BOARD OF PUBLIC UTILITIES

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Posted By	Posted Date	Comments	Attachments(s)
Erik T. Hartten	5/10/2024 5:49:40 PM	To whom it may concern, As you design New Jersey's own adaptation of the HEAR program, as implemented through the Comfort Partners Program, please ensure that its funding also benefits the growing number of low/fixed-income households owned by senior citizens, many of whom are struggling to stay in the state due to burden of high property taxes, the difficulty of accessing traditional home equity loan financing, the complexity of navigating the ever-changing landscape of existing incentive programs and those who may not have participated yet in the Comfort Partners Program. Many of these long-time residents enthusiastically support the state's emissions reduction policies, would love to live out the rest of their years in the state, and would relish the opportunity to electrify the space heating and domestic hot water systems in their homes were it not for the simple fact that they lack the financial means to do so without substantial public assistance. Thank you very much for your time and consideration! Erik T. Hartten
Tom Handza	2/15/2024 3:54:48 PM	2nd attempt to attached file of gas vs heat pump calculations. 2/15/24 During the December technology webinar one person asked a question about heat pumps being more expensive to operate than natural gas heaters. Attached is an excel file that shows my calculations for the performance of a heat pump I purchased January 2022. Even at 47 deg F my heat pump at $0.20/kWh costs 29% more to operate than a 96% efficient gas heater. It requires a COP of 3.75 to break even with natural gas. My solar panels makes the heat pump cost effective for me. Should we have incentives for heat pumps when they are not cost effective compared with gas heater? Should we bundle the incentives with solar panels to get middle and high income people to consider fuel switching? Low to middle income people need to weatherize their homes first. But when their heater stops working it needs to be replaced within a few days. How do you make the heat pump the lowest cost option? If you do then is there a program to help cover the higher operating cost? What is being done to lower the cost of electricity from $0.20/kW close to the national average of around $0.15/kW? Can you lower the delivery cost of $0.0936kW and Transmission cost $0.0323/kW. Have you developed a road map for a cost effective way to electrify homes. I have spent about $40,000 (after ITC) to electrify my home. Solar panels, heat pump, heat pump HWH, electric dryer, Induction stove. I have reduced my gas usage by 90%. Between $2,000/yr savings on electric and gas bills and Solar renewable energy credits my payout is about 9 years. That's not good enough to get the majority of the middle to high income people to pay extra for these appliances. My conclusion is reducing the electric rates may be the best way to encourage people to switch from gas to electric heat. Community and utility solar may be the most cost effective approach. Regards, Tom Handza.	Gas vs Heat pump calculations 2024-01-10
K Frost	1/12/2024 4:59:26 PM	Please see attached comment	2024-01-11 KF Comment-QO23100733
Tom Handza	1/12/2024 4:51:01 PM	During the December technology webinar one person asked a question about heat pumps being more expensive to operate than natural gas heaters. Attached is an excel file that shows my calculations for the performance of a heat pump I purchased January 2022. Even at 47 deg F my heat pump at $0.20/kWh costs 29% more to operate than a 96% efficient gas heater. It requires a COP of 3.75 to break even with natural gas. My solar panels makes the heat pump cost effective for me. Should we have incentives for heat pumps when they are not cost effective compared with gas heater? Should we bundle the incentives with solar panels to get middle and high income people to consider fuel switching? Low to middle income people need to weatherize their homes first. But when their heater stops working it needs to be replaced within a few days. How do you make the heat pump the lowest cost option? If you do then is there a program to help cover the higher operating cost? What is being done to lower the cost of electricity from $0.20/kW close to the national average of around $0.15/kW? Can you lower the delivery cost of $0.0936kW and Transmission cost $0.0323/kW. Have you developed a road map for a cost effective way to electrify homes. I have spent about $40,000 (after ITC) to electrify my home. Solar panels, heat pump, heat pump HWH, electric dryer, Induction stove. I have reduced my gas usage by 90%. Between $2,000/yr savings on electric and gas bills and Solar renewable energy credits my payout is about 9 years. That's not good enough to get the majority of the middle to high income people to pay extra for these appliances. My conclusion is reducing the electric rates may be the best way to encourage people to switch from gas to electric heat. Community and utility solar may be the most cost effective approach. Regards, Tom Handa	Gas vs Heat pump calculations 2024-01-10
