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Comments to FERC on Transmission ANOPR

We submitted comments to FERC responding to questions posed in its advanced notice of proposed rulemaking (ANOPR) on transmission reform. We recommend that FERC make significant changes to enhance the transmission planning and cost allocation processes -- changes that address barriers to development of regional and interregional transmission that would interconnect and integrate far-flung but low-cost renewable resources. Those changes would center on how transmission projects are evaluated before being selected for development. Specifically, we argue for using a nationally uniform, forward-looking cost-benefit analysis to guide project selection. We also encourage the Commission to consider prescribing cost allocations that distribute as broadly as possible the costs associated with societal benefits and public goods, like reduced emissions of global and local pollutants and enhanced resilience.