Washington, D.C. (August 17, 2022) — Today, Americans for a Clean Energy Grid (ACEG), a diverse coalition of business, labor, consumer, utility, environmental, and other groups that support effective transmission development, submitted comments to the Federal Energy Regulatory Commission (FERC) in response to its Notice of Proposed Rulemaking (NOPR). This proposed rule, issued in April, is aimed at reforming its regional transmission planning and cost allocation policies and processes.
In the last decade, regionally planned transmission investment decreased by 50 percent and almost no new interregional lines have been planned. Addressing the major policy roadblocks to planning and paying for new transmission lines is critical to the development of a modern and resilient clean energy grid. Action on this issue was supported by a diverse group of over 30 organizations, who sent a letter to the Commission, urging them to finalize a strong planning rule.
ACEG applauds FERC’s initiative to improve transmission planning and thanks the Commission for the opportunity to comment. The key points addressed within the comments include:
- Efficient investment in long range high-capacity transmissions is needed to protect reliability and resiliency, meet decarbonization goals, and bring low cost-power to consumers.
- 174 parties in the ANOPR supported FERC adopting rules that would facilitate proactive planning, and ACEG continues to see widespread support for this core aspect of FERC’s proposal.
- A diverse group of stakeholders including consumers, NGOs, organized labor, and various businesses agree that proactive planning is needed and FERC’s proposal is generally a strong approach and utilities, independent transmission developers, and various other business models in the electric industry agree that FERC’s proposal is workable.
- While a certain level of regional variation is expected and reasonable, the nation’s regulator should adopt a common methodology as the basis of planning; this is especially in an industry where every line and every regional plan has power flow impacts across states and regions.
- Successful planning is proactive, multi-benefit, and scenario- and portfolio-based as ACEG has consistently recommended. We are pleased to see those features in the NOPR.
- Transmission successfully gets planned, permitted, funded, and built when there is effective regional planning with key stakeholders including states involved. ACEG is also pleased to see these features in the NOPR.
- There are a few ways in which the NOPR needs to be strengthened in order to ensure planning is substantively improved and that loopholes do not allow regions to relegate planning processes to a mere checklist.
The NOPR can ensure transmission planning is sufficiently forward-looking as transmission needs grow rapidly in the U.S., particularly with growing emphasis on electrified buildings and cars. Join ACEG on Thursday, August 18 at 12 p.m. ET for a public briefing to discuss comments submitted in response to FERC’s notice of proposed rulemaking (NOPR), seeking to reform its regional transmission planning and cost allocation policies.
ACEG’s Executive Director, Christina Hayes stated that “ACEG’s diverse coalition broadly supports FERC’s rulemaking process to address the most important issue of our time: expanding and modernizing the interstate transmission system. In order to achieve this, we need transmission to be reformed so that planning is done under a proactive and holistic approach, and 174 parties and 59 consumer organization who filed in the ANOPR proceeding agree. We thank the Commission for their consideration of ACEG’s comments and hope they move swiftly to finalize – and implement – a strong rule.”
A better U.S. grid will provide many benefits to Americans, including consumer energy cost savings. Large-scale transmission, combined with large-scale buildout of renewable energy, is estimated to lead to $100 billion in savings cumulatively, saving a typical household more than $300 per year. Under a national macro grid, over 80 percent of the power system’s electricity can be supplied with renewable energy at a cost equal to or lower than today’s energy costs. Further, transmission makes the electricity market more competitive and increases the market influence of consumers. In 2021 alone, voluntary energy customers contracted for 11.06 GW of clean energy—the equivalent of 40% of all new carbon-free capacity installed that year.
“Large energy customers are working toward a vision of a customer-driven, clean energy future for all, but we must scale rigorous sustainability commitments and clean energy access if we want to meet growing demand, support businesses and spur job creation,” said Adrienne Mouton-Henderson, Director of Market and Policy Innovation, Clean Energy Buyers Association (CEBA). “It is critical to advance integrated, well-planned transmission expansion and FERC’s NOPR is a step forward in the robust reforms needed for long-term transmission planning and cost allocation to develop cost-effective and efficient solutions that will accommodate all resources, particularly renewable resources that are key to the energy transition.”
