Thank you for the opportunity to submit comments on the RGGI Strategic Funding: Years 2026-2028.
Regional Plan Association (RPA) is an independent, non-profit regional planning organization that works to improve the prosperity, infrastructure, sustainability and quality of life of the New York-New Jersey-Connecticut metropolitan region. Since 1929, RPA has produced four comprehensive long-term plans to direct the growth, development, and sustainability of our region. The ideas and recommendations from these plans have shaped the region’s infrastructure, open spaces, and economic development projects for the past century.
Initiative One: Catalyze Clean, Equitable Transportation
Building on this legacy, RPA urges the NJEDA, NJBPU and NJDEP to improve current funding proposals for RGGI Initiative One: “Catalyze Clean, Equitable Transportation” to maximize their potential to advance equity across the state.
In 2022, transportation accounted for 36% of New Jersey’s greenhouse gas emissions, and although passenger cars contributed the greatest volume of emissions, medium and heavy-duty vehicles (MHDV) emissions caused disproportionate harm to overburdened communities. These communities are suffering from health disparities, such as high rates of asthma, resulting from the concentration of emissions from buses, delivery trucks, and off-road equipment. RGGI funding should primarily support the reduction of emissions from MHDV for New Jersey’s overburdened communities.
RPA supports NJBPU, NJEDA, and NJDEP’s continued support of electrification of MHDV and NJBPU’s funding of upgrades to electric vehicle infrastructure to accommodate future demand, however, current proposals should go further to reduce emissions from MHDV and set specific goals around electrification for MHDV fleets:
RGGI proposals should be concentrated on funding programs which have proven successful at increasing MHDV adoption, such as NJ ZIP and NJ ZEV, which cannot currently accept all applicants.
The scale of RGGI funding requires prioritizing high impact strategies, and RPA believes proposals such as supporting workplace charging infrastructure should be reevaluated in terms of their scale of impact on addressing urgent community needs compared to MHDV projects.
There is uneven distribution and access of MHDV market availability, which creates barriers to fleet conversion and adoption. Initiative One proposals should both address barriers to MHDV EV adoption and provide support for technical assistance to encourage more fleets to take advantage of existing incentives and financing programs.
NJBPU, NJEDA, and NJDEP should update the current RGGI Priority Ranking System to ensure greater transparency and responsiveness to community needs. This additional transparency in the ranking process would provide more clarity on the connection between project applicants and RGGI goals.
Initiative Two: Accelerate Healthy Homes and Building Decarbonization
Funds going towards building decarbonization should focus on providing incentives that promote long-term cost savings, like helping multifamily homes or low-income households purchase heat pumps or other efficient heating and cooling equipment. This proposed program should help multifamily homes (specifically ones that meet certain income thresholds) not only purchase updated technology like a heat pump but also assist them by retrofitting their buildings to support that technology.
Additionally, one potential use of funding describes “encouraging” zero-energy new construction. Simply “encouraging” is too vague of an action, and not bold enough. The state needs to use the remaining RGGI funds on real, tangible outcomes. There needs to be measures of success that go along with the funding, and the measures of success for “encouraging” look a lot different from a concrete program.
Potential initiatives include:
Provide incentives through NJ HFA to figure out how to do all-electric new affordable housing construction and work with them to update their internal performance standards to effectively require all-electric whenever it makes economic sense.
Provide funding for analysis of EDA-supported economic development projects to identify waste heat that can be captured cost-effectively and support electrification of nearby multi-family housing.
Initiative Six: Supplement Ratepayer Relief
Using RGGI funds for ratepayer relief is a bandaid solution that does not net long-term benefits. This is the least impactful initiative that can address energy affordability in New Jersey. Ratepayer relief may give short term benefits, but when that relief funding runs out ratepayers are still stuck paying higher electricity rates without addressing the systemic issues that caused those high rates in the first place. Short-term ratepayer relief can still be done by the state, but it should not be taken from a fund intended to reduce greenhouse gas emissions. Blanket ratepayer relief without addressing the key issues as to why rates went up simply encourages a continuation of the same structure as before - using expensive, unreliable, and aging fossil fuel infrastructure. If the funds must be used for ratepayer relief, we then encourage those funds to be used for those experiencing the most hardship - identify communities where ratepayer relief would be most impactful, and use the remaining funds for projects that would improve long term reliability.
