PJM Offers Comments to NJDEP Newly Proposed Carbon Emission Limit Rule  


PJM filed comments Friday with the New Jersey Department of Environmental Protection (NJDEP) in response to a newly proposed rule to establish carbon emission limits on certain electric generating facilities in order to support the state’s clean energy goals.  

The NJDEP’s proposed rule “seeks to achieve reductions of CO2 emissions from fossil fuel-fired generating units by requiring those facilities to meet output-based emission limits for CO2 that become more stringent over time.”  

In its comments (PDF), PJM references its efforts to utilize PJM’s subject matter expertise to help states advance state policy initiatives. PJM also references its five-year strategy, noting that a pillar of that strategy is for PJM to facilitate state and federal decarbonization policies reliably and cost-effectively. 

PJM made just a few recommendations to the NJDEP in its comments. First, PJM requests that the NJDEP align its compliance deadlines with PJM’s planning year to create a more efficient process for the exit of existing resources from the PJM system. Second, PJM requests that the NJDEP consider additional reliability considerations that would serve to allow for units to run past their compliance deadlines beyond Reliability Must Run. PJM references its work with the state of Illinois on reliability guidance related to the Climate and Equitable Jobs Act.