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In New Jersey parties filed resource adequacy (RA) technical conference post-conference comments in the New Jersey Board of Public Utilities (BPU’s) investigation into issues surrounding resource adequacy and participation in wholesale electricity markets.  

Among other things the BPU seeks to understand multi-year interconnection delays, past and projected generation retirements, and increased load growth from sources such as new data centers to support artificial intelligence.

Advanced Energy United – “Appreciates the opportunity to provide comments in response to the August 5, 2025 technical conference on resource adequacy (“RA”) convened by the New Jersey Board of Public Utilities (“Board” or “BPU”). 1 United is a national association of businesses that works to accelerate the move to 100% clean energy and electrified transportation in the U.S. The term advanced energy encompasses a broad range of products and services that constitute the best available technologies for meeting our energy needs today and tomorrow.”

“United is encouraged by the Board’s interest in exploring methods for ensuring RA and is pleased to offer recommendations of several actions the state can take itself to act on this goal. 

Key areas for state engagement include: 

Remaining vigilant to ensure PJM is fully compliant with existing FERC orders on interconnection (FERC Order No. 2023) and transmission planning (FERC Order Nos. 1920 and 1920-A) and apply pressure to ensure further progress beyond FERC’s minimal requirements. 

• Engaging in key PJM stakeholder processes and FERC proceedings impacting RA, such as continued refinement of Effective Load Carrying Capability (ELCC) and development of sub-annual capacity auctions. 
• Streamlining NJ siting and permitting processes for critical transmission and generation infrastructure. 
• Developing appropriate New Jersey-specific demand-side management polices to better forecast and manage demand, including large single site load interconnections, while aligning with PJM’s load forecast and Regional Transmission Expansion Planning (“RTEP”) process. 
• Developing appropriate jurisdictional polices to better forecast and manage demand and large single site load interconnections, while aligning with PJM’s load forecast and RTEP process. 
• Supporting demand-side resources, reducing barriers to VPP deployment in the PJM market, and creating state-level VPP programs to deploy and scale distributed energy resources (“DER”).

“Developers of new generation resources are seeking to meet this surging demand by submitting requests to interconnect to the PJM grid, but the process is slow. The next PJM study cluster to be approved for interconnection, Transition Cluster 1 (“TC1”), recently entered the application review phase in December 2024.8 This cluster contains roughly 72,000 MW of generation resources, but it is not slated for full approval until October 31, 2025 at the earliest. 9 While this new generation would meet a large proportion of PJM’s predicted 15-year increase, the upgrades needed to connect the projects in TC1 will take several years to construct, and the projects themselves have other processes to complete before they can start injecting energy into the system. This approval to operation lag is itself a contributor to PJM’s generation gap and highlights why it is imperative that proposed generation projects be studied and approved for interconnection as quickly as possible.”

“Part of the challenge facing new resources seeking to come online is that the region has not engaged in efficient regional transmission planning and now has a grid that is congested and in need of significant investment. Despite this lack of investment in regional transmission, consumers in the PJM region have faced a 117% increase in transmission costs10 resulting from increased reliance on less efficient locally planned transmission projects.11 The region has an opportunity to improve regional planning and get more value from money spent on transmission by ensuring strong compliance and implementation of FERC Order No. 1920. States have a central role in the success of this effort and participate primarily through the PJM Area Relevant State Entities Committee (“PARSEC”). 12 

“In addition to a functional interconnection process and adequate grid infrastructure, another key component of RA is fair and predictable markets to signal system needs and reward resources for their contributions to RA. The PJM capacity market ensures that the required generation resources are in place, operational and available to meet system power demands at the times of greatest system need. Getting capacity market design right is critically important to incentivize capacity resources to enter the market, and to ensure the right kind of resources are available at the lowest possible cost.”

Constellation Energy Generation – Among other things Constellation Energy Generation asks the BPU to: 

• “examine and work to streamline siting and interconnection barriers at the local and state government and” utilities; 
• “prioritize demand response, energy efficiency and energy storage investments… [to] provide greater near to mid-term (pre-2030) impacts on resource adequacy;” 
• “hold a conference to ensure LDCs are following best practices in forecasting load and are doing so reasonably and consistently across the state”; and
• “explore opportunities for long-term financial hedging of capacity prices for BGS customers or for all residential customers as such transactions can help better manage price volatility.”

Division of Rate Counsel – Comments noted that “supports continued participation in PJM markets because the primary driver of recent capacity price increases is explosive data center load growth outside of the State,” arguing that the financial burden of this growth “should be shifted away from residential and small commercial ratepayers and instead financed by the very same tech companies that are responsible.”  

NRG – Recommends “requiring data centers to bring their own new capacity to the table before interconnecting to the system,” noting that “Other states have required long-term contractual commitments on the part of retailers seeking to serve load in a state—although typically in a manner that imposes that requirement across all loads, and not for a particular customer class or vintage of load,”   NRG also noted:

• [“r]ate design for utility-offered default products should reflect the peak-demand-related services, such as the provision of capacity” and “all utility default customers should be on a time-of-use (‘TOU’) rate;” and recommended to establish:
• “programs that allow customers and their suppliers to more readily optimize [smart devices]… in relation to the energy and capacity markets.” 

QO25060358  (06/19/2025)
(In The Matter Of New Jersey’s Renewed Investigation Surrounding Resource Adequacy)