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:


David Roberts


By now, it’s fairly well understood that the US badly needs more
electricity transmission lines to keep up with the changing
generation mix and growth in demand that will come with clean
electrification. But new lines, especially the much-needed
longer-distance regional lines, are being built at a snail’s
pace. If the US is to hit its mid-century climate goals,
transmission capacity expansion must radically accelerate.


Congress helped a little with money in the infrastructure bill,
and the Biden administration helped by establishing a Grid
Deployment Office inside the Department of Energy, but arguably
the biggest opportunity for progress comes in the form of an
upcoming rule by the Federal Energy Regulatory Commission (FERC).


It will beef up the commission’s existing rules on regional
transmission planning, but exactly how much it will strengthen
them depends on the final rule, expected early next year.
Transmission advocates are urging FERC to pass a rule with reel
teeth — including Senate Majority Leader Chuck Schumer, who sent
the commission a letter with encouragement and suggestions in
July.


Nobody knows more about grid policy than Rob Gramlich, founder
and president of Grid Strategies, a policy analysis and strategy
firm. He is executive director of the WATT Coalition, co-founded
and used to run Americans for a Clean Energy Grid, serves as a
board advisor to a half-dozen other groups, and has a long
history in the industry, including a stint at FERC in the early
2000s.


I talked with Rob about the current state of affairs in
transmission policy, the scope of FERC’s authority, and the
details that matter in the coming rule. Don’t let the
technical-sounding subject scare you off — this was a fun one,
and incredibly clarifying.


Okay then, with no further ado, Rob Gramlich. Welcome to Volts.
Thank you so much for coming.


Rob Gramlich


Thanks, David. Great to be here.


David Roberts


I am excited to talk about this. I know that perhaps FERC is not
at the top of people's mind when they think about excitement and
thrills, but I think people will see by the end of this why this
is a very good time to tune in to what FERC's doing. So let's
start here. I think we can assume for the purposes of this pod
that Volts listeners understand the need for more transmission,
specifically the need for more long-distance transmission for a
bunch of reasons. We know that the resource mix is changing. We
care more about renewables now.


They're located in different places. They're located not
necessarily next to load. They're remote. We're going to double
or triple the amount of electricity we're using in the coming
years, because we're electrifying everything. So we need more
transmission for that reason. We know that connecting up a wider
geographical area makes the whole system more reliable, makes the
whole system cheaper. Transmission is the wonder tool of energy.
It makes everything better, and yet we are not building it. So
back in the late 90s, FERC, the Federal Energy Regulatory
Commission, which has jurisdiction over interstate transmission,
released a series of orders.


So in the beginning, there were, just across the nation, just
dozens and dozens of individual vertically integrated utilities,
all of which were building their own transmission, more or less
for their own areas. And so back in the late 90s, FERC saw this
and many other people saw the need for more interregional
transmission and issued a series of orders trying to kind of
nudge things in that direction, doing, among other things, they
created regional transmission operators and independent system
operators, RTOs and ISOs, which were supposed to be regional
organizations that did regional transmission planning. And there
were others too, I think, going all the way up to 2011, there
were other orders, basically like, "please friggin utilities, get
together and start doing some planning, do some interregional
planning." And yet, despite this series of orders, and despite
the existence now of RTOs, we're still not building interregional
transmission.


I mean, we're building it at a snail's pace and not necessarily
where we need it, and certainly nothing close to the pace we need
to be building at. So maybe let's just start here. Why, given the
existence of RTOs, which are explicitly supposed to do this, is
there still not adequate regional transportation planning? Maybe
you could run through the three P's here. That's going to help
kind of set us up for what's to come.


Rob Gramlich


Sure. Well, first of all, thanks for your help in communicating
all that. So let's stipulate that the need for transmission is
understood. And that's great that it is, because a few years ago
it wasn't. But you've been helpful.


David Roberts


It does seem like that at least has sunk in, in the wider world.


