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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.

We then submitted reply comments in response to comments from other parties seeking to dissuade the Commission from using its authority to define the benefits of transmission capacity and to guide the allocation of transmission project costs among beneficiaries. Our comments clarify that FERC has broad authority to designate particular effects as relevant to transmission planning and project selection, so long as those effects bear on the justness and reasonableness of rates. That authority allows the Commission to prescribe a uniform baseline set of effects that should be considered in transmission planning and project selection, which should include societal benefits and distributional outcomes. These comments also refute arguments that FERC lacks authority to allocate the costs of real but diffuse and difficult to quantify benefits broadly to all beneficiaries.