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 solar renewable energy certificate (“SREC”) market program since inception, including early engagement in the actual setup and implementation of the original NJ SREC program. EMA Members have worked extensively to achieve the program’s targets and continue to interface with the policy in multiple ways (e.g., as retail electricity suppliers, basic generation service providers, SREC traders, SREC brokers, SREC marketplaces, SREC aggregators, solar energy project developers, and as solar energy project investors). Accordingly, the EMA believes it is in a unique position to provide the BPU with a balanced perspective of this policy’s history and to help the BPU adopt a balanced framework that can satisfy each SREC Transition Principle.
EMA’s comments are primarily focused on the design of the solar successor program and the diverse set of options and tools available to the NJ BPU that can be used to establish an RPS budget that can accommodate the NJ Class I, NJ SREC, and the forthcoming NJ SREC II program. The EMA strongly recommends that the NJ BPU pursue a tradable NJ SREC II program that is modelled based on the existing, effective, NJ SREC program. Enclosed in this submission please find the following:
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Appendix A – Answers to NJ Solar Transition Staff Straw Proposal Questions
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Appendix B – Best Practice Principles for Renewable Energy Certificate Markets
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Appendix C – Supplemental Guidance Document
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Attachment A: Excel-based Model “NJ SREC Successor Program Model – EMA”
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