On behalf of the 20,000 members of the New Jersey Business & Industry Association (NJBIA), I ask you to oppose S-3059 (Sweeney, Smith) which requires the State’s full participation in Regional Greenhouse Gas Initiative (RGGI).
NJBIA has been involved with the policy discussions surrounding RGGI since 2003, when it was proposed to be an innovative pilot to reduce carbon. At that time concerns over leakage from Pennsylvania and Ohio as well as dispatch penalties for our cleaner power plants with higher compliance costs were of concern and not able to be addressed by RGGI. New Jersey’s participation resulted in higher electric costs and funds from the RGGI auction were diverted to the general fund instead of being used for energy efficiency purposes. New Jersey generators were complying with stricter standards and compliance costs which allowed for dirtier generation to dispatch at lower rates.
Today, there is good news about the state not participating in RGGI. New Jersey has a robust electric generation sector that is among the cleanest in the nation. We are by far the cleanest within PJM and our state is making significant contributions to improved air quality and reduced CO2 as a result. New Jersey’s electric generation plants are tied for 2nd in the nation for lowest SO2 Emission rates,10th for lowest CO2 emission rates, and tied for 1st for lowest NOx emission rates. Not one other state within PJM is lower than New Jersey! The more clean energy generated in New Jersey, the better for our air quality and the region’s air quality. We don’t need to rejoin RGGI, we are already leading without additional costs to our power sector.
New Jersey is helping lower PJM CO2 emissions by building new base load natural gas combined cycle plants in our state. For every ton of CO2 emitted by a new NGCC plant, between 2.5 and 3 tons of CO2 emissions are avoided from old coal fired power plants in PJM. These new plants also reduce the loss of energy through long distance high voltage transmission lines resulting in additional CO2 savings. Rejoining RGGI could potentially impact the development and operation of these cleaner NGCC plants and cause PJM to dispatch dirtier baseload options.
The majority of PJM states are to New Jersey’s west. Joining a program that does not include these states is bad for New Jersey. The potentially increased air pollution produced in Pennsylvania and Ohio, blows west to New Jersey. This exacerbates our ozone and other air pollutants as well. Therefore it is in our best interest to have New Jersey’s cleaner plants running, instead of other plants in the grid, and lower emissions produced.
New Jersey does not need RGGI. We are a leader in our own right in curbing emissions and producing clean power. Do not penalize our generation sector for their good work by adding additional compliance costs. Instead, work with PJM states to improve energy efficiency, emissions and fuel diversity that lead to a healthier air quality.
Chart 1a: Sulfur Dioxide (SO2) Emission Rate – All Electric Power Generation Plants, 2015
Chart 1b: Nitrogen Oxides (NOx) Emission Rate – All Electric Power Generation Plants, 2015
Chart 1c: Carbon Dioxide (CO2) Emission Rate – All Electric Power Generation Plants, 2015
Chart 3: Carbon Dioxide (CO2) Emission Rate – All electric power generation plants (PJM States)