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FERC is about to make some very important decisions about transmission

The Federal Energy Regulatory Commission (FERC) is poised to pass new policy that will expand regional transmission capacity, but how impactful will its new rule be? In this episode, grid policy expert Rob Gramlich gives the lay of the land. (PDF transcript) (Active transcript) Text transcript: Davi

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Rob Gramlich Guest

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Episode Summary

Executive Summary: The episode examines FERC’s upcoming transmission-planning rule as a rare federal lever to accelerate U.S. grid expansion. Rob Gramlich argues the proposal is strong but needs tighter requirements on future-oriented planning, holistic benefit assessment, portfolio-based evaluation, cost allocation, and FERC enforcement to overcome incumbent resistance and inertia.

Main Topics: Why transmission planning is central to climate and electrification (Priority: 5/5): The conversation frames transmission as essential for integrating remote renewables, serving rising electrified load, improving reliability, and lowering system costs, while noting U.S. buildout remains far too slow. FERC’s historical role and legal authority (Priority: 5/5): Gramlich reviews decades of FERC orders—from the 1990s through Order 1000—showing that the agency’s authority to require planning has been repeatedly affirmed by courts, even though outcomes have been disappointing. Four needed fixes to the proposed planning rule (Priority: 5/5): The heart of the discussion is the proposed rule’s planning requirements: plan for future system conditions, evaluate all benefits, consider all solution types (including grid-enhancing technologies), and assess portfolios rather than individual projects. Cost allocation and the ‘paying’ problem (Priority: 4/5): Because transmission is a public good, disagreement over who pays can stall projects. Gramlich urges FERC to require a decision-making process that prevents deadlock and better aligns costs with regional benefits. FERC oversight and enforcement (Priority: 4/5): The episode argues the rule will only work if FERC actively ensures compliance, rather than allowing RTOs and other planners to satisfy a formal process without producing real transmission plans. Commission politics and timing (Priority: 4/5): The transcript explains the significance of FERC’s commissioner balance in early 2024, when a smaller commission could still pass a stronger rule, and highlights Chairman Phillips as the key decision-maker. Legislative possibilities beyond FERC (Priority: 3/5): The discussion ends with possible bipartisan congressional actions for inter-regional transmission, including process reforms and minimum interconnection requirements, despite broader legislative gridlock.

Key Arguments: Transmission buildout is lagging badly even though the need for it is widely understood; federal policy must move from encouragement to enforceable requirements. Past FERC orders helped create RTOs/ISOs and planning institutions, but many were voluntary or weakly enforced, allowing inertia and incumbent interests to dominate. FERC’s legal authority is now strong enough to require planning methodologies, not just ask utilities to cooperate voluntarily. Regional planners should forecast actual future load, generation additions/retirements, and electrification scenarios rather than simply react to present conditions. Cost-benefit tests should include the full range of relevant benefits—reliability, resilience, congestion relief, and cost savings—so projects are not unfairly rejected. Planners should evaluate alternatives such as grid-enhancing technologies and reconductoring, not just new rights-of-way and new lines. Transmission planning should optimize portfolios of upgrades and lines together, because the grid is a network and network solutions are often cheaper and more effective. FERC must require a decision on cost allocation; deadlock over who pays should not be allowed to stall needed infrastructure. Active FERC oversight is necessary because rules without enforcement can be reduced to compliance theater. Inter-regional transmission is a separate but important next frontier and may be more amenable to bipartisan legislative action than the intra-regional rulemaking. Consumer interests align with more disciplined planning because current practice can be the most expensive way to serve new load and generation.

Data Points: FERC commissioners: 5 total seats; currently 4 filled, heading to 3 - Used to explain the agency’s decision-making window and possible 2-1 Democratic majority in early 2024 Democratic-Republican split: 2-2 in 2023; likely 2-1 after Danly departs - Commission balance may affect whether the rule is adopted unanimously or by partisan vote Transmission Facilitation Program: $2.5 billion - Infrastructure law funding described as helpful but far too small relative to industry investment needs Build Back Better transmission tax credit: $13 billion scored value - A proposed transmission tax credit that was stripped out, which would have materially eased cost-allocation challenges Planning horizon example: 20 years - Example of how some regions such as MISO and CAISO already model long-range load and generation changes Interconnection queue: 2 terawatts - Referenced as evidence of very large potential generation needing transmission support Typical utility investment cycle: every couple of months - Used to illustrate that $2.5 billion is not transformative for an industry spending at scale

Pivotal Quotes: "planning for the future" — Rob Gramlich: Summarizing the first and most basic requirement FERC should impose on regional planners "regional planning involves no regional planning" — David Roberts: Reaction to the claim that many transmission entities do not actually forecast and plan for future system conditions "The rule only matters if there's some stick, some element of enforcement." — Rob Gramlich: On why FERC oversight must be more than a paperwork exercise

Implications: If FERC strengthens the rule, the U.S. could finally shift from passive, utility-driven transmission decisions to proactive grid planning that supports clean electrification. Weak enforcement would likely preserve slow buildout, higher costs, and missed climate targets.

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