Rob Gramlich


I think that's right. And of course, in recent years, it's been
more sort of the climate-focused policymakers and community who
have understood this, which is great, as they should, for the
incredible clean energy need for transmission and climate
benefit. But just suffice to say, it wasn't always such a
democratically tilted issue. But that's a separate conversation
we could get into. But, yeah, FERC has been, in the 90s, the
early 2000s, had orders trying to beg, plead and borrow the
industry to get going on regional transmission. And in fact, it
goes even way back. I mean, the 1935 Federal Power Act itself has
some language about the voluntary, encouraging the voluntary
coordination of the systems.


And then there were actions in the pre-war and wartime to be able
to produce the military assets and airplanes and everything by —
we needed to increase the production basically out of the
electric industry.


David Roberts


Yeah, it's a bummer. We decided to build this interstate road
network basically for security purposes around then, and did not
decide at the same time to do the same thing for transmission. It
would have been a good move on our part.


Rob Gramlich


That's right. But there were actions by the predecessor to FERC,
the Federal Power Commission, during those same years, though,
trying to strengthen the connections, but it only went so far.
And then it was really when the electric industry tried to
restructure to get generation competition in the 90s that it
started pushing harder. There was a 1993 regional transmission
group RTG policy statement, and then they said, well, that's not
enough. And then they had Order 888 for open access transmission.
That included a push for voluntary creation of independent system
operators. That's where that term really came into practice.


It was encouraged and voluntary. And then the commission tried in
1999 to require participation in the regional transmission
organizations (RTOs). That's where that term was sort of defined.
But Chairman Hoecker, at that time, couldn't quite get the votes
to make that mandatory — so it was voluntary. And then I was part
of — my full-time job was standard market design. I'm not
embarrassed to say that one never made it to being even a rule
because of a political backlash. Again, another story for another
day. But that was at least strong encouragement. And then Order
890, when Republican Chairman Joe Kelliher came in, he had been
on House Energy and Commerce and in the Bush administration, and
he tried to require, well, he did require through Order 890, some
strengthened planning requirements.


And then Chairman Jon Wellinghoff issued Order 1000 and the
commission, of course, in 2011. And that also sort of went
another step further. In this process, some of those orders were
challenged in the courts. Then FERC's hand was actually
strengthened after all of that because the court challenges
upheld FERC's authority and said, "absolutely, you can require
transmission planning." So FERC's role here has only been
strengthened over the years in terms of the clarity of its legal
authority. And yet, as you say, it hasn't really worked yet. So
here we are at the end of 2023 with an agency that actually is in
charge of this and has quite clearly been claimed by the courts
to be the one entity that can really do this in a significant
way.


And it's actually kind of exciting now, because look at this, we
have this great proposed rule that Chairman Glick and the
commission issued a year and a half ago —


David Roberts


Well, before we get to that, though, I want an explanation for
why those previous ones didn't work. Like why aren't RTOs
building these things?


Rob Gramlich


Yeah, there are probably a few reasons.


David Roberts


Yeah. In like 100 words or less. Because we can't get too bogged
down in this, because I know this is a tar pit.


Rob Gramlich


I'll try to just give you a few. Look, I mean, one issue is
incumbent generators don't necessarily want to enable new
generation to come onto the grid. So we have these RTO entities,
incumbent generation owners, whether they're part of a utility or
independent, they are usually not the strongest supporters of new
transmission. So that's a factor. And then those entities are
active in FERC proceedings as well. That's one factor. Another
factor: We had all this transmission collaboration happening in
2010 through 2013, and a bunch of transmission got built. We
actually got a ton of new renewable energy connected to the grid
a decade ago.


From these, I'm sure many of your listeners know about the
multivalue projects in the Midwest and Texas competitive
renewable energy zones. So there was a little bit of a
renaissance then, but then it was very short lived, and it ended
like ten years ago, it stopped. Some people say Order 1000 had
some unintended consequences that stopped that. I think that's
part of it. Also, the cost of solar dropped and the cost of gas
dropped, so a lot of that transmission was more wind driven. And
when you could do a lot of gas and solar, you didn't need quite
as much transmission.


So I think that does factor as well. And then I just sort of
think, like, inertia took over. People got used to going to
regional transmission planning meetings and making sure nothing
actually happened, and they got good at eating muffins and
checking the compliance box, but then not actually doing
anything. So, I think it's just ripe for a whole reshuffling. And
that's what FERC can do.


David Roberts


Okay, so before we get to this FERC opportunity, let's at least
give a little shout out to some movement lately, some policy
wins. So in the Infrastructure Act, the Bipartisan Infrastructure
Act, there's some money for transportation, which I think is nice
but inadequate. And then there's this new Grid Development
Office. Are those the two biggies, and how sort of like a big of
a deal are those, relatively?


Rob Gramlich


Relatively, yeah, potentially over time. The Grid Deployment
Office could be huge, and it's off to a great start. I will say
the current team there and the current administration and
Secretary Granholm are leading, I think, a very productive and
promising exercise there.


David Roberts


Was that created by legislation, or was that just created by an
executive action?


Rob Gramlich


Technically just an executive action by Secretary Granholm. She
can set up offices, if she so chooses —


David Roberts


As an office within DOE.


Rob Gramlich


That's right, which — put this on your list of future policies.
Let's actually formalize that in legislation. It would be nice to
do that, but there was actually an attempt. But that's a longer
story. But that office has financing tools, it has permitting
tools, it has capabilities. They've been hiring like crazy,
really good people, and that could really be a very helpful
enabler of transmission, private sector investment. There's no
shortage of capital that wants to invest in this sector, but it's
just a morass trying to get projects done. So DOE has important
tools. Many of them are now kind of all being consolidated in
this Grid Deployment Office to enable transmission.


David Roberts


And what's the money in the Bipartisan Infrastructure Act?


Rob Gramlich


Right. Well, very little, unfortunately. I mean, there's like one
really great provision called the Transmission Facilitation
Program. Senator Cantwell introduced that, but it's a $2.5
billion program, and it's not technically a loan, but it's sort
of like a loan. It does have to be paid back, and so it's not
really that much money. It's intended to be a revolving fund, but
$2.5 billion in the scheme of an industry that spends that every
couple of months is not transformative.


David Roberts


And there was, at one point in the Build Back Better saga, a
pretty hefty tax credit for transmission, which got stripped out
at some point. That would have been serious money, right?


Rob Gramlich


That could have been serious money. It's scored at 13 billion.
But who knows? The way tax credits work is if the industry really
gets excited, it's uncapped. And more could have been done, so
that could have been great. And it's so hard to figure out who
pays for how much. Just starting to evolve into the three P's,
planning, permitting and paying that paying part is, I think, the
hardest, because it's a public good and everybody benefits some,
so nobody wants to pay for it. And so that tax credit could have
at least made that whole problem 30% easier by covering 30% of
the investment cost.


David Roberts


Right. So then you're having to allocate 70% rather than having
to allocate 100%. And we'll get into that cost allocation in a
bit. So we've had some movement, but inadequate, and there is
some legislative stuff that would be relatively easy and high
impact. And maybe when we get through this FERC stuff, we can
touch on that before we're done. But now, in terms of the tools
Biden has to use here, well, not even Biden, really, since it's
supposed to be independent. But in terms of federal tools,
basically we're dealing with FERC. So before we jump into the
proposed rule, let's just talk for a second about FERC.


As I understand it, there are supposed to be five commissioners,
ideally. There are, in fact, four, and we're heading to three.
So, make some sense of all that for us. Where are we with FERC in
terms of the balance of commissioners?


Rob Gramlich


Yeah, that's right. There's supposed to be five, no more than
three from one party. So over the years, it's typically been
three-two, one direction or the other.


David Roberts


Right.


Rob Gramlich


And Chairman Glick, his term expired, and so he is off. And that
seat is open. Commissioner Danly, his term ends, well,
technically, June 30.


David Roberts


So, wait, Glick is gone, which left a two-two Republican-Democrat
split. That's the current state of affairs?


Rob Gramlich


That's the current state of affairs, as we said. Yes, for, I
guess, the entire year of 2023, it'll be two-two.


David Roberts


Right. And then Danly, who is a Republican, is stepping down
when?


Rob Gramlich


That's right. So, yes, every year one seat opens because they're
staggered five-year terms. So he will need to leave by the end of
2023 in a month or two.


David Roberts


Got it. Which will leave a two to one Democratic majority on FERC
and those other two — we don't have to get into this, but what
the hell is going on? Why is it taking so long to get new
commissioners? Is it Joe Manchin? I'm just going to throw it out
there. I'm just guessing. Is it Joe Manchin?


Rob Gramlich


Well, I mean, certainly he's the chair of the committee and he
has strong preferences that he expressed both on existing
commissioners and potential new commissioners. And the White
House technically gets to — you know, the two of them have to
agree, the president and Senator Manchin, but also the history
and the tradition — the practice is sort of often one party will
pair with the other party, so you'll do two together, and there's
just been just a lack of activity. I'm not actually sure either
party. I'm not sure the president or McConnell or Barrasso or
Manchin. I'm not sure any of them are like, hustling or feel a
need to hustle to get a lot done right away.


I think they all recognize, like in 2024, when you're down to
three, then you really can start having problems. Like, you might
not have a quorum just to get business done. Somebody might have
a cousin who, one commissioner might have a cousin who works for
a company, and they get recused from the case and you can't vote
the order out, and it gets dicey like that. So just when
situations like that arise, the Senate Energy Committee, knowing
it's their responsibility to make sure business can get done at
FERC, they'll get more active. So I do expect in early 2024 they
will get active.


There seems to be a name that Manchin and the White House agree
on. There could be a pairing. There could be somebody that
McConnell and or Barrasso recommend from the Republican side. But
I think everybody's kind of holding their cards close right now.
There's not a lot of —


David Roberts


And that could take a while. So what's relevant for us here, I
think, is if this rule is, the rule that we're about to talk
about is advanced expeditiously, it could be voted on by a
three-commissioner FERC, with a two to one Democratic majority,
meaning it could be made good and strong and get through with
Democratic votes.


Rob Gramlich


That's right. I mean, the order seems close to ready. They wanted
to do interconnection first. We could talk about that, but that
was a major undertaking, one of the biggest orders ever. And so
Chairman Phillips had to sequence things one way or another.
Couldn't do them all at once. So that happened first. They seem
to be getting close to ready on this big planning rule. And so I
think early in 2024 they'd be ready to do that. It will be a two
to one at that point. But everybody in FERC world likes to not
talk about it in partisan terms.


David Roberts


Of course, or pretending.


Rob Gramlich


Well, the proposal did issue as a unanimous bipartisan proposal.
So the hope is that it would be a three to zero and it could be.


David Roberts


I mean, let's just say there's no obvious reason that this should
be partisan at all. It's literally good for everyone, except
maybe some utilities. It's good for society. Name your entity.
Bipartisan would be nice. But should that fail, it could still
get through. So tell us a little bit about this planning rule. It
dates back to 2021. It was a Glick joint originally.


Rob Gramlich


That's right, yeah, so Chairman Glick and his team really led the
development of it. The other commissioners were there,
Commissioner Clements is the other Democrat on the commission who
I don't think we mentioned yet, and she's very supportive of the
rule. And then they had this extensive process with the states.
That's part of why it's taken a lot of time, which is, I think,
great and very helpful. But there's this incredibly extensive
record of discussion with states on how this works through this
joint federal-state task force. So it has been out there for now
18 months. And again, we had commissioners transition and a chair
transition and other big orders that the commission had to get
out, but I feel like it's ripe now and good and close to ready.


David Roberts


One other preface question. So I saw that Chuck Schumer, Senate
Majority leader, wrote a letter to FERC recently acknowledging
the importance of this rule and giving some recommendations for
strengthening it, recommendations that, as far as I can tell,
were lifted more or less straight from this report you wrote last
year with recommendations, and we're going to go through some of
those recommendations. But is it the case that the current order,
as it currently exists does none of these things and that's why
you're recommending all these things? Or so it's unclear on how
strong the extant order is and how much of these recommendations
— you know what I mean? Where is it now?


Rob Gramlich


Yeah. So many things are great about the order. It has all the
right analysis, I think, and record evidence and support from a
really vast majority of the industry, including utilities and
consumer advocates and the whole range of stakeholders who care
about these things. And the proposed rule is generally, I think,
excellent. And I think Chairman Glick is going to be commended or
should be commended for that, as well as the other commissioners.
But there were a few things that somehow ended up a little bit
weak in the proposal, and I don't think, accomplished what the
commission thought it was trying to accomplish.


Now, there's a lot of cooks in that kitchen, and the
commissioners don't talk about internal deliberations. So one can
only on the outside kind of guess what happens on the inside.
Where I used to be there walking up and down the hall trying to
negotiate orders like this. But sometimes you can guess because
the commissioners make public statements about what they like or
dislike or what they would want to see in the final rule. But I
thought that letter you mentioned from Senator Schumer did an
excellent job of saying, "hey, here's a few things you really
need to fix to make this thing do what you say it does."


David Roberts


Yes, let's walk through some of those. So there's sort of three
buckets here of recommendations. One is about planning what to
require in terms of interregional planning. There's some stuff
about cost allocation, paying the planning and the paying —
permitting, I think is separate and will have to be dealt with
separately. And then there's stuff on basically making sure the
process is cost-effective with a little bit more FERC oversight.
So we're going to walk through all those. So in terms of
interregional planning, there are four specific recommendations
about what to require of the planning process. So let's walk
through those.


The first is just maybe do your planning based on what you
actually think is going to happen to the electricity system,
forward looking rather than backward looking. Just tell us a
little bit about that.


Rob Gramlich


Yeah, that's right. And by the way, the rule really is more
intra-regional than interregional. They're going to do,
hopefully, they'll do interregional separate, but they bit off
the intra-regional.


David Roberts


Oh, so this is planning within regions.


Rob Gramlich


Right. As a first step. But honestly, everything in here could
equally be applied. You could just a year later come through with
a redline — global search and replace intra with inter. And it's
all the same, things would work. But let's focus on the regional.
And these are wide regions of the country, you know, the whole
Midwest, the whole mid-Atlantic. The west is in three areas, but
could be one merged together. There's discussion about that. But
at any rate, yeah, the planning requirements. And again, the
courts have said, FERC, you've got very strong authority to
require planning practices, whether you can actually direct the
outcome, like plan for this or that outcome.


That's sort of untested. But in terms of planning methodologies,
absolutely FERC, go for it. So they issued these planning
methodologies and the first one, as you say, is essentially plan
for the anticipated future resource mix. If you're going to plan
—


David Roberts


I had to read this section a couple of times. I'm like, "they're
not doing that?!" What else would you do?


Rob Gramlich


You would think that if there are these organizations around the
country with regional planning in the name of the organization
and in their charter of what they're supposed to do, as well as
departments called regional planning and people with regional
transmission planning in their title, you would think you would
be forgiven if you thought, "oh, these people plan," which by any
definition means like preparing for the anticipated future.


David Roberts


Right, right.


Rob Gramlich


Well, that is not actually what happens. So in most of the
country, they really don't do any kind of long term, they don't
do an estimate of what the future resource mix is going to be.
And I'm talking about load and generation and retirements and
additions and all these sort of macro categories of the things
that change on a transmission system. And by the way, it's not
like saying, "oh well, the president wants to decarbonize the
system by such and such amount, by such and such a date,
therefore everybody do that." No, it's not even saying that.


It's just saying "regional planner, you and your region
anticipate these changes, these additions, these subtractions,
these load changes, and then plan for that."


David Roberts


So the critique is not even that your forecasts are inadequate or
that your forecasts and modeling are flawed in some way, but just
that they're literally just not —


Rob Gramlich


ONot doing it.


David Roberts


doing at all. Right, that's a little crazy. Seems like an
entirely reasonable request that when you're planning, you
anticipate what's to come. And especially