Thread by @LizaBevin

happy friday night, I'm going to tweet about #electricity #transmission for a while. Facts, opinions, and ideas, motivated by BIB, BBB and SITE b/c Congress has THREE opportunities to get transmission development kickstarted. Here we go.

As a reminder, and for anyone new to the transmission black hole,

Transmission is enabling infrastructure for fast and fair decarbonization. Necessary but not sufficient.
niskanencenter.org/transmission-i…

A Macrogrid -- nation spanning, interconnected infrastructure -- is the dream/ideal.
niskanencenter.org/america-needs-…

Not every decarb study concludes with a Macrogrid, but every macrogrid study concludes with a macrogrid, so that's something.

I jest. Transmission lets us share resources broadly, a macrogrid maximizes the fair part of fast and fair and also helps with the fast. More options for sending power more places means less cost

We haven't seen significant (any?) congressional action on transmission since the the Energy Policy Act of 2005. This R led effort established the first federal authority for siting transmission lines, previously something only under state authority.

EPAct of 2005 required the DOE to find areas of economic congestion, which then allowed FERC to site transmission in those areas (read: an market opportunity that was unable to be realized due to state inaction).

The authority has been significantly pared back to put us in the bind we're in now. Klass&Wilson 2012 puts it best: "Federalism mismatch" —the authority split between states/feds does not align with the needs to be addressed or the benefits that can accrue
scholarship.law.vanderbilt.edu/vlr/vol65/iss6…

There are economic opportunities still (see @aceg's paper on 22 projects ready to go: cleanenergygrid.org/transmission-p…)

@aceg But lack of transmission also keeps the market opportunity from developing in the first place by keeping clean energy projects from coming to fruition (see ACEG's paper on the interconnection queue: acore.org/new-report-dis…)

it's not great, folks, and we end up with Transmission Stalled:
niskanencenter.org/transmission-s…

BUT, we have some action in Congress. What can it do for us? Welp, that depends on what we want

Some folks want a national transmission organization that would facilitate the development of a macrogrid, starting with public-private partnerships for "no regrets" lines (like the economic congestion concept, but adding likely future clean energy hubs) eenews.net/articles/repor…

With @catf, @NiskanenCenter agreed a profound rebalancing of authority is needed, which could be a national transmission org or could be a restructuring of authority to enable expansion more like Natural gas pipelines. TBD!
niskanencenter.org/report-how-are…

In our webinar earlier this week, Chairman Glick said
1. he thought a national transmission organization would take too long to get in place to make a difference, and
2. FERC had to take action on transmission because action needed to be taken

noble, but precarious

So, I think it's fair to say we have no idea what we want. The Silverstein/Zavadil paper on an NETA is the most fleshed out idea I've seen anyone commit to.

We need more transmission. It's been so broken for so long we need change to figure out what is going to work.

specifically we need more high capacity, interstate and interregional transmission.

So, enough throat clearing and on to Congress and the FERC ANOPR

In case we all forgot, the bipartisan infrastructure bill had some potentially significant transmission provisions:

niskanencenter.org/bipartisan-inf…

CRUCIALLY, it includes a provision to expand DOE/FERC siting authority, allowing FERC to overrule state denial of lines with regional significance, based on an expanded list of factors DOE can take under consideration (security and that pesky interconnection issue for generators)

This has the potential to be huge. It is expansive—transmission is typically considered >100kV. For reference when I say high capacity lines are needed I mean >345 kV. But the 100 kV "local" lines aren't the ones facing siting challenges at the state level, so it's kind of moot

But it doesn't protect landowners from the abusive practices seen under FERC's siting authority for Natural Gas. The transmission buildout is going to have major land impacts and destroying land for things that don't even get built is not going to help anti-NIMBY arguments

This is where SITE is much stronger—landowner protections, and clearly establishes a federal authority for high capacity lines. No DOE study needed. It's not in the BIB, but it's an idea worth continuing to fight for.

