The U.S. is in dire need of more transmission — or, at least, more transmission capacity. To achieve net-zero carbon emissions, we will likely need to electrify virtually everything we do that consumes energy, requiring far more electricity and far more grid infrastructure than we have today.^[1] That will require huge increases in renewable energy generation in remote locations that are not already connected to the power grid, in turn requiring substantial new transmission.^[2]

To achieve the Inflation Reduction Act’s full potential and President Biden’s goal of reducing carbon emissions by 50-52% by 2030, experts have estimated that the U.S. may need to triple its existing 240,000 miles^[3] of high-voltage transmission by midcentury, with an estimated cost of $2.2 trillion.^[4] The Biden Administration has paved the way for such dramatic change in three ways. First, last year’s debt-ceiling deal imposed time limits and page limits on environmental impact statements under the National Environmental Policy Act.^[5] Second, the Administration has pledged or catalyzed $8 billion for grid resiliency^[6] and already begun to deploy billions for interstate transmission projects.^[7] And third, President Biden has supported permitting reform that would streamline the path for new renewable generation to interconnect to the grid.^[8]

Perhaps Biden’s biggest support for transmission, however, has come in the form of person-power. In February, the President nominated three new commissioners to the Federal Energy Regulatory Commission (FERC) after more than a year of multiple vacancies.^[9] Although these extended vacancies have not prevented FERC from making meaningful progress on accelerating transmission deployment — as FERC did last year with its landmark Order 2023^[10] — Biden has cemented a Democratic majority on the Commission for the next few years, making further progress more likely. FERC will now have a pro-transmission majority that can take steps, such as last month’s Order 2023-A, that clarify and further implement Order 2023.^[11]

Among Order 2023’s most critical reforms is also the one that most reduces the need for new transmission: a requirement to consider “alternative transmission technologies.”^[12] Within this opaque term falls a group of highly cost-effective innovations called “grid-enhancing technologies” (GETs), which have been proven effective over many years but are not yet widely deployed by any transmission operators in the U.S.^[13] That is a significant problem, because GETs are the best tool for getting more transmission capacity out of the current grid.^[14]

In 2021, FERC Order 881 began a push toward adoption of GETs, mandating use of technology to adjust the allowable capacity of power lines with seasonal weather variation.^[15] And though it was FERC’s best effort on grid resiliency and transmission modernization to date, Order 881 was behind the times even in 2021. FERC could have chosen to require such adjustments by the hour, not merely the season, with a GET called “dynamic line ratings” that is proven and safe — indeed, safer than the current practice of static line ratings.

Beyond their safety benefits, GETs typically save utility ratepayers huge sums while reducing the need to build new transmission by unlocking more capacity from existing lines.^[16] Unfortunately, utilities’ incentive structure in the U.S. primarily rewards new capital expenditures, and GETs, to their credit, are relatively inexpensive to install.^[17] As a result, utilities have little reason to aggressively pursue GETs only to pass on the savings to their customers. In other words, the dearth of GETs on the grid is a perfect candidate for regulatory intervention: FERC has clear jurisdiction and an obvious mandate, and no other body can compel conservative utilities to adopt the latest technology.

For clean energy and climate advocates, the rallying cry must become “Transmission Now!” or more prosaically, “Mandate the Deployment of Grid-Enhancing Technologies to Mitigate the Urgent Need for Transmission Now!” The stakes could hardly be higher. Experts expect capacity additions for the rest of the decade will need to be double the rate in 2023.^[18] Either the U.S. will build enough transmission to bring that amount of renewable power onto the grid and move it to where consumers need it, or we will almost surely miss our climate targets. New transmission lines currently take several years to complete at best, making GETs the linchpin of any strategy to decarbonize the power sector on schedule and keep our climate goals alive. So for FERC, it’s time to GET to work.

 

^[1] See generally Saul Griffith, Electrify (2021).

^[2] See, e.g., Advantages and Challenges of Wind Energy, U.S. Department of Energy, https://www.energy.gov/eere/wind/advantages-and-challenges-wind-energy (last visited Mar. 28, 2024).

