“New Jersey’s investor-owned electric, natural gas, water, wastewater, and telecommunications companies provide New Jersey residents and businesses and so many others with essential utility services that we rely on every day. It is the mandate of our members to provide safe, reliable, and reasonably priced service to all those who live, learn, and conduct business in this great state. Our members have also been tasked with meeting the requirements of the Clean Energy Act of 2018 and planning for the clean energy future envisioned in this Draft Energy Master plan. Governor Murphy has certainly set ambitious goals and New Jersey’s investor-owned utilities are not merely following a trend but have been leaders in investment in renewable energy and they are also leaders in energy efficiency initiatives.

Safe and reliable service does not happen without careful planning and prudent investments. In recent years, the utility industry as a whole has been making about $6 billion a year in capital investment in New Jersey to ensure reliability and resilience and to make infrastructure smarter. Compare that, for example, to $2 billion a year invested in transportation projects and one gets a sense of the economic magnitude of the work utilities do. Capital investments in the transmission and distribution systems are critical to ensuring utilities meet their statutory obligation and help the State achieve its policy goals.

But we need to continue investments in resilience. Nationwide, power outages from severe weather costs billions and NJUA members continue to seek BPU approval to improve and modernize electric systems and undertake natural gas replacement programs to significantly reduce emissions. And, while we’re on the subject, thank you for recognizing in the Draft EMP that natural gas contributes important reliability services to the grid and that the transition from other fuel sources to cleaner burning natural gas has led to lower emissions while also lowering our electric bills. As we deploy more renewables, we must recognize that natural gas and renewables are NOT mutually exclusive as natural gas is a necessary compliment to intermittent renewable energy sources. And so, notwithstanding some of the hyperbole we have heard –our statutory mandate provides that we cannot put a moratorium on heating our homes in the winter, on safety, or on reasonably priced electric generation.

I urge the BPU to recognize the need for incentives – the Infrastructure Improvement Plan is an excellent step forward. Yet, at the core of our ratemaking – a system that ties revenue to kilowatt hours or therms sold – there remains an inherent disincentive to deployment of distributed energy resources, renewables, and energy efficiency programs. And so, we encourage continued exploration of alternative models for revenue recovery.

Utilities will play a critical role in deployment of compressed natural gas vehicles and charging infrastructure for electric vehicles. If range anxiety is our biggest impediment to broad based deployment and if we are serious about our commitment of getting 330,000 light duty electric vehicles on New Jersey roads by 2024 then it stands to reason we should leave all charging infrastructure options on the table. We support Advanced Metering Infrastructure that will be an important tool for things like electric vehicle charging, renewables, and energy efficiency but we need the right support to make that investment.

As the BPU seeks to explore its authority with respect to electric transmission project approvals, we emphasize that the electric utilities must have the flexibility to undertake projects needed to ensure the integrity of the grid and to modernize the grid for integration of distributed energy resources and renewables, and they have an obligation to adhere to federal directives.

Finally – utilities provide essential services, they are community partners, taxpayers, and residents. They are invested in New Jersey’s future and will continue to play a critical role in ensuring that future includes safe, reliable, and affordable utility service that is the backbone of our economy and enables our high quality of life in New Jersey.”