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09/30/19 6:30 PM

#15576 RE: Drgdarf #15562

Draft 2019 New Jersey Energy Master Plan Policy Vision to 2050 Comments of FuelCell Energy, Inc. September 16, 2019

I. Introduction FuelCell Energy, Inc. (FCE) wishes to take this opportunity to submit written comments in the stakeholder feedback process with respect to the Draft 2019 New Jersey Energy Master Plan (EMP) document, as solicited by the Board of Public Utilities (BPU) on June 10, 2019.

It should be noted that FCE has provided testimony and comments at Energy Master Plan stakeholder meetings related to the inclusion of fuel cells as a carbon-neutral, distributed energy resource, and on our products, value proposition, and contributions to grid resiliency, carbon reduction and air quality improvement.

We (FCE) have also provided comments as to how fuel cells offer unique benefits that contribute to carbon reduction, resiliency and air quality that are not achievable via more traditional, intermittent, clean energy resources and they should be explicitly included in this Plan. II. RESPONSES TO ENERGY MASTER PLAN QUESTIONS Strategy 5: Modernize the Grid and Utility Infrastructure 19) How should New Jersey approach the modernization of the current utility model (e.g., decoupling or performance incentives, rate design, smart grid technology, demand response) Create Resilience and Microgrids Fuel cells have a proven record of providing reliable, consistent energy for sites in need of high-quality primary power such as data centers, hospitals, university