^[3] Richard Kessler, US “Ready-to-Go” Grid Projects Could Support Near Doubling of Nation’s Renewables Base, Recharge (Sept. 14, 2023, 4:17 PM), https://www.rechargenews.com/energy-transition/us-ready-to-go-grid-projects-could-support-near-doubling-of-nations-renewables-base/2-1-1517802.

^[4] E. Larson, C. Greig, J. Jenkins, et al., Net-Zero America: Potential Pathways, Infrastructure, and Impacts, Final report (2021), https://netzeroamerica.princeton.edu/.

^[5] Chris Megerian & Matthew Daly, Debt ceiling deal advances pipeline and tweaks environmental rules. But more work remains., AP News (June 1, 2023, 11:31 PM), https://apnews.com/article/biden-permitting-climate-energy-pipeline-b9cc880fbce3ad4f140d6ab71ac9ef0f

^[6] Catherine Clifford, Biden administration to invest $3.5 billion to improve the resiliency of the electric grid, CNBC (Oct. 18, 2023, 3:49 PM), https://www.cnbc.com/2023/10/18/biden-administration-to-invest-3point5-billion-into-the-electric-grid.html.

^[7] Biden-Harris Administration Announces $1.3 Billion to Build Out Nation’s Electric Transmission and Releases New Study Identifying Critical Grid Needs, U.S. Department of Energy (Oct. 30, 2023), https://www.energy.gov/articles/biden-harris-administration-announces-13-billion-build-out-nations-electric-transmission.

^[8] Zack Budryk, Biden administration outlines permitting reform goals, calls on Congress to pass Manchin bill, The Hill (May 10, 2023, 12:48 PM), https://thehill.com/policy/energy-environment/3997948-biden-administration-outlines-permitting-reform-goals-calls-on-congress-to-pass-manchin-bill/.

^[9] See President Biden Announces Three FERC Nominees, Federal Energy Regulatory Commission, https://www.ferc.gov/news-events/news/president-biden-announces-three-ferc-nominees (last visited Feb. 29, 2024); see also Ethan Howland, FERC Outlook: Danly exit could boost transmission reform, but smaller commission poses risks, Utility Dive (Jan. 29, 2024), https://www.utilitydive.com/news/ferc-outlook-2024-transmission-interconnection-grid-reliability-phillips/705562/.

^[10] Improvements to Generator Interconnection Procedures and Agreements, Order No. 2023, 88 Fed. Reg. 61014 (Nov. 6, 2023) (to be codified at 18 C.F.R. pt. 35).

^[11] FERC Affirms Generator Interconnection Rule, Acts on Compliance Filings, Federal Energy Regulatory Commission (Mar. 21, 2024), https://www.ferc.gov/news-events/news/ferc-affirms-generator-interconnection-rule-acts-compliance-filings.

^[12] See supra note 10.

^[13] See John Carey, “Grid-enhancing technologies” can squeeze a lot more power from the existing electric grid, Proceedings of the National Academy of Sciences of the United States of America (Jan. 18, 2024), https://www.pnas.org/doi/10.1073/pnas.2322803121.

^[14] See id.

^[15] Managing Transmission Line Ratings, Order No. 881, 87 Fed. Reg. 2244 (Jan. 13, 2022) (to be codified at 18 C.F.R. pt. 35).

^[16] Richard Doying, Michael Goggin & Abby Sherman, Transmission Congestion Costs Rise Again in U.S. RTOs, Grid Strategies, LLC (2023), https://gridstrategiesllc.com/wp-content/uploads/2023/07/GS_Transmission-Congestion-Costs-in-the-U.S.-RTOs1.pdf.

^[17] Unlocking the Queue, WATT Coalition (2022), https://watt-transmission.org/unlocking-the-queue/ (last visited Mar. 28, 2024).

^[18] Jeff St. John, US climate goals: EVs are on track, but clean power is lagging, Canary Media (Feb. 21, 2024), https://www.canarymedia.com/articles/clean-energy/us-climate-goals-evs-are-on-track-but-clean-power-is-lagging.