procure the remaining one third of the State's Basic Generation Customers Fixed Price ("BGS FP") and Commercial and Industrial ("CIEP") customers requirements for the period beginning June 1, 2015. The Board also invited all other interested stakeholders to file alternative BGS procurement proposals with the Board by July 1, 2014.


I/M/O the Provision of Basic Generation Service for the Period Beginning June 1, 2014, BPU Docket No. ER13050378

By Order dated May 29, 2013, the New Jersey Board of Public Utilities directed New Jersey's four Electric Distribution Distribution Companies to file their BGS proposals no later than July 1, 2013 addressing how to procure the remaining one third of the State's Basic Generation Customers Fixed Price ("BGS FP") and Commercial and Industrial ("CIEP") customers requirements for the period beginning June 1, 2014. The Board also invited all other interested stakeholders to file alternative BGS procurement proposals with the Board by July 1, 2013.

Initial Comments filed by the Division of Rate Counsel on September 3, 2014.

Initial Comments filed by the Division of Rate Counsel on August 30, 2013.

Comments of Stefanie A. Brand, Director of the Division of Rate Counsel, Sept. 19, 2013, before the Board of Public Utilities, regarding the Provision of Basic Generation Service ("BGS") for the Period Beginning June 1, 2013.


I/M/O THE BOARD’S REVIEW OF THE APPLICABILITY AND CALCULATION OF A CONSOLIDATED TAX ADJUSTMENT, BPU Dkt. No. EO12121072

On January 23, 2013, the New Jersey Board of Public Utilities (“BPU” or “Board”) issued an Order establishing a proceeding to address the issue of Consolidated Income Tax Adjustments (“CTAs”).  CTAs result from the filing of a consolidated income tax return by a utility, its parent, and other members of a consolidated income tax group. The methodology currently utilized by the BPU to calculate CTAs has been utilized for approximately 20 years. Given the changes in tax laws and corporate structures over this period, the BPU has determined that it would be appropriate to review its consolidated income tax policy. 

Comments filed by the Division of Rate Counsel on May 3, 2012.


I/M/O the Provision of Basic Generation Service for the Period Beginning June 1, 2013, BPU Docket No. ER12060485

By Order dated June 18, 2012, the New Jersey Board of Public Utilities directed New Jersey's four Electric Distribution Distribution Companies to file their BGS proposals no later than July 2, 2012 addressing how to procure the remaining one third of the State's BGS FP and CIEP requirements. The Board also invited all other interested stakeholders to file alternative BGS procurement proposals with the Board by July 2, 2012.

Inital Comments filed by the Division of Rate Counsel on August 31, 2012.

Comments of Stefanie A. Brand, Director of the Division of Rate Counsel, Sept. 21, 2012, before the Board of Public Utilities,  Regarding the Provision of Basic Generation Service ("BGS") for the Period Beginning June 1, 2013.

Reply Comments filed by the Division of Rate Counsel on  September 28, 2012.


I/M/O the Board of Public Utilities' Investigation of Capacity Procurement and Transmission Planning

On May 16, 2011, the Board of Public Utilities ("Board") initiated a proceeding to investigate (1) whether there is a need to pursue additional generating capacity beyond the 2,000MWs that has already been contracted for under the Board's recently concluded Long-Term Capacity Agreement Pilot Program ("LCAPP") proceeding, (2) possible impediments to the development of new generation capacity in New Jersey, (3) the competitiveness of the State's power market; and (4) issues concerning the PJM Interconnection, LLC's. ("PJM") transmission planning process.  The Board is interested in determining the need for additional electric capacity and how best to facilitate the timely development of that capacity while addressing the reliability and economic needs of its ratepayers.

Remarks of Stefanie A. Brand, Director Division of Rate Counsel before Board of Public Utilities on October 14, 2011

Remarks of Stefanie A. Brand, Director Division of Rate Counsel before Board of Public Utilities on June 17, 2011

Comments filed by the Division of Rate Counsel on June 17, 2011


Comments of Stefanie A. Brand, Director of the Division of Rate Counsel, Sept. 21, 2010, Before the Board of Public Utilities,  Regarding the Provision of Basic Generation Service ("BGS") for the Period Beginning June 1, 2011.


I/M/O the Provision of Basic Generation Service for the Period Beginning June 1, 2010, BPU Docket No. EO09050351
 

Pursuant to the schedule set forth in the Board's Order dated May 20, 2009, the Department of the Public Advocate, Division of Rate Counsel is providing comments in response to the New Jersey Electric Distribution Companies' filing of July 1, 2009 and their responses to discovery requests.
 
Comments filed by the Division of Rate Counsel on August 28, 2009.


Proposed Amendments to 14:5-9.2 and 9.6, Vegetation Management for Electric Utility Lines, BPU Docket No. EX0804235

The New Jersey Board of Public Utilities proposed amendments to its rules for vegetation management for electric utility lines. The purpose of the amendments is to review and revise the vegetation management rules in an attempt to ensure proper maintenance of Electric Distribution Companies Transmission Line right of Way.
 
Comments filed by the Division of Rate Counsel on July 22, 2009.

Public Hearing Statement given by James W. Glassen on July 21, 2009 at the Board of Public Utilities in Newark, New Jersey.


Proposed Amendments to N.J.A.C. 14:4-1.2, 14:8-2.1 to 8-2.3, 2.8 to 2.11 Published June 15, 2008, New Jersey Public Register Before the New Jersey Board of Public Utilities
 

Comments filed by the Division of Rate Counsel on August 15, 2008 on the BPU's proposed revisions to the solar energy component of it Renewable Portfolio Standards Rule.

