The DOE Wants to Know What You Think About its National Electric Transmission Congestion Study

On August 19, the U.S. Department of Energy issued its long overdue "National Electric Transmission Congestion Study" for public comment.  You're the public!  Serendipity!

I'm not sure what DOE is trying to hide, but I didn't get any notice about this study, although I participated in one of the webinars, and usually get 15 copies of these kinds of notices forwarded to me from lots of different folks when they get them.  Nope.  *crickets*

Maybe it's because I've been engrossed in the project from hell and not paying attention to much else?

Virtual paper cuts be damned, I happened across it the other day while putting together some links for a transmission opposition group.  Serendipity, again!

It looks like the DOE really didn't pay much attention to the comments it received before writing this study.  They still seem to think that we need more transmission to make sure that every electron produced can be used anywhere else, no matter how far from the generation source.

The DOE is supposed to do a triennial congestion study.  That means every three years.  But after it got the stuffing kicked out of it in the 9th Circuit over its 2009 designation of National Interest Electric Transmission Corridors (NIETCs) without properly consulting the states, and without performing a proper environmental review of said corridors, we can understand why DOE is only just now getting around to the triennial study it was supposed to complete in 2012.  It's taken them this long to venture timidly out of their cave.  I'll guess that this "study" is only a tentative foray back into the game, since it states that another study will be completed in 2015, to keep to the original triennial schedule.  It's September, 2014 now, right?  DOE moves at a glacial pace...  Seriously?  What's the point of this year's study?

Anyhow... please do read the 175 page study, paying particular interest to your particular geographic area, or transmission project of concern.

And I'd like to mention a few special things that DOE said in this report that you should be thinking about while crafting your comments.

The first is a particular pet peeve of mine.  Perhaps in my next life I'll finally find time to do the full accounting of the TRUE cost of building new transmission that I've been constructing in my head over the last few years while listening to how transmission proposals affect hundreds of opponents across the country.  Maybe we can start making a dent in it by addressing it here.  DOE says:

Construction of major new transmission facilities, in particular, raises unique issues because transmission facilities have long lives – typically 40 years or more. Evaluating the merits of a proposed new facility is  challenging, because common practices take into account only those expected costs and benefits from a project that can be quantified with a high degree of perceived certainty. This has two effects:
First, it leads to a focus on the subset of cost and benefits that can be readily quantified. Not taking into account the costs and benefits that are hard to quantify has the effect of setting their value to zero in a comparison of costs and benefits.
Second, it leads to projections of costs and benefits that are generally on extrapolations drawn from recent experiences. Projections based only on recent experiences will not value the costs and benefits a transmission project will have under very different assumptions or scenarios regarding the future because they ignore or discount the likelihood of these possibilities. Such a narrow view of the range of costs and benefits that could occur provides a false sense of precision.

Transmission developers are all about tossing made up, speculative, or fantasy "benefits" onto the table in order to make their projects appear to pass a cost-benefit analysis.  But no one has ever quantified the REAL cost of transmission.  I'm not talking about a project's total capital spend, or its annual revenue requirement. I'm talking about the very real costs to landowners who are unlucky enough to be picked to sacrifice their homes, businesses, retirement, health, peace of mind and countless other intangible COSTS for the benefit of the electricity-slurping public in some far off city.  Market value payments for the involuntary sale of transmission right of way only attempt to compensate for the value of the land, not all the other costs to the landowner's way of life that can't be... in DOE-speak... "readily quantified."

Also, the DOE still seems to think that offshore wind is experimental. 

As will be discussed later in this chapter, many states adopted Renewable Portfolio Standards with requirements or goals to use more  renewable‐sourced electricity.
Because much of the best utility‐scale renewable resource potential is relatively remote from the load centers, the states then had to authorize new transmission construction to enable the desired renewable‐based electricity to reach the grid.

Maybe you can give DOE a link to its own map showing the best utility-scale renewable potential located just a few miles offshore, conveniently near load centers?  Quit tinkering, Einstein, and get 'er done!

And how about this? 

Many points of transmission congestion today result from the need to deliver electricity from
changing sources of generation. For example, generation sources are changing because of
state‐mandated RPSs. The best renewable 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. Existing transmission constraints may deter development of these resources. While this is not a challenge in all parts of the Eastern Interconnect, it is a principal cause of evolving congestion concerns in the Midwest.

Maybe you could let the DOE know about the economic benefits that come with LOCALLY-produced renewable energy?  Jobs, tax revenue and economic development happen where renewables develop.  States that buy, rather than create their own, renewables are only exporting their energy dollars to other states or regions and hurting their own communities.

Oh, and let's make this next part a fun scavenger hunt... can you find all the little hidden mentions of the Clean Line projects in this report?

So, what's the point here?  The DOE is going to use this draft and the comments it receives to create the final report.  From that report it may designate National Interest Electric Transmission Corridors (NIETCs).  NIETCs are very bad news, and a stupid idea left over from the 2005 energy policy act (don't ya wish your congress-person would get off their tookus and fix that mess?)

Designation of an area as a National Corridor is one of several preconditions required for
possible exercise by the Federal Energy Regulatory Commission (FERC) of “backstop” authority to approve the siting of transmission facilities in that area.

No.  No.  NOOOO!

So, what can you do?  Read the report.  Write a comment.  Send it here.  Do it now!  Comments are only going to be accepted until October 20.  If you don't participate, no one's going to care what you think later...