Mr. Mark Friedrich, PI-40 February 17, 2004

Office of Policy and International Affairs

US Department of Energy

Room IE 190

100 Independence Avenue SW

Washington DC 20585

Re: Comments on the Proposed 1605 (b) General Guidelines for Voluntary
Greenhouse Gas Reporting -- Climate Change Part 300

Dear Mr. Friedrich:

The New Jersey Board of Public Utilities (NJBPU) appreciates the
opportunity to submit comments on the above referenced General
Guidelines. One of the goals of the NJBPU Strategic Plan is to reduce
the use of energy demand, while enhancing the quality of life for the
citizens of New Jersey, by promoting and advancing the use of energy
efficiency and renewable energy. Developing and implementing this goal
will aid in reducing New Jersey's greenhouse gas emissions.

NJBPU administers the New Jersey Clean Energy Program. The Clean Energy
Program provides incentives, grants, rebates and financing for energy
efficiency and renewable energy projects in New Jersey. The New Jersey
Clean Energy Program is funded through a systems benefits charge on
natural gas and electricity customers in New Jersey. The goal of the
program is to lower the demand for overall energy use, while providing
sufficient and reliable clean energy to our residents and businesses.
The objectives of the program are to lower the life cycle costs of
energy use and its associated environmental impacts including greenhouse
gas reductions for our residents and businesses. A copy of the 2002
Annual Report is enclosed. As you will note in the Report this program
significantly aids in reducing New Jersey's greenhouse gas emissions in
a cost effective manner.

Through the Clean Energy Program, the NJBPU also manages the New Jersey
Renewable Portfolio Standards (RPS) regulations and is developing a
Solar Renewable Energy Certificate (SREC) program in New Jersey. New
Jersey has set a solar RPS for 90 MW, a total RPS at 6.5% by 2008 and a
20% target by 2020.

An improved and robust national greenhouse gas reporting system will
help to support the New Jersey Clean Energy Program goals and objectives
and the clean energy efforts of other states. We also believe that an
improved and robust national greenhouse reporting system will support
and compliment the efforts to reduce, register and report greenhouse
emissions currently being developed and implemented by the states. We
hope that the USDOE will continue to request comments and continually
improve the validity of the system. The proposed guidelines are a step
in that process of continual improvement to develop a robust and valid
national reporting system.

The comments submitted by NJBPU are intended to assist in that continual
process.

1.  Guidelines for Small Emitter - Aggregation

Small entities should be allowed to report through an aggregator. This
would allow for an efficient consolidation of smaller reporters such as
households or small business, well below the 10,000-ton level that would
not seek to participate in the reporting system. However, this system
would need to be transparent and the aggregatee would need to clearly
assign the reductions to the aggregator. The transaction to aggregate
smaller sources should be transparent and the trail of assignment should
be clear.

Likewise a trade association that aggregates for an industry should not
be permitted to report average or consolidated reporting without clearly
delineating the individual industry verified reporting and
certification. Without clear and transparent reporting the system cannot
be relied on for accuracy and validity.

2.  Indirect Emissions

    a.  On-site renewable energy -- net metering

Protocols should be developed for the reporting of on-site renewable
energy or other clean generation that is net metered into the local
distribution system. This would be similar to the method used in
electricity metering configuration for cogeneration and waste heat
recovery. This protocol should also recognize the generation of
renewable energy credits. The ownership of the renewable energy credits
should be the generator, the household or business that installed the
renewable energy or clean energy generation technology. As stated above
these small sources should be allowed to report through an aggregator
that is assigned the credits or reductions.

b.  Selection of Clean or Green Power purchases

A protocol should be developed that recognizes that in a deregulated
market an entity has a choice in the selection of their energy supplier.
If that choice results in increased emissions for indirect electricity
use the increased emissions should be netted against the entity's
reporting. If that choice results in decreased emissions for indirect
electricity use, the decreased emissions should be credited to the
reporting entity.