Both of these siting changes limit state authority, which most state commissioners do not like. FERC and NARUC have a joint task force to attempt to address this.

Can a joint task force of 5 FERC commissioners and 10 state regulators find a path forward on this? I'm skeptical

I support the effort! I think the conversations need to happen. I do not think those 15 people will find a solution to balancing authority, priority and politics that works for the 48 cont states, and we need most of them to get a macrogrid

The other thing BIB has is $$, which is going to bring us to the BBB too, and then back to the questions of what we have and what we want and what we need.

BIB sets aside some money for DOE to support transmission lines by buying power capacity on them for a limited time so they can get built and eventually fully finance themselves through partnerships to buy and sell power. Interesting idea, attractive for private developers

it's not a lot of money though, in the grand scheme of transmission lines. I've heard a very narrow range of estimates in the single digits for how many projects this can support at one time. Maybe this program can get more money in the future if it proves successful?

Now the BBB has a whole Part 5 on transmission, plus a tax credit. It's a hodge podge of things.

First, it has a few billion for interties. This is where the #FreeSeams study started: expanding the HVDC interties between the east and west.

The definition of intertie can be expanded by the Secretary and can include the areas that DOE studies and finds need transmission (I didn't name them in prior tweets, but they are NIETCs — National Interest Electric Transmission Corridors).
Great opportunity, not a ton of money

next there are grants to facilitate siting of lines. I think this is a cool idea, and I'll avoid the cynicism of calling these payoffs.

If states say they need a seat at the table to make siting happen, this could be an effective parallel with the FERC task force to test out ideas&negotiate. There are also economic development grants allowed. Economic impacts are often a reason states deny interstate lines

Now, some states are not going to want to participate at all in efforts to expand clean energy. This is where backstop could help of course.

Next there's money for technical assistance for wholesale markets. This is so not my area, but I think this is to encourage regions not served by an RTO to organize around an RTO.

There are benefits to every region being under an RTO, not the least of which is one less East/West tension in all transmission discussions. But RTOs haven't been leaders in getting high capacity interstate and interregional lines built. at all.

Closing out Part 5 is $$ for planning transmission to support an offshore wind network. I love this provision. The money is for planning and studying offshore wind, as it relates to integrating offshore wind and y'know, everything else.

Grid enhancing technologies (i.e. things that maximize our existing lines), using existing rights of way (unclear if they mean just electrical or also highway, rail, etc), and even a nationally planned grid into which the offshore lines would connect.

That's a lot of studies.

FINALLY we get to the transmission tax credit. It's in there. Why does this matter?

1. financing of merchant/private developer/non-incumbent lines. tax credits reduce risk. Like the transmission capacity buys in the BIB this gives private investors a little more runway to pursue projects so hopefully we get more projects.

2. I'm told this will also help with cost allocation, i.e. the debates around which ratepayers should pay how much for new transmission lines. this reduces the $ that have to be allocated, but doesn't solve the underlying debate on who counts as a beneficiary.

which also brings me to the FERC ANOPR on Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection

ferc.gov/news-events/ne…

I've not read the comments yet, nor even most of @AriPeskoe's ongoing I-read-the-comments-so-you-don't-have-to thread:

https://twitter.com/AriPeskoe/status/1449009827771031554?s=20

On Wednesday Chairman Glick was very passionate about the FERC-NARUC taskforce and the ANOPR. These might be the most important things that happen for transmission. But, maybe because I've never worked at FERC, I'm just not convinced it's going to be enough.

What can FERC possibly conclude in a rule that's going to fix a "federalism mismatch"? what do they have the authority to even rule on effectively? Can/will they really impose a peanut-butter/post-stamp (my god we need a new letter. it can't all be Ps) cost allocation?

Will that hold up against a challenge? If they don't come up with a universal cost allocation solution, will the problem of cost allocation be solved at all or just reframed in new terms?

Is an independent transmission monitor going to do anything other than add another voice to the fight?

What do we want? Do we want more competition to build transmission lines? Is that an opportunity that makes sense to defend or a planning issue best left to utilities (or possibly a national org)?

