State of New Jersey
Board of Public Utilities
44 South Clinton Ave, 3rdFloor, suite 314
P.O. Box 350
Trenton, New Jersey 08625-0350


Dear Secretary Camacho-Welch:

Jersey Renews is pleased to submit these comments on behalf of its member organizations and the undersigned to the Board of Public Utilities (“BPU”) in the above reference proceeding.



Norah Langweiler, Jersey Renews

Debra Coyle McFadden, New Jersey Work Environment Council

Liz Cohen, Reform Jewish Voice of New Jersey

David Hughes, Rutgers American Association of University Professor -American Federation of Teachers

Ray Greaves, Amalgamated Transit Union New Jersey State Council

David Weiner, Communications Workers of America Local 1081

Carol Gay, New Jersey State Industrial Union Council

Walt McRee, Banking on New Jersey

Nancy Griffeth, Unitarian Universalists Faith Action

Lynn Perry, Care of Creation Task Group, New Jersey Synod of the Evangelical Lutheran Church in America

Richard Lawton, New Jersey Sustainable Business

Michael Rollins, New Jersey Education Association

Imam Saffet A. Catovic, Green Muslims of New Jersey

Barbara Rosen, Health Professionals and Allied Employees

Peter Rose, Isles, Inc.



Energy efficiency jobs are directly tied to strong energy efficiency policies. Over the last decade, New Jersey has dropped 10 spots in the American Council for an Energy-Efficient Economy’s (ACEEE) energy efficiency scorecard. Nearby states like Pennsylvania, Massachusetts, and New York have increased investment in energy efficiency which has resulted in job growth to 65,000, 85,000, and 110,000 respectively. In designing its program, NJ should adopt and improve the best practices from other states to regain its position as a national leader in energy efficiency and provide the backbone for its clean energy economy.

Traditional utility ratemaking models reward utilities for selling more electricity which is poorly suited to accommodate an energy efficient, clean energy economy wherein customers use less energy overall. New Jersey should require a 30% reduction of 2015 levels for electric and natural gas usage by 2030 with clear, measurable interim benchmarks.

New Jersey should support policies and measures that expand the use of industrial energy efficiency technologies that will serve to reduce greenhouse gas emissions, maximize efficiency in some of the most energy-intensive facilities, reduce waste, and help industrial facilities be more competitive nationally and globally.

The new programs established under the Clean Energy Act must create a partnership between utilities and customers to remove barriers to energy efficiency interventions, provide incentives for performance that go beyond mandates, and achieve robust energy efficiency savings. Access to energy data is the foundation for any real building efficiency progress. Residents and building owners need simple access to understandable and reliable energy information. The NJBPU should give building owners and managers electronic access to monthly, whole-building aggregated energy consumption data with reasonable confidentiality protections for tenants.

Stakeholders must have an active role in the design phase of the program through public hearings and opportunities for discussion between stakeholders. The state should convene an energy efficiency task force made of building industry professionals and stakeholders to chart a comprehensive and long-term path to reducing pollution in the building sector. Once a program has been established, key stakeholders should convene an advisory council on a regular basis to review program metrics and make recommendations for improvement.

High-performance green building standards in new and existing state construction ensure that the state leads by example. New Jersey should improve green building standards by examining and updating building envelope and efficiency codes. The state should provide funding to qualified labor-management training providers to train employees in operations and maintenance to optimize building performance including the implementation of green cleaning and renewable energy measures in public and commercial buildings, particularly schools. New Jersey should offer free benchmarking for hospitals, municipalities, public schools, universities, multifamily units, retail, and other sectors which allows for greater insights into the benefits of energy efficiency.

Finally, New Jersey needs to invest in building performance departments. Local building departments must be given the tools and resources they need to implement New Jersey’s building energy standards. Current policy rewards the exceeding of mandatory code, but does not address the larger problems of overall compliance and older buildings that lag far behind current standards. To achieve state goals for efficiency and energy independence the state must prioritize strong compliance for all buildings with the state’s energy code and consider incentivizing up-to-code improvements for buildings designed and built to lower standards.

Energy efficiency is the lowest cost energy-saving tactic for New Jersey residents and businesses that saves money on energy bills and decreases greenhouse gas emissions. Across the country cost-effective investments in EE are consistently shown to lower energy costs for customers who participate in EE programs and decrease utility costs for all ratepayers. Increasing energy efficiency also lowers greenhouse gas emissions and, along with investments in clean energy, can improve grid resilience.