The Niskanen Center submitted comments in response to the Federal Energy Regulatory Commission’s (FERC) July 15, 2021 Advance Notice of Proposed Rulemaking: Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection (“ANOPR”). The ANOPR sought public comment on “potential reforms for longer-term regional transmission planning and cost-allocation processes that take into account more holistic planning, including planning for anticipated future generation, rethinking cost responsibility for regional transmission facilities and interconnection-related network upgrades, and enhanced transmission oversight over how new transmission facilities are identified and paid for.”

The Niskanen Center commends FERC for its forward-thinking approach. We  encourage the Commission to consider a 5P framework (Permitting, Planning, Paying, Participation, Process) and pay greater attention to the Participation and Process aspects of building transmission infrastructure.  While these aspects are often implicit in Planning and Paying, neglecting to explicitly consider them can be to the detriment of stakeholders.  FERC should:

  • Create consistent and transparent processes to reduce uncertainty, transaction costs, and barriers to participation.
  • Include the new Office of Public Participation (OPP) in any actions affecting  transmission planning, cost allocation, and the interconnection queue.
  • Expand participation requirements in transmission planning processes, explicitly expanding the definition of “stakeholder” to engage various community organizations, governments, and other stakeholders. 
  • Establish minimum requirements for how landowners and communities are provided with data and access to ensure the planning process and materials are more accessible to non-industry stakeholders.
  • If FERC determines that more than one independent transmission monitor should be established, it should form a Monitors Council. The Council would identify and provide opportunities for coordination, collaboration, and consistency among the regions to prevent the transmission development process from being further fragmented..

The full comments can be found here.

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