DOE's initial attempts ran into a buzzsaw of opposition that ended up in two separate federal court decisions that effectively castrated Sec. 1221. But, hey, that Sec. 1221 mandate still exists, so DOE must still go through the motions.
And that's what they did, albeit 2 years past the 2012 due date. The DOE secretly opened their "draft" congestion study up for public comment (never mind the contradiction of a secret opportunity for public comment, we won't dwell there).
The public commented -- nearly 100 comments panning the report and warning against designation of any new NIETCs were submitted by interested "stakeholders."
But, a handful of industry players also found out about the secret study and submitted comments. So, let's take a look!
Utilities SDG&E, Southern Co., Duke, and Florida Municipal Power Agency filed self-serving comments about their own service territory, either pointing to "congestion" where they want to build lines, or cheering a DOE finding that there was no congestion in their region.
Regional transmission organizations Southwest Power Pool, NY-ISO and ISO-NE also filed comments. The general gist of their comments was that RTOs already have robust transmission planning processes and power markets that make DOE's congestion study a frivolous and unnecessary duplication of effort. And then they resorted to redline editorial corrections. I did get a kick out of ISO-NE's correction to add offshore wind to DOE's narrow resource focus:
The best onshore renewable wind resources (i.e., those with the highest potential
capacity factors) tend to be located far from load and sometimes in areas with less
transmission than desired for effective resource development. The best offshore renewable wind resources, however, are often located close to load centers, as is the case with New England.
Edison Electric Institute (EEI), the investor-owned utility lobbyist organization, told DOE to forget all about that NIETC stuff and to spend its time finding ways to streamline transmission permits on federal land. Yes... that's just what's missing from America's National Parks -- more and bigger transmission lines! Just think how sweet the Grand Canyon would look with a couple of huge transmission lines spanning it at its widest points! And wouldn't Old Faithful be much, much cooler if it erupted into an overhead transmission line and created even more steam and maybe an electric arc or two? Yeehaw.... idiots!
WIRES, the transmission developer's lobbying group just seems to want to get its paws on a whole bunch of congestion data. If DOE can't find or easily gather this data for WIRES's use in proposing competitive transmission projects, then WIRES thinks the DOE should pursue new legislation to obtain it, no matter how much providing this information burdens other utilities.
The American Wind Energy Association and Next Era Energy want DOE to allow transmission developers to do their own "congestion studies" and apply to DOE for designation of narrow "corridors" just wide enough for projects they want to build. That's just ridiculous!! A version of this bastardization of Sec. 1221 was proposed several years ago, and was promptly disposed of by Congress. Not a good idea! DOE doing this study and designating corridors is bad enough without throwing wide the door to self-serving "studies" and corridor requests inspired, not by need for new transmission, but by corporate greed.
And speaking of corporate greed, I've saved the best for last. As expected, our heroes at Clean Line Energy just couldn't be left out of a process where it may benefit by using the government as its own personal land agent to take what it isn't granted by individual states.
Clean Line makes a bunch of obsequious comments that really don't do much but promote its own projects and display their self-centered stupidity.
Clean Line made much of this diagram:
All of Clean Line’s projects originate in a Type 1 Conditional Constraint Area, identified by DOE in the 2009 National Electric Transmission Congestion Study (“2009 Congestion Study”) and illustrated in Figure 2. The 2009 Congestion Study defined a Type I Conditional Constraint Area as, “an area where large quantities of renewable resources could be developed economically using existing technology with known cost and performance characteristics – if transmission were available to serve them.” The 2009 Congestion Study also noted, “Construction of major new transmission projects would enable development of thousands of MW of new renewable generation” within these areas.
Clean Line tells a HUGE lie:
Clean Line has engaged with thousands of local stakeholders in eleven states, where its five projects are actively under development.
Clean Line rumbles on about demand for its projects from unbuilt wind generators. Note, Clean Line doesn't mention any interest from load serving entities, most likely because there isn't any! And Clean Line's price for "all in" delivery includes the production tax credit that expired LAST year.
Clean Line even elects itself to speak as a champion for you struggling farmers!
These are real projects, many of which have land leased for wind turbines from
farmers seeking new sources of income, as drought has made traditional farming livelihoods uncertain. Wind power represents new hope for drought-resistant income and economic development in regions of the country otherwise struggling with diminishing populations.
The next step is for DOE to "review and consider" comments on the draft study, and to prepare and release a final version of the study. Watch this website, because it's likely to be another secret public process from our taxpayer-funded U.S. DOE!