One nice thing about private investors is they can disrupt existing paradigms. Build a bunch of transmission lines and see how the system of oversight has to reform around them!

But hold up, SooGreen, a privately financed transmission line, is stuck in the interconnection queue. The RTOs say they need to build more transmission to allow this transmission online.

There's an argument from utilities that competition is the problem, and they should be trusted to keep managing the system. Competition discourages them from investing and doesn't make sense for transmission.

This is particularly unconvincing given the bottleneck transmission faces. Utilities have been content in many places to just strengthen their regions. interregional transmission is a benefit to the whole, but carving up the parts is tricky. Easier to avoid

So there's some money in BIB and BBB, and that's going to help. I do think so. the more people with money who are involved, including DOE, the more the problems come to the fore and MUST be answered.

And there's some siting authority. And that's going to help. It's going to be messy, but I do think that will help too.

If I squint one way, we're halfway to a National Transmission Authority. Tax credits and loans and possibly peanut butter cost allocation to spread the money across everyone, and a planning bill that could, together with siting, line everything up under federal leadership

If I squint the other way, we're creating some financial and siting certainty to unleash a lot of capital to allow private lines to develop

I think it leans more towards the NETA, because the private lines are still so constrained.

The NOPR will tell us a lot, about who is going to be trusted to do this. My money is on the utilities.

The EE in me gets this. The system has to keep the lights on.

Transmission mandates create clean energy markets. Will the NOPR and the "offshore wind" planning bill create enough of a mandate?

What's the "right size" for such an extensive government effort? Where is the role for private developers? How do we both protect and bring along land owners and communities in this massive change?

I haven't even talked about undergrounding, and where that fits in. Or how we test it (seriously, I trust no one's $ numbers on this).

I fundamentally do not see a scenario in which this (BIB/BBB) is enough to get us where we need to be re: transmission capacity by 2030. Still too much to figure out and no scalable process. But I don't think that was ever going to be possible due to the complexity.

I'd rather be part of the solution than just pointing out problems. I'm not at FERC and I'm not a lawyer, but I look forward to working on these things with whoever wants to engage.

If I knew Rich Glick was a Babylon 5 fan I'd feel way better about our collective chances to get this transmission stuff right.

https://twitter.com/LizaBevin/status/1454288010741157892?s=20

The thing about planning is that it matters. We won't stumble into a macrogrid, and the way electricity flows has real (and reactive — hey-o!) impacts. We have to plan. an academic study is not a plan. It doesn't consider business models, or land owners, or heuristic frameworks.

But the other thing about planning is that it locks things in. Intimidating given changing technology and outlay of capital. It lays the cards on the table. Groups will know where to invest in a fight to get their way over the planned way, especially in a state siting paradigm.

If I could find one, I'd include a Dr. Strangelove gif here. They'll see the BIG BOARD!

The thing about paying is that no one wants to do it or claim it. Making everyone pay (peanut butter) is "easy" because there's no complex negotiation, but leaving it up to private developers is also attractive because of the hands-off-ness of it.

The thing about permitting is that no one wants a transmission line. Undergrounding still is a significant disturbance and requires a big site for the wide trench. plus the costs. Transmission is disruptive visually and environmentally. But we need it. Period. We need it.

No, I'm not addressing NEPA. The state issues are an issue I know about, and I know very little about NEPA yet

The thing about participation is that it's easy to say but hard to do. Some developers say that cancelled lines were poorly managed lines. Eh, there's a lot at play. Generation siting has faced limitations from state&local law makers, limiting what people can do on their own land

The goal line keeps changing. Plus lots of people think rooftop solar & community batteries will be enough. I just can't see building out what we need w/o incorporating people and working to ensure we're not repeating the least fair choices from previous infrastructure buildouts.

The thing about process is that every region says they have unique considerations that can't be standardized with everyone else. Do you treat wind like solar? mountains like plains? Cities (load centers) like rural areas (generation sources)?

Hard Choices