Doug Presley	1/12/2024 4:49:54 PM	Please see attached comments from the Building Performance Association.	01-12-2024 - Building Performance Association HOMES_HEEHR TREC Comments
whit faulconer	1/12/2024 4:22:13 PM	Please find our responses attached. Thank you.	NJ Public Comment 1.12.24
Steven Miller	1/12/2024 3:46:52 PM	For two years, I have hosted a monthly Building Decarbonization webinar with HVAC vendors and consumers and heard much. In addition, my family has just completed a 12 month cycle of HPwES audit and weatherization, with delays in all phases. Given that energy audit and weatherization are expected first, and only then are heat pumps sized properly, I recommend: 1. AUDITS AND WEATHERIZATION • Deployment of the audit training immediately when the grant is received (grant application was announced during the Dec Technical webinar). The goal: quickly shorten the current LONG waits for audit. • DECOUPLE an audit from the recommended weatherization work. The BPU should require vendors to break up the complex audit report into separable portions that are rank-ordered by impact on home energy efficiency. Make it convenient for homeowners, and encourage homeowners to seek multiple bids from qualified contractors on highest impact portion of the audit report. • Deploy weatherization funds to quickly train new contractors in order to shorten the current LONG waits for weatherization. • Work with manufacturers and professional associations to initiate a publicly available customer rating/feedback for each of the current qualified contractors. • Immediately start planning to define NJ audit/weatherization rebates in connection with the currently received (Dec 2023) 2nd triennium decarbonization & weatherization proposals from each utility. The goal: stacked weatherization/remediation rebates goal on 1/1/2025 is near 100% payback for LMI families. 2. HVAC SALES AND SERVICE PROVIDERS: • Ensure funds for HVAC training programs to teach current deployment practices for the rapidly changing technology of cold climate heat pumps and their integrated control system. This includes training in the rapid transition in 1/1/2025 to new low climate warming refrigerants and disposal of old refrigerants. (see need for independent training center- • Work with NJ ACCA (Air Conditioning Contractors of America), or other professional organizations to develop qualified lists of the most experienced and trained heat pump sales and service providers (esp those who most often receive positive referrals) • Ensure that the qualified list of heat pump vendors is fully educated and motivated about the decarbonization advantage of cold climate heat pumps, and appropriately trained to avoid using traditional gas furnaces as backup heating, unless a rare exception. • Co-develop programs to ensure HVAC vendor proposals to customers ALWAYS provides a decarbonization message. For example: option 1 installed price is $,and will save $x operating costs and save x tons of GHG; option 2 installed price is $, and will save $y operating costs, and save y tons of GHG,.. 3. ESTABLISH AN OUTREACH AND EDUCATION PROGRAM • An independent Building Electrification Technical Resource Center (Rutgers Center for Green Building and partnerships with NJIT Building Learning Center and Rowan GIS mapping center) is fundamental to most quickly and widely deploy the knowledge and provide the skill training requirements of latest technology heat pumps to meet the Governor EO316 goals; electrification of 400,000 additional residential homes, 20,000 additional commercial buildings plus an additional 10% of low income residential units.
David Kolata	1/12/2024 3:00:43 PM	Attached, please find the comments from Sealed. We appreciate the oppportunity!	Sealed NJ IRA Comments (2)
Ryan Kristoff	1/12/2024 2:23:15 PM	See attached	ICAST NJ Rebate Program Response
John Kolesnik	1/12/2024 1:40:43 PM	EEA-NJ Comments on HOMES/HEEHR Technical conference 01.12.2023	EEA-NJ Comments on HOMES_HEEHR Technical conference 01.12.2023
Jeaneen Zappa	1/12/2024 1:37:49 PM	Coalition Comments Coalition Comments on HOMES_HEEHR 01.12.2023	Coalition Comments on HOMES_HEEHR 01.12.2023
