BOARD OF PUBLIC UTILITIES

Showing result(s) 1 - 5 of 5

Posted By	Posted Date	Comments	Attachments(s)
Tyler Orcutt	1/31/2025 6:40:54 PM	Please see comments below as our file was not able to be uploaded. I. Introduction Renewable Properties, LLC respectfully submits the following comments in response to Proposal No. PRN 2024-137 (Proposal), concerning the Dual-Use Solar Energy Pilot Program (Pilot Program), as filed by Staff of the New Jersey Board of Public Utilities (Board) (Staff) in Docket No. QX24080597. We sincerely appreciate Staff's time and effort in developing this program and for the guidance provided thus far. As our comments pertain specifically to EOI submission requirements developed in the Proposal, we respectfully request that Staff expedite their response so applicants have the necessary information ahead of the February 14, 2025 deadline. Please contact us if you have any questions about this submission. Renewable Properties Point of Contact: Tyler Orcutt Community Solar Manager Tyler@renewprop.com II. Comments regarding research plan requirements Per PRN 2024-137, the Pilot Program includes baseline requirements for conducting mandatory research studies applicable to all projects. Further, the Proposed Rules states that the Board entered into a grant agreement with RAP to serve as the primary designer and organizer of research studies. Renewable Properties has also reviewed the subsequent filing in Docket No. QO23090679 Notice of Solar Incentive Availability (NOIA), the Expression of Interest (EOI) Form, and Guidance Document regarding research plans. While these filings offer more detail on research expectations, additional guidance is needed to ensure that applicants fully grasp program requirements and can effectively present project progress during the application review process. Specifically, Staff should address the following questions when providing guidance: 1. Applicants are expected to provide detailed research plans in the EOI, yet RAP will ultimately design the studies. Since RAP can be contracted to serve as a research partner only after the Board approves projects for the Pilot Program, how should applicants present a research plan that meets the requirements without excessive speculation? a. Does this indicate that an early partnership with a non-Board appointed entity at cost to the developer will receive higher preference in EOI evaluation? 2. Can the Board provide any indication of what data will be required regarding non-Board appointed entities for submission with the final application? Are there specific requirements we can address in our EOI if we choose to pursue that route? We understand that the Board has indicated that this information will be provided after prequalification and before final applications, but overarching guidance is appreciated as we connect with institutions while developing our EOI research plans. 3. We understand that the research items in A–M of Appendix B of the Order launching the Pilot Program are the project owner’s responsibility to execute. However, is it within the scope of RAP’s contract with the Board to help develop a plan for these items when designing the research plan? III. Comments regarding adder calculation The Proposed Rules specify that applicants will provide an estimated Dual-Use incentive adder required to cover incremental costs. Please clarify whether the prequalification estimate is considered binding if a project advances to the full application stage, as further refinements to project details are anticipated over time. IV. Comments regarding underserved communities The link to the U.S. Department of Energy’s Low-income Energy Affordability Data (“LEAD”) tool provided by Staff is broken. Please provide guidance on an alternative method to identify underserved communities.	BPU Docket QX24080597_Comments from Renewable Properties
Rebecca Peichel	1/31/2025 4:45:45 PM	Please find attached the comments of Forefront Power relating to Docket No. QX24080597 regarding the proposed new rule to the Dual–Use Solar Energy Pilot Program.	New Jersey Dual-Use Solar Energy Pilot Program Proposed Rule Comments 01312025 - ForeFront Power
Paul Rhodes III	1/31/2025 3:55:16 PM	Attached are the comments of BlueWave in BPU Docket Number: QX24080597 regarding the proposed amendments to N.J.A.C. 14:8-1.2 and 11.4 and proposed new rule to N.J.A.C 14:8-13, Dual–Use Solar Energy Pilot Program.	BlueWave comments on BPU Docket Number QX24080597
Kelly Buchanan	1/31/2025 2:19:14 PM	Thank you for the opportunity to provide written comments in the above referenced proceeding, Docket No. QX24080597. Lightstar applauds the New Jersey Board of Public Utilities (the Board) for the release of the dual-use solar energy pilot program rules, and we look forward to the timely implementation of the pilot program. This is an exciting opportunity for New Jersey’s farmers and simultaneously creates a new path towards meeting clean energy goals. Lightstar develops, builds, and owns community solar projects with more than 1200 megawatts (MW) of projects completed or in development across the country. Of that 1200 MW portfolio, nearly 300 MWs are agrivoltaics projects. As part of our business model, Lightstar cares for and stewards the land before, during, and after a project is built, while maintaining long-term partnerships with landowners and farmers. We’re one of the few providers that own and operate all our projects and one of the first to offer landowners the opportunity to maintain the agricultural viability of their land through agrivoltaics. New Jersey agrivoltaics sites represent a large part of our portfolio but will also serve as important sources of new information and research for the broader Mid-Atlantic region. While we applaud the Board for opening the dual-use pilot program, we would like to reiterate our concern with the proposed control area requirements and seek clarification on several important items within the regulations. First, and as stated in previous comments, the proposed control area unnecessarily limits and restricts farmers and presents significant threats to the viability of mature dual-use projects based on land constraints. Lightstar believes that requiring a 3-acre control area is inconsistent with current Rutgers and National Renewable Energy Lab research practices for dual-use sites. Requiring such a large control plot does not aid in scientific validity and will severely limit the number