Comment on Docket No. E022030130
on NJ BPU Rate Payer Study Presentation 3-25-22

Thank you for the opportunity to provide comments on the proposed NJ BPU rate payer study.

The NJ BPU rate payer study needs to include a study of the impact of NJ Renewable Government Energy Aggregation (RGEA) both at its current subscriber take rate, and also with the scenario of making RGEA available at a statewide level to ALL electric customers as a mandatory required offering by the NJ Basic Generation Service (BGS) entities. 

The scenarios the NJ BPU rate payer study need to consider include an offering of electricity to ALL rate payers at 100% clean electric and optionally at lower levels of clean electric such as 75%, and well above the current level of clean energy NJ currently generates (estimated at 48 to 50%, noting that this means perhaps over 50% is currently dirty NJ electric generation).  The scenarios considered should include where with due notice electric customers are gradually and automatically configured over a reasonable but short period to get clean energy, though with the provision of individual customers being able to opt out, and the opposite approach, where customers are not automatically opted in, but would receive notice such that they can decide to do so.  The NJ BPU rate payer study would consider this statewide RGEA under various pricing scenarios for the years ahead, including those scenarios listed in the 2019 NJ EMP.  Of course all statewide RGEA offerings would need to be continually and thoroughly advertised by the BGS to their customers, not hidden in NJ state government documentation.

NJ has offered the possibility of Government Energy Aggregation (GEA) with renewable content since 2003 (see  Yet, after almost 20 years, as of 2020, according to a local NJ environmental organization’s data, there are less than an estimated 15 municipalities out of 564 NJ municipalities that offer it, i.e. no more than an exceedingly small estimated 3%, with an even smaller estimated portion of NJ population and hence rate payers as no major NJ cities are known to be included.  This percentage is so low, and it has been around so long, that a casual observer can consider this program a failure, except perhaps for the relatively few participants.  Furthermore, it denies millions of NJ rate payers the opportunity to participate in such a renewable electric program, because it requires such programs to be offered only through local government or similar entities, creating a huge administrative and bureaucratic obstacle, and thus discriminates against all residents of the state which want such an offering and are denied it because of the failure of their local government entities to offer it, instead of just simply offering it to all rate payers at the state level.   For a further example of inertia, since at least 2019, a locally oriented NJ environment organization for a town with tens of thousands of NJ residents and likewise many thousands of electric rate paying households and entities, has recommended numerous times to its town government that RGEA be offered to its residents, yet no meaningful action has been taken.

Further Context:

Other comments that have been submitted to the BPU explain that it is essential to achieve drastic Green House Gas including CO2 emission reductions by reducing such emissions towards zero by 2050 so as to avoid the worst impacts of global warming.  The United States and New Jersey are NOT currently on such a path, and drastic action is immediately required without further study to achieve zero fossil fuel emissions.  100% Clean Electric needs to be obtained as soon as possible and no later than 2035.

Robert Erickson.  The author is a resident of Middletown, NJ.   The author is not associated previously or currently with any regulatory, HVAC installation, utility, power generation or transmission entity.