Policy Integrity Comments to New Jersey on Cost Test Straw Proposal

The New Jersey Board of Public Utilities (BPU) asked for comments on its straw proposal for the benefit-cost test that BPU would employ pursuant to the 2018 Clean Energy Act, which requires energy efficiency and peak demand reduction programs to satisfy a benefit-cost test. Policy Integrity’s comments encourage BPU to include avoided greenhouse gas emissions among the non-energy benefits it credits to energy efficiency and peak demand reduction projects. The comments also suggest that BPU adopt a tool and methodology for assessing the benefit of avoided local air pollutants that is more sensitive than those identified in the proposal.

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