2009-2012 Comprehensive Resource Analysis, BPU Docket No. EO07030203

On January 11, 2008, the Office of Clean Energy released a draft-straw proposal for funding the Clean Energy Program during the years 2009-2012.

Comments filed by Rate Counsel on the various straw proposals offered by the Office of Clean Energy on renewable energy funding. Filed on May 6, 2008.

Comments filed by Rate Counsel on energy Efficiency Programs on May 6, 2008.

In the Matter of the Proposal for Account Look-Up for Third Party Suppliers and Clean Power Marketers, BPU Docket No. EA07110885

On November 30, 2007, the BPU issued a request for comments to all interested parties concerning a procedure to allow local distribution companies (gas and electric) to release customer account information to third party energy suppliers or clean power marketers pursuant to N.J.A.C. 14:4-1A.3.

Comments filed on January 11, 2008, in response to the BPU's request for comments.


In the Matter of the Comprehensive Energy Efficiency and Renewable Energy Analysis for 2005-2008, Final 2007 programs and Budgets: Compliance Filings-Modification of smart Growth Restrictions and Combined Heat and Power (CHP) Eligibility, BPU Docket No. EX04040276

The below comments are filed in response to a public notice issued by the Secretary to the Board of Public Utilities on or about November 30, 2007.


Comments of the Division of Rate Counsel regarding the proposed EE program amendment and the proposed correction of certain provisions of market manager TRC's compliance filing concerning the Combined Heat and Power Program.
Market Manager Recommendations of the 2008 Clean Energy Program Renewable Energy, Energy Efficiency Programs and Energy Efficiency Protocols, BPU Docket No. EX04040276

Rate Counsel is participating in the proposed 2008 Renewable Energy ("RE") budget and RE programs, Energy Efficiency ("EE") budget and EE programs.

Final Comments filed by Rate Counsel on November 30, 2008 which address the proposed budgets and program proposals developed by the Market Managers.
I/M/O the Provision of Basic Generation Service-Implementation of a Demand Response Program, BPU Docket No. EO07050351

On June 26, 2007, the Board invited the four electric utilities, Demand Response Providers and any other interested party to join the BGS Demand Response Working Group. The goal of the Working Group is to design a Pilot Demand Response procurement program that can be presented for Board approval.


Comments filed by Rate Counsel on November 28, 2007 pursuant to a notice posted on the New Jersey Board of Public Utilities website requesting that comments be filed by November 28, 2007.

Letter filed on September 27, 2007 by Rate Counsel requesting Board clarification as to how the price of the Demand Response Service should be set.

I/M/O the Provision of Basic Generation Service for the Period Beginning June 1, 2008. BPU Docket No. ER07060379.

By Order dated June 22, 2007, the New Jersey Board of Public Utilities directed New Jersey's four Electric Distribution Distribution Companies to file their BGS proposals no later than July 2, 2007 addressing how to procure the remaining one third of the State's BGS FP and CIEP requirements. The Board also invited all other interested stakeholders to file alternative BGS procurement proposals with the Board by July 2, 2007.


 
Initial Brief filed on August 4, 2008 on Appeal from the January 25, 2008 Order of the New Jersey Board of Public Utilities. 

Notice of Appeal and Case Information Sheet On March 10, 2008, Rate Counsel filed a Notice of Appeal and Case Information Statement with the Appellate Division stating that the S-REC value over $300 should not be passed through to ratepayers as additional costs.

Comments filed by Rate Counsel on July 2, 2007 advocating among other things the hiring of a "Portfolio Manager" to insure price stability, economic supply and reduced prices.

Comments filed by Rate Counsel on August 24, 2007 addressing the issues of: Pay As Bid and Tick Down on Ties; Pass through of changes in transmission charges; Information concerning BGS-FP supply sources and; The BGS portfolio.

Final Comments filed on September 28, 2007 where Rate Counsel responds to comments made and issues raised by other parties in their initial comments.

I/M/O the Renewable Portfolio Standard - Recommendations for Alternative Compliance Payments and Solar Alternative Compliance Payment for Energy Year 2008, a Stakeholder Process Regarding Alternative Compliance Payment and Solar Alternative Compliance Payment levels for Energy Year 2009 and 2010 or Longer, and a Solar REC-Only Pilot BPU Docket No. EO6100744 
 
Rate Counsel's comments filed June 22, 2006 on issues on the future of solar energy development in New Jersey. Rate Counsel's comments address four important areas (1) the current analyses conducted by Summit Blue Consulting on behalf of the Board and the Office of Clean Energy (OCE); (2) the potential market design structures for organizing the future of New Jersey's solar markets; (3) the OCE Strawman proposal submitted on May 25, 2007 and (4) our comments and thoughts on the remaining questions included in the Board's December 21, 2006 Order.


Stefanie A. Brand Comments from the Legislative Type Hearing held on Sept. 29, 2014

Final Comments filed by the Division of Rate Counsel on October 7, 2014

BPU ER14040370_BGS_Leg_Hrg_S_Brand_comments_Sept__29__2014

ER14040376 BGS_2015 Rate Counsel Final_Comments_-_Oct__7__2014

ER14040376_BGS_2015_Rate_Counsel_Cvr_Ltr_Final_Comments_10-7-14

Supplemental Comments filed by the Division of Rate Counsel on October 22, 2014

Final Supplemental Comments filed by the Division of Rate Counsel on October 29, 2014