Comments on New Jersey Board of Public Utilities’ Virtual Power Plant Straw Proposal

Clean Energy Group (CEG) submitted comments to the New Jersey Board of Public Utilities (NJ BPU) in response to their request for comments on their Virtual Power Plant Straw Proposal under Docket No. QO26030099. CEG congratulates NJ BPU on its thorough and well-thought-out VPP program proposal. CEG then lays out recommendations regarding many facets of the program, including equity, compensation structure, program coordination, locational benefits, cost-effectiveness testing and interim program evaluation, the Proactive System Upgrade Plan, technology neutrality, open-access market rules, EDC ownership/administration of DERs, small storage procurement and energy efficiency program overlap, and program reporting and accountability. CEG also directs NJ BPU to CESA’s Program Design for Battery-Based Virtual Power Plants issue brief.