Among states with established climate change mitigation and carbon reduction goals, one of the first issues addressed is peak energy demand, with New Jersey being no exception to this trend. In this pursuit, the New jersey Board of Public Utilities (BPU) has developed a straw proposal on energy efficiency and peak demand reduction programs.

In short, the proposal looks to reduce statewide energy costs, give all residents access to energy efficiency upgrades and create jobs through programs administered by the state and the state’s utilities.

Yet with these goals laid out, there’s one glaring omission, one that Luis Davila, a consultant with the Distributed Generation Advocacy Coalition claims could set the state back nationally: there’s no mention of the benefits of storage technologies for peak reduction and efficiency in the entire proposal.

“It’s baffling that Jersey hasn’t taken advantage of [storage], even though others have done the analytical studies and have started to implement the non-energy benefits of battery storage – the efficiency benefits.”

Industry responses

Davila is not alone in this opinion, as during the proposal’s comment period, Sunrun issued twofold recommendations, with one calling on the BPU to establish “bring-your-own-device (BYOD) programs that leverage customer sited energy storage assets” as a core peak reduction program offering.

The company went on to outline how Green Mountain Power, Public Service Enterprise Group of Long Island and the state of Massachusetts have all established BYOD programs and how such programs could be used to evaluate New Jersey’s proposed peak demand reduction strategy.

The Energy Storage Association (ESA) also filed comments, focusing on how the state already has an energy storage target of 600 MW by 2021 and 2,000 MW by 2030. With such a goal already laid out and with storage’s proven ability to provide overall system reliability and drive down the peak — the strange exclusion of storage from the straw proposal is magnified.

To solve this issue, ESA offered five recommendations:

Define energy storage as an eligible resource for system efficiency and peak demand programs

Establish more prescriptive frameworks for utility peak demand reduction programs

Lean on existing peak demand reduction programs in Massachusetts, Vermont, and New Hampshire

Look to BYOD and Daily/Targeted Dispatch programs as cost-effective solutions

Non-wires Alternatives pilot design should borrow from New York and Maryland

Fortunately, the initial proposal is just the first step towards the development of a comprehensive energy efficiency and peak demand reduction policy in New Jersey. With such a strong industry show of support for the inclusion of battery storage this early in the process and existing state mandates for storage procurement, there is strong groundwork for inclusion in later revisions.