On May 12, 2022, the DOE released a “Notice of Intent and Request for Information Regarding Establishment of a Transmission Facilitation Program.” Comments are due June 13. Here’s the Federal Register publication:


One aspect that particularly concerns me is focus on NIETC transmission corridors, designated more than a decade ago, 2005 to be precise, and also containing a category of claimed need for “transmission across more than one state or transmission region.” That criteria would apply to almost every transmission project I’ve worked on, although most were segmented (so that the full extent of the project would not be considered or evaluated, DOH!):

What to comment on? Go to the above Federal Register link, and specific issues for comment start on page 6, “Questions for Requests for Information.” However, if you know of issues that should be considered but are not specified, have at it, put it down in detail.

I do get a little paranoid when they request comments on subjects like this — that “barriers to transmission” is one often raised by Beth Soholt, WOW (now as “Clean Grid Alliance” even more directly identifiable as transmission toadies), and here it is:

Comments are due by June 13, and should be sent to the “Federal eRulemaking Portal” (the only option), and must include the “agency name and identifier.” The agency is “Grid Deployment Office, Department of Energy.”

A decade ago or more, our state agencies eliminated consideration and scrutiny of “need” for transmission by making transmission a “regional” and market matter, making state permitting review nothing more than a rubber stamp. There’s never been a transmission proposal that state agencies didn’t love, rubber stamping everything that came their way. Now that fossil is to be shut down, that should free up immense capacity, but you’ll note that that doesn’t ever seem to be in the mix. Even NERC notes that fossil generation isn’t projected to decrease much, and locally, a good example is GRE’s walk-back on their promise to close Coal Creek, and instead “sold” the plant and transmission, and signed PPA to buy the Coal Creek generated energy.

Here’s NERC’s 2021 Long Term Reliability Assessment’s projection of MW of resources, note that coal doesn’t seem to be going anywhere anytime soon:

For full NERC report: https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_LTRA_2021.pdf

If shuttering down fossil is not incorporated into the transmission capacity “need,” exactly what are they basing the “need” claim on? Inquiring minds want to know.

Anyway, do check out the request for comments and let them have it. There are a many specific issues presented that has something for everyone!

Here it is:

PJM 2021 State of the Market Report

Note that where NERC does not project a significant decrease in coal production, PJM’s coal generation increased from 2020 to 2021 (now we do need to keep in mind that 2020 was a very low demand year):

From PJM State of the Market, p. 21

Here’s an overall summary:

The big takeaway is that demand has increased over 2020, which is no surprise. Note the “Average Hourly Load” and “Average Hourly Generation” and compare with “Installed Capacity.” Capacity is essentially twice Average Hourly Load and Average Hourly generation (and note exports and imports are included).

And just for shits and giggles, here’s the PJM LOCATIONAL MARGINAL PRICING MAP!

And here’s MISO’s too:


What it looks like right now in MISO:

Just WOW! Yeah, that WOW too… Today was the meeting of House Climate and Energy Policy and Finance, and check out the presentations:


The good news is that MRES did have challenges to the proposed language in HF XXX/BE133 (Stephenson) Permitting Reform, but aside from MRES, what a bunch of transmission toadies.

Commerce’s Electric Transmission System Report and a PUC Commissioner ADVOCATING for more transmission Presentation-PUC-Updated.pdf, good grief, there’s just no excuse.

More of this?

No thanks…

Needless to say, I should have pushed to get on the list to testify, a letter isn’t enough.

A little holiday gift for my good friends at NSP/Xcel Energy:

The issues I’m concerned about, at this point, are primarily transmission related:

This should be intense, guaranteed, but fun, eh?

First the state court, though there’s that matter of a HUGE bond, and now federal court.

Here’s the Order:


Bottom line:

Given the balance of harms implicated by the parties and the plaintiffs’ likelihood of success on the merits, a narrowly tailored motion for preliminary injunction will be granted with respect to land on or near
federal jurisdictional waters until issuance of this court’s decision on the parties’ cross-motions for summary judgment, which will be fully briefed within a day of the issuance of this order.

From REUTERS (!):

Judge delays construction on parts of $500 mln U.S. power line