New Jersey Staff Seeks Comment on Removing RPS Obligation from Default Service, Retail Suppliers

Staff of the New Jersey BPU have issued for comment a series of questions relating to the potential removal of the RPS requirement from the BGS procurement process, and also asked about transferring the RPS obligation of retail suppliers to the electric distribution companies.

Since initiating such a review in 2012, Staff noted that, "there have been a number of developments within the renewable energy sector such as the Solar Act of 2012, the dramatic decrease in the cost of Solar Renewable Energy Credits ('SRECs') and an excess of SRECs being produced, all of which have had an impact on the renewable energy markets and the cost of compliance of the RPS in New Jersey."

"In an effort to better understand the developments within the renewable energy sector in New Jersey before Staff makes a final recommendation regarding the RPS requirement as it relates to the BGS procurement process," Staff issued a series of questions for stakeholder comment.

Among other things, Staff sought comment on:

• Would transferring the RPS responsibility from BGS suppliers back to the EDCs affect the competitive electric energy retail choice market in New Jersey?

• Are there legal, regulatory or other impediments to transferring RPS responsibility for Third Party Suppliers' load to the EDCs? Please explain.

• Describe the potential benefits and/or risks of removing the RPS obligation from the BGS full requirement product.

• Is the price transparency created by the separation of the RPS from the BGS procurement process still needed now that (a) the SACP has been reduced drastically, and (b) the market prices for SRECs are much lower than the SACP?

• To what extent have BGS suppliers contracted for RECs on a long-term basis?

• Are there legal, regulatory or other impediments to transferring RPS responsibility for BGS load to New Jersey's Electric Distribution Companies (EDCs)? Please address any issues relating to mandatory terms for contracts, cost recovery, the prudency of an EDC's actions in meeting the RPS obligations in a process separate from the BGS procurement, including the possibility for over- or under-procurement and the costs?

Docket No. ER13090861