VIA ELECTRONIC MAIL Docket: GO23020099 In the Matter of the Implementation of Executive Order 317

Governor Murphy’s Order 317 expressly draws the connection between the development of gas utility plans to reduce emissions and the need to manage stranded cost risk, specifically highlighting the reality of a “shrinking customer base,” the need for changes in subsidies to avoid encouraging investments that are destined to become stranded costs, and shifting investment funding from the natural gas. [...] Specifically, the BPU may require public utilities to furnish “safe, adequate, and proper service, including furnishing and performance of service in a manner that tends to conserve and preserve the quality of the environment and prevent the pollution of the waters, land and air of this State.”18 What pollution prevention and preserving environmental quality has looked like over time has changed. [...] In its 2021 update, the Interagency Working Group acknowledged that its valuations were substantial underestimates due to the use of high discount rates and the failure to incorporate the latest climate science and economics.53 Key stakeholders including the National Academies of Sciences for years to have been calling for an update to the Working Group’s approach. [...] 20 Whether a shift to hydrogen blending would reduce the climate impacts of the existing system, and by what extent, depends on the lifecycle emissions of the hydrogen.60 This section does not address issues specifically resulting from the implications of blending hydrogen with methane for delivery to end users, such as the need to replace pipelines to prevent leakage or the ability of home applia. [...] The extent to which blending hydrogen with natural gas could reduce the total emissions intensity of the natural gas system will depend on the emissions associated with the hydrogen, and how those emissions compare with the emissions associated with the natural gas that the hydrogen partially displaces.61 Although hydrogen produces no GHG emissions upon combustion (or use in a fuel cell),62 the fu.