Beyond helping those that need it most, we recommend this money be used to directly address some of the issues causing high electricity rates in New Jersey, through pathways identified in initiative seven.. That includes:
Funding transmission and distribution network upgrades: Our energy system is still outdated despite several years of ongoing work post-Superstorm Sandy. Using this money to fund additional infrastructure upgrades will be beneficial long-term to energy bills. Energy infrastructure projects are typically paid for by ratepayers on their bills, so this would provide much needed upgrades without having the ratepayers foot the bill. This also directly reduces emissions through upgraded grid efficiency - upgraded energy infrastructure can reduce the actual amount of power needed to flow through the power lines due to decreased losses from transmission.
Funding Energy Storage: Energy storage is a critical, dispatchable energy solution that is necessary for the grid of the future and reduces energy costs. This money can be used to supplement the Garden State Energy Storage initiative, increasing the initiative’s megawatt goal. Energy storage replaces the traditional peaker plant with emission free dispatchable energy and can be charged with fuel-free energy systems such as solar and wind.
Funding community solar and residential solar: More in-state generation is needed to combat rising energy costs. New Jersey is fairly geographically constrained, so community solar and residential solar are particularly important for boosting in state generation, particularly with the future of offshore wind being uncertain. As a fuel-free energy, they are not subject to fluctuating costs, and provide long term rate relief. Community solar and residential solar insulates NJ residents from rising rates by allowing them to generate their own electricity and not have to rely on the larger PJM system. With federal tax incentives ending soon for residential solar, these funds could be used to fill the gap in the near future.
Initiative Seven: Expand Clean Energy Generation, Transmission, Storage, and Grid Resilience
Clean energy generation, transmission, storage, and grid resilience are not only necessary to combat climate change and protect our grid from extreme weather events, but are critical to reducing long-term electricity costs. Building new renewable generation paired with storage in-state will better insulate the state from PJM price fluctuations and the volatile energy commodity market. The state should continue to invest in solar and storage, and upgrade the state’s transmission system to be offshore wind ready once the federal fog of uncertainty is lifted.
Our energy system is still outdated despite several years of ongoing work post-Superstorm Sandy. Using this money to fund additional infrastructure upgrades will be beneficial long-term to energy bills. Energy infrastructure projects are typically paid for by ratepayers on their bills, so this would provide much needed upgrades without having the ratepayers foot the bill. This also directly reduces emissions through upgraded grid efficiency - upgraded energy infrastructure can reduce the actual amount of power needed to flow through the power lines due to decreased losses from transmission.
Conclusion
As RGGI’s time is nearing its end due to the success of the program, we implore the state to use this finite source of funding wisely and boldly. The state should focus on making the most significant long-term impact by using the existing funds to promote programs that reduce emissions and electricity rates in the long-term. RGGI’s large scope is commendable but there is value in focusing the already spread-out dollars into a handful of directions that would have the most impact. RGGI Initiatives One, Two, and Seven are the types of bold, impactful programs that need to be prioritized. Initiative One is able to reduce local carbon emissions in underserved communities if strategies to reduce emissions from medium and heavy-duty vehicles are prioritized, rather than general EV adoption. Funds from Initiative Two should go towards building decarbonization programs that focus on providing incentives that promote long-term cost savings, like helping multifamily homes or low-income households purchase heat pumps or other efficient heating and cooling equipment. Initiative Six funding should be diverted towards Initiative Seven because clean energy generation, transmission, storage, and grid resilience are not only necessary to combat climate change and protect our grid from extreme weather events, but are critical to reducing long-term electricity costs. While ratepayer relief is important, this type of direct ratepayer relief provides no long-term benefit.
Short-term solutions will not be able to provide the solutions that we need to see in New Jersey. RGGI’s impact and legacy should be focused on strategies that invest in energy infrastructure that will sustainably drive down costs and prioritize programs that will improve the lives of the most vulnerable in our underserved communities.