Carolyn Sloan	1/12/2024 1:35:15 PM	Enclosed please find Oracle Opower's comments on the implementation of the HOMES and HEEHR programs in Docket No. QO23100733	Oracle Opower NJ BPU HOMES and HEEHR Comments 1.12.23
Carmen Best	1/12/2024 1:33:35 PM	Please see Recurve's comments on Implementation of Federal IRA HOMES and HEEHR Programs	Recurve's Comments on NJBPU's RFI on IRA Home Energy Rebates (Docket#_ QO23100733)
Prerna Tomar	1/12/2024 1:31:08 PM	Please see the attached comments on the IRA Rebate Programs from Samsung Electronics America.	01112024 - Samsung Comments on NJ Request for Public Input - IRA Home Rebates - FINAL
Michael Winka	1/12/2024 12:26:22 PM	Comments IMO the Implementation of the IRA HOMES and HEEHR Programs	Comments from MW on BPU TC for the HOMES and HEERH programs 1-12-24
Noreen Giblin	1/11/2024 4:09:18 PM	Public Service Electric and Gas Company respectfully submits the attached comments in response to the Board of Public Utilities’ December 13, 2023 Technical Conference.	PSE&G - IRA Technical Conference Comments
Anne Arquit Niederberger	1/11/2024 12:29:11 PM	See attached Enervee comments	Comments on NJ BPU IRA HEAR Program – Enervee
Audrey Winzinger	1/6/2024 11:10:47 PM	The existing energy efficiency programs consistently have a hole in them that needs to be filled. There are programs offered that serve residential homeowners, owners of large commercial properties and landlords of multi-tenant properties; but, landlords who own one or multiple free standing single residential rental properties and who wish to upgrade the HVAC in their properties are left with no energy efficiency programs that make the upgrades financially feasible. There are thousands of landlords in New Jersey; and, I believe a high percentage of them own single (not multi-tenant) free standing properties as do we. In our case we own 22 single family homes that we have converted to apartments upstairs and commercial units downstairs. Like many other landlords we would like to upgrade our existing leased properties (many of which are leased to low or mod tenants) to energy efficient HVAC. The problem is, converting 22 residential rental units to high efficiency HVAC (likely also converting from gas furnaces to all electric mini splits) is cost prohibitive without a program that would either provide some grant cost savings or at least provide for OBR or both. As an example of the hole that consistently exists eliminating a huge category of New Jersey's residential rental units sorely in need of energy efficiency upgrades, when PSE&G was petitioned to find a path to a program for these properties the response was not a grant program or even one providing a financing program or OBR what was provided was one undesirable remedy. That remedy was to add a meter to each of these single buildings, followed by using that meter number to create a PSE&G account, at which time we could use the new account to accommodate an OBR. Our properties have an apartment upstairs that has a meter and its own PSE&G account. Our properties have a commercial tenant downstairs that has a meter and its own PSE&G account. In the recommended scenario we would spend the 6-12 months it would take to get a meter (if PSE&G will even install a meter for absolutely no use); and, then we would use that meter number to create an account which would be used to “house” the OBR for the HVAC installation. This really isn’t a realistic business remedy to reach the energy efficiency HVAC conversion. We requested a better path to paying the OBRs associated with the installation of HVAC upgrades/energy efficiency upgrades rather than the remedy outlined above. I certainly was asking for our projects; but, I am not unique. There are thousands of landlords just like me who have the exact same issue. So I requested that PSE&G develop a policy that allows for an “OBR account” to be created serving each of the free standing residential rentals. So for instance, if we have a property with an apartment upstairs (and its own PSE&G account) plus a commercial property downstairs (and its own PSE&G account), we the landlord would open a 3rd account for that property to bill the OBR for the HVAC installation in the apartment. PSE&G said no, essentially denying a path forward for the landlords who wish to make the substantial energy efficiency upgrades to thousands of residential rentals in NJ. Hopefully the existing hole in all of the programs can be remedied by creating a grant program to fund energy efficiency upgrades to NJ residential rentals existing in free standing (not multi-family) properties.