“Long-term, proactive transmission planning that properly recognizes the benefits of transmission to both interconnection customers and load is critical to building the low carbon economy and the grid of the future. FERC should be congratulated for its leadership on these issues and for taking this first step to drive much needed regional transmission deployment. FERC should also continue to advance a holistic approach to transmission policy by implementing reforms that encourage the further development of interregional projects and specifically merchant HVDC projects, through reliability compensation, regional planning, interconnection and participant funding reform, and an overhaul of import and export charges for such projects.” — Nicole Luckey, Senior Vice President of Regulatory Affairs, Invenergy
“It will take a moonshot effort to build out the electric grid if the nation is going to meet the rapidly growing need for more transmission to support the clean energy transition, adequately address reliability and resilience challenges, and further electrify the economy within the next decade or two. WIRES supports FERC’s proposed regional transmission planning and cost allocation rule as an important first step toward advancing this effort and urges the Commission to take further meaningful, unambiguous, and consistent actions to promote investment in transmission infrastructure to meet the well-documented needs of the future.” — Larry Gasteiger, Executive Director, WIRES
Transmission creates domestic, good-paying union jobs, especially in low-income rural communities. Analysis by the Brattle Group indicates that domestic content accounts for 82 percent of the total value of transmission investment, with 61 percent of materials, such as towers and transformers, are sourced domestically. A 2020 study revealed that expanding and modernizing the transmission grid would unleash more than 6 million net new renewable energy and transmission jobs in the Eastern US alone, and predicted similar results in the Western half of the country.
“Today, large-scale build-out of transmission infrastructure will get more clean energy on the grid faster than any other step we can take. Unfortunately, roadblocks to transmission expansion remain. Building the modernized grid we need will generate high-quality jobs here in the U.S. Almost all transmission work—construction, O&M work, transmission planning, engineering, logistics— is domestic. New transmission infrastructure will benefit the IBEW and the communities we serve across the country and create tens of thousands of good paying, union jobs.” — Bob Dean, Business Manager, International Brotherhood of Electrical Workers (IBEW) 1245
“The electroindustry is pleased to see FERC proceed with transformative rules that encourage proactive transmission planning. This approach acknowledges the vital role played by modern technologies and innovative products that will enable the grid to meet growing electrification needs in communities and businesses nationwide. Reliable transmission is integral to an energy transition that meets consumer demand, reduces carbon intensity, and delivers affordable and resilient American energy.” — Debra Phillips, President and CEO of the National Electrical Manufacturers Association (NEMA)
Adequate reforms to transmission policy could unlock access for much of the 1,300 gigawatts (GW) of wind, solar, and energy storage capacity that are waiting in interconnection queues today. This energy would not only benefit communities with cleaner air, energy cost savings, and emissions reductions, but would also improve the reliability of the electric system. Well-planned transmission expansion would allow variable resources, like wind and solar, to move across regions to ensure demand is met in all hours at all locations and make targeted attacks on the grid more difficult to execute.
“Enel agrees with the Commission’s findings in the NOPR that the current regional transmission planning process will not adequately meet the needs of the electricity sector as customer and reliability needs evolve. The ability to move power across large areas helps maintain reliability and deliver low-cost renewable energy, which is what consumers, utilities and states are procuring. Enel applauds the Commission for its leadership in this effort and encourages the Commission to act swiftly to finalize a strong planning rule that enables the low-cost, clean, and reliable energy grid that American businesses and consumers demand.” — Enrico Viale, Head of Enel North America
“FERC must take decisive action to upgrade our power grid,” said John Moore, director of the Sustainable FERC Project at NRDC (Natural Resources Defense Council). “Far too many clean energy projects are dying on the vine because of outdated FERC transmission rules. New FERC standards are necessary to lower customer costs, reduce carbon pollution, and increase grid resiliency against climate-fueled hurricanes, floods and heat waves.”
“Non-RTO regions like the southeast have been behind on transmission planning for far too long. As the electric industry shifts to more low-cost renewable resources throughout the south, it will be even more important that states work together on transmission planning.” — Simon Mahan, Executive Director, Southern Renewable Energy Association
“A 21st century economy needs a 21st century grid. ACORE commends the Federal Energy Regulatory Commission (FERC) for proposing to require long-term, scenario-based transmission planning, and for identifying a wider array of transmission benefits. As we stated in our comments, FERC can also make improvements in its final rule by using a minimum set of benefits for both transmission planning and cost allocation, implementing a more efficient portfolio-based approach, assuring that all drivers of transmission are incorporated, and requiring the inclusion of a broader group of grid-enhancing technologies. These measures are vital for improving system resilience, keeping costs low for consumers, and delivering the clean power that Americans deserve. ACORE continues to urge the Commission to expeditiously finalize this rule with these improvements and initiate additional rulemaking procedures to help upgrade our transmission infrastructure and move the country forward on its path to a clean energy future.” — Gregory Wetstone, American Council on Renewable Energy (ACORE) President and CEO
About Americans for a Clean Energy Grid:
Americans for a Clean Energy Grid (ACEG) is a non-profit, broad-based public interest advocacy coalition focused on the need to expand, integrate, and modernize the North American high-voltage grid. ACEG brings together the diverse support for an expanded and modernized grid from business, labor, consumer, environmental groups, and other transmission supporters to support policy that recognizes the benefits of a robust transmission grid. For more information, please visit cleanenergygrid.org.
ACEG: Sabreen Ahmed, Research Associate
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