PSE&G has urged state regulators to partner with the state's electric and gas utilities to adopt the policies and programs to help consumers conserve energy and use renewable energy. New Jersey's largest utility expressed support for models already effective in other states such as California, where utilities are rewarded for meeting aggressive energy efficiency targets set by regulators.

In a statement distributed during a meeting on energy efficiency hosted by the New Jersey Board of Public Utilities, Anne E. Hoskins, PSEG's vice president-federal affairs and policy, said, "We commend the state's leaders for exploring creative solutions to this challenge, but urge the state not to overlook one of its most powerful resources - and allies - in the quest for efficiency: the state's regulated utilities. We believe PSE&G and the state's other utilities are uniquely positioned to work in partnership with the state and to implement the state's energy efficiency initiative."

Utilities, Hoskins said, have strong relationships with customers, well- established brand recognition and trust. She said PSE&G, which serves New Jersey's six largest cities, is also well positioned to promote efficiency among all customer groups - including urban residents, low-income customers and renters.

"Utilities have millions of customer interactions, and a dedicated and highly capable union workforce that can be engaged to promote efficiency," Hoskins said. "Utilities can serve as the organizing force to avoid conflicts and ensure that customers are offered the right mix of options and mechanisms." She added that utilities can deploy capital over the long term, just as they have done to make universal service a reality. Universal access to efficiency is critical for ensuring that all ratepayers have the opportunity to benefit from efficiency programs.

Reacting to several options under consideration by regulators, Hoskins said that creating an "energy efficiency utility," such as the Efficiency Vermont non-profit agency under contract to the state, may not translate easily to a highly urbanized state like New Jersey with a broad industrial and commercial base.

Similarly, the concept of "white tags" is a relatively untested concept that requires considerable additional analysis and investigation. "PSE&G is concerned that white tags may not provide enough of an incentive for customers to invest in efficiency, and that many of our low-income, residential customers could be left out of an efficiency program structured around white tags," Hoskins said. "PSE&G believes more work must be done to discuss and work through the numerous practical issues, potential drawbacks and benefits involved in implementing efficiency white tags in New Jersey."