3.  Calculating emissions reduction with electricity generation and use
    -- Calculating emission reductions

The Ozone Transport Commission (OTC) report [Predicting Avoided
Emissions from Policies that Encourage Energy Efficiency and Clean
Power]{.underline}, prepared by Synapse Energy Economics dated June 24
2002 and the accompanying technical worksheets entitled, [The OTC
Emission Reduction Workbook 2.1 Description and User's
Manual]{.underline} dated October 15, 2002 does a better job of
reporting emissions reductions than the current methodology listed in
the general guidelines, technical guidelines and Instructions for Form
EIA 1605 (VRGG). This is especially true for states like New Jersey that
buy and use electricity, from an ISO with multiple states, such a PJM.

The electricity generation factors listed in the Instruction for Form
EIA 1605 (Instructions) for New Jersey represents only the in-state
electricity generation factor. Given the state's actions to reduce
emissions, New Jersey's instate electricity generation factor is
relatively cleaner compared to most states. Given that New Jersey buys
and uses electricity from multiple states in the PJM, the electricity
generation factor for electricity use should be representative of this
fact. The electricity generation factor listed in the Instructions
vastly misrepresents the GHG reduction for indirect measures implemented
in New Jersey. The OTC method more accurately reflects the fact that
emission reductions occur across the PJM and not just New Jersey.
Further, the OTC method more accurately reflects time of day (day vs.
night), time day year (summer vs. winter) and peak or off peak usage of
electricity. The OTC uses an economic dispatch model to match emissions
with base-load generation at the time of use.

While the OTC method needs refinement, it is substantially better than
the current average statewide electricity generation factors listed in
the Instructions. The OTC method accounts for changes in the marginal
emission rate, as changes in the base-load generation occurs at the time
of the indirect activity. The OTC method matches more accurately the
protocols used to calculate the energy savings from energy efficiency
and renewable energy activities.

4.  Entity wide Reporting -- Absolute v. Intensity

In terms of whether an entity or corporation should report, we recommend
you contract the New Jersey Higher Education Partnership for
Sustainability (NJHEPS) for examples of how large disaggregated sources
can be consolidated into an efficient reporting mechanism using an
output based matrix. NJHEPS represents the New Jersey Colleges and
Universities in the development of a sustainable energy plan and GHG
reporting for their campuses. NJHEPS can be contacted at the following
address:

NJHEPS

c/o York Center for Environmental Engineering and Science

New Jersey Institute of Technology

148 Warren Street, University Heights

Newark, New Jersey 07102-9895

\(973\) 642-4881; <njheps@njheps.org>

The 55 New Jersey Universities and Colleges have signed an agreement to
assist New Jersey in meeting its statewide GHG reduction goal. Part of
this commitment is annual reporting from the Colleges and Universities.
Last year, with 17 Colleges and Universities reporting representing 45%
of New Jersey college students, NJHEPS reported a 14 percent increase in
staff and students and a 17 percent increase in conditioned floor space
between 1990 and 2000, with a near zero increase in energy use and
associated GHG emissions for this period. This occurred despite a
significant increase in electrical equipment (computers, TV, stereo and
microwave) usage on campus between 1990 and 2000.

The NJHEPS report is provided on an energy per square foot basis and a
GHG emission per square foot. We understand NJHEPS is now up to 70
percent of the members reporting on an annual basis.

NJBPU supports the use of an absolute reporting mechanism on a corporate
wide basis as a more accurate and transparent method of reporting GHG
reductions, we are providing this information as an example of an output
method, that along with absolute tonnage reporting, provides for a
fuller picture of energy use and GHG emissions.

5.  Linking of like Federal Reporting Systems

We recommend that USDOE link with other federal agencies such as USEPA
Energy Star Program to link similar reporting mechanisms for energy
efficiency that result in GHG reductions. This would save users of both
systems time in filing the same report with the same data and the same
GHG reductions.

NJBPU supports the activities being implemented by the Northeast states
in the Regional Greenhouse Gas Initiative and recommends that the USDOE
coordinate its activities with this interstate group to develop a robust
national reporting and registry system.

Very Truly Yours

Jeanne M. Fox

President

cc: Lance Miller Chief of Staff, NJBPU

Michael Winka Director Office of Clean Energy