Chad Kruse	1/5/2024 4:09:47 PM	Please accept the attached comments from UtilityAPI in response to the December 13th HOMES/HEEHR Energy Efficiency Incentives Technical Conference.	2024-1-5_NJ_QO23100733_UtilityAPI
Madeleine McCullough	1/5/2024 2:47:56 PM	Based on program design considerations and parameters outlined in the Technical Conference Notice 1. Optimal pathway to calculating rebates delivered to the customer between modeled versus measured approaches recommended by U.S Department of Energy (DOE). The Board of Public Utilities should adopt a flexible approach to modeling energy savings in multifamily homes, consistent with DOE guidance. The DOE guidance acknowledges that not every home will have conditions that allow for modeled savings consistent with the BPI-2400 calibration methodology, such as incorporating historical utility consumption data. At multifamily buildings where residents do pay their utilities, collecting individual unit energy usage data for 100% of units can be a significant administrative challenge. There should be an alternative method of calculating modeled energy savings in multifamily buildings that do not rely on historic energy usage data where access to aggregated whole-building data is not available. The Board should also work with utilities to ensure that utilities provide customers access to dedicated customer representatives that building owners can contact if they need support accessing whole-building energy usage data. In addition, utilities should not require building owners to go out and physically collect meter data/accounts to provide back to the utility. 2. Integration of the HOMES Program and the HEEHR Programs with existing energy efficiency and low- and moderate-income programs. The Board of Utilities should ensure the state’s Home Energy Rebate programs align with existing energy efficiency programs like those included in New Jersey’s Clean Energy Program (NJCEP). NJCEP has a number of existing rebate and incentive programs and services that can be used to leverage the DOE rebates to further support the costs of appliance, system, or building envelope upgrades. In its guidance, DOE confirmed that “funding authorized by a state government, or local government, or available through a utility program or philanthropic support, can be used to co-fund any remaining costs for upgrades and individual components of qualified electrification projects beyond the value of the Federal rebate.” Ensuring the DOE rebates can be integrated with existing state programs allows for greater household savings and higher levels of energy efficiency. DOE has not released guidance as to how rebates can be structured for Low Income Housing Tax Credit (LIHTC) projects. LIHTC properties face unique financial constraints, including an inability to incorporate grants such as rebates. Since LIHTC is responsible for financing most affordable housing in New Jersey, it is important to reduce barriers to rebate use in these properties. There should be flexibility to structure loans and/or identify another flexible funding source that can be structured as loans and paid back by rebates. If The Board is not inclined to structure the rebates as loans, it should allow nonprofit sponsors of LIHTC partnerships to claim the rebate and loan the funds into the LIHTC partnership. In its FAQ, DOE is explicit that a nonprofit entity, referred to as an eligible entity representative, carrying out a qualified project on behalf of an eligible entity, such as a multifamily building owner (e.g., a LIHTC partnership), may access a rebate on behalf of the eligible entity. The Board should consult with NJHMFA in developing an approach to ensure that rebates can be used by LIHTC housing providers. 3. Approaches to designing programs serving multi-family buildings in low-income communities. The Board of Utilities should work with the New Jersey Housing and Mortgage Finance Agency (NJHMFA) to not only ensure rebates can seamlessly be incorporated into project financing but because NJHMFA has existing relationships with multifamily developers and owners and can support outreach and engagement efforts with these communities. NJHMFA can serve as a strategic entry point for The Board to identify a pipeline of projects slated for recapitalization and rehabilitation and would benefit from additional upgrade/retrofit incentives. The Board should ensure the rebates are designed to best integrate with existing multifamily financing processes, including allowing multi-year rebate reservation periods and providing incentive installment payments to address cashflow constraints. As stated by DOE “A multifamily rehabilitation can take upward of 3 years when accounting for predevelopment through construction. To factor rebates into housing finance, developers/owners will need some guarantee that rebates will be reserved over this time for their project (i.e., options beyond point-of-sale). In addition, the Department of Energy encourages states to include staged incentive payments to ensure affordable multifamily housing owners can make timely payments to subcontractors throughout the retrofit process.” The Board should include funding for technical assistance to help facilitate the use of rebate funds in multifamily buildings and for onsite property management and maintenance staff. The Board should consider allocating a portion of their state funding to supporting technical assistance to multifamily building owners and onsite property management maintenance staff. Affordable multifamily owners need more staff capacity and resources to plan and implement energy efficiency measures. The technical assistance should include energy assessments, support to determine the final scope of work, identify potential contractors, ensure energy efficiency measures are installed properly, and maintenance and operational support. Technical assistance can be implemented through a network delivery model that includes pre-approved partner organizations that meet certification and quality standards. New Jersey should also consider developing peer-learning opportunities for affordable multifamily owners to come together and share lessons learned and best practices from their own experience in energy efficiency upgrades. The Board should also take advantage of DOE guidance allowing states to apply rebates to common area and whole-building energy upgrades so long as the work benefits individual dwelling units, including energy savings, cost savings, pollution reduction, or other health and safety benefits. For the HEAR (HEEHR) program, DOE is explicit that per dwelling rebate amounts can be aggregated to pay for central system upgrades, e.g., replacing a central boiler with a central heat pump system. This allows for a more holistic approach to maximize energy savings, health and safety benefits, and emissions reductions that benefit all residents. 4. Ensuring efficient delivery of these programs with respect to income verification, outreach and customer experience. Historically, low-income communities are not given a voice in program design and implementation, leading to programs that make it more difficult for residents to access resources, especially for affordable multifamily owners and residents. The Board of Utilities should prioritize community engagement and education through a Community Engagement Plan that enables community-based organizations and residents to participate in the design and implementation of the state’s rebate program through a series of public forums and stakeholder meetings. Selected community-based organizations should be ones trusted by residents and who are aware of the existing needs for affordable multifamily housing. There should be flexible income documentation requirements to alleviate administrative burdens for affordable multifamily owners. The range of documents that could be submitted can include income covenant documents for entire buildings, proof that households participate in public assistance programs such as SNAP or Medicaid and Signed Resident Income Certification forms. The Board should also use the list of multifamily buildings deemed income-eligible provided by NJHMFA based on income information already verified by the agency. This is consistent with DOE’s recognition that affordable housing programs, including LIHTC and project-based Section 8, qualify for categorical eligibility. Through the Community Engagement Plan, New Jersey should design educational resources that can be shared with housing owners. Educational resources should specify what energy efficiency upgrades and appliances can be supported or purchased with the rebates and what appliances and upgrades work best for different building/housing types. These resources can be shared through webinars, office hours, mailed to homes, materials distributed through community-based organizations, and posted around communities. Educational resources should also be developed for multifamily residents that explain the benefits of these upgrades (i.e., health impact, utility savings, environmental impact, etc.). The Board should also consider establishing office hours with dedicated staff to support building/homeowners making these decisions. 5. Additional Considerations DOE requires 40% of state funding be allocated to low-income households and an additional 10% must be allocated to multifamily low-income households. While this is a good step in ensuring disadvantaged communities are able to access the rebates, many of these residents are severely energy burdened and owners do not have access to the same resources or capital to complete energy efficiency upgrades on their own. The Home Energy Rebates are the best-suited resource in the IRA for supporting energy efficiency and electrification upgrades in low-income homes. Most resources provided in the IRA are structured as tax credits and financing programs. Low-income households and affordable housing providers are less able to access these programs because of limited tax liability and insufficient income to leverage debt. Therefore, The Board of Utilities should increase the minimum requirement of funds that must be allocated to low-income multifamily households to ensure as many low-income households are able to access the rebates. In addition, The Board should provide enhanced efficiency rebates to low-income households as allowed by DOE.
Maggie McCarey	1/5/2024 1:10:27 PM	Thank you for the opportunity to comment. Please see attached.	1-5-24 Aeroseal NJ Comments
Jamal Lewis	1/5/2024 11:44:07 AM	Attached are comments from Rewiring America with respect to DOCKET NO. QO23100733 on the Implementation of the Federal IRA Home Energy Rebates.	Rewiring America Comments on New Jersey's Rebates RFI
Walter Korfmacher	1/5/2024 9:54:53 AM	I think NJ should provide a 10% tax credit to homeowners that install solar panels on the roof of their home. This would be in addition to the federal tax credit of 30%. This would make it easier for homeowners to buy solar panels and then take advantage of the cost savings from low electric bills and the SREC program. This would also help to reduce the cost of owning an EV car and charging it at home.
Lloyd Kass	1/4/2024 5:51:54 PM	Enclosed for filing are comments of Franklin Energy Services, LLC, on the New Jersey Board of Public Utilities (“Board”) docket on the implementation of the Federal Inflation Reduction Act (“IRA”) Home Efficiency Rebate (“HOMES”) and Home Electrification and Appliance Rebates (“HEEHR”) programs.	Franklin Energy Comments on Implementation of the IRA Home Rebates 1.5.24
Vince Faherty	1/4/2024 4:40:19 PM	Please see attached for the comments of Google Nest	Google Nest Comments on NJ IRA Rebate Design 1-4-2024
Mike MacMillan	1/3/2024 2:08:10 PM	New Jersey should consider a homogenous statewide loan program to support residents' financing needs with these projects, which even after incentives, can cost a homeowner several thousand dollars. Low-cost financing will be required by many residents to afford HOMES and HEEHR projects which "pencil-out." There are several models for State supported loan programs including those that leverage private bank equity through loan loss reserves and interest buy down incentives. However, this private equity is subject to interest rate fluctuations, market conditions necessitating higher interest rates, and myriad of fees associated with loan closing. Another model employed in the state of Delaware through their Delaware Sustainable Energy Utility (DESEU) is a statewide low-interest direct lend program which has proved predictable, affordable, and popular with contractors and homeowners. The direct lend model requires more capital at initiation but has proven to be the lowest cost solution for the state and its customers to run a loan program for energy efficiency projects. Interest rates are well below market rates for the Delaware SEU's loan program and we encourage the NJ BPU to consider partnering with a NJ state or quasi-state agency with the authority to direct lend to pursue a statewide loan program similar to Delaware. Without an affordable loan program of some type, New Jersey may find it difficult to reach equity communities particularly middle-income populations.

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