and the diversity of farmers who will be able to accommodate such a large control plot and restriction on their farming practices outside of the array. Hamstringing farmers should not be the intent of these regulations. Lightstar would also like to reiterate that the sites with available interconnection capacity (both distributed and transmission) are smaller sites, as the majority of family farms in New Jersey are on small acreage farms. For example, we are currently dealing with a serious concern that has arisen with one of our landowners who is hoping to participate in the dual-use pilot program. This project is Lightstar's most mature as it has completed municipal permitting and received its System Impact Study issued by JCPL. The tenant farmer is very excited about farming the arrays with a variety of vegetables, namely tomatoes. By way of background and context, the landowner of this parcel is in his 80s and is frustrated by the programmatic delays that this project has faced - at no fault of Lightstar. As a result, he is very upset with the program requirement that he "tie up" additional land to accommodate a control plot area for this project. He is concerned that the Board will continue to delay the pilot program and as he is older, he will not be able to otherwise sell, develop, or use the additional land necessary for a control plot. The current leased site area is exceedingly small. We have permitted for the use of 9.4 acres. Downsizing the project to accommodate the control plot would not demonstrate commercial viability which is a stated purpose of the pilot program. Downsizing a project to around 1 MW to accommodate for a control plot would increase EPC costs and decrease the benefit to the landowner and farmer. We respectfully suggest that it would be more appropriate to require a minimum control plot size based on the total project site of the farmer’s land in question. We propose that the rules be amended to require control plots to be 15% of the total project site acreage, but not less than a .5 acre and maximum of 3 acres. Additionally, if there is not an opportunity to site the control within the array area, then we request that adjacent properties be acceptable control plots as long as the soils are similar, the farmer is the same, the farm plan and agricultural practices are the same it is within ¼ mile of the array site. This is important, especially in New Jersey as most family farmers and especially tenant farmers only have access to a patchwork of small sites. Lightstar is also concerned that the rule proposal requires a lease between landowner, farmer, and developer. Unfortunately, this three-party agreement goes against current industry practices. Typically, developers have a lease agreement with a landowner and a separate legal contract with a tenant farmer. We respectfully suggest that the Board accept separate but binding agreements to fulfill this requirement. Finally, Lightstar seeks clarification from the Board regarding the following: What are the expectations of Rutgers’ participation in research? When will we know more about how Rutgers will conduct research and work with farmers? Farmers have expressed concern over the lack of clarity around their responsibilities associated with research. Do we need to contract with Rutgers during the EOI process, application process or after a program award is given? Can the BPU confirm that fences and/or control areas are allowed to be located in the buffer and/or setback areas of a parcel? And, can the control plot be on an adjacent or abutting parcel and be preserved farmland? There would be no solar generation on the control plot area. Thank you for the opportunity to provide these comments in relation to Docket No. QX24080597. Lightstar strongly urges the Board to act expeditiously to incorporate stakeholder comments and to move forward with a 2025 dual-use pilot program application process. If you have any questions or need additional information, please contact us. Sincerely, Lucy Bullock-Sieger Vice President of Strategy, Lightstar Kelly Buchanan Policy & Strategy Manger, Lightstar	Lightstar Comments 1.31.25 (2)
Alexander DePillis	1/6/2025 5:03:37 PM	Per Dawn Gray's (BPU) request of 1/3/2025, I am copying the comment from QO23090679 to this docket QX24080597. BEGIN PASTE FROM QX24080597 ==> Sherry L. Golden: I'm monitoring this case from the Vermont Agency of Agriculture, Food, and Markets as the person in the Agency charging with reviewing solar project petitions and applications for a Certificate of Public Good for their potential impact on statutorily defined farmland here in Vermont. 30 V.S.A. § 248, New gas and electric purchases, investments, and facilities; certificate of public good (https://legislature.vermont.gov/statutes/section/30/005/00248). Outside of that regulatory role, our Agency promotes farming-friendly solar practices (https://agriculture.vermont.gov/land-use-renewable-energy/farm-renewable-energy) and we facilitated a grant to fund agronomic research on solar grazing at two sites. With our land-grant university, we hosted a workshop on solar grazing this past summer (https://agriculture.vermont.gov/event/solar-grazing-workshop-solar-grazing-climate-smart-farming-practice). Precious little agronomic data from agrivoltaics exists. I have high hopes for your proposed program. The proposed requirements of 14:8-13.10 (Monitoring and research requirements) are extensive. I simply urge you to be as transparent as possible with everything related to the research, i.e., to make everything listed in this section available. In the alternative or as a complement, your research designee could compile the many agronomic aspects and data of each project into a project-specific report. For my part, I have been collecting the agronomic studies on agrivoltaics and am glad to share a compilation with your designee if you think it would help. The only exception meriting confidentiality that occurs to me is the technical particulars of agrivoltaic equipment's design or operation. I do understand stakeholders may have other reasons to ask for confidentiality and I am simply not familiar with those concerns. I trust the Board is familiar with those concerns, experienced at judging the merit of confidentiality requests, and will err on the side of transparency with regard to agronomic aspects. Sincerely, Alex DePillis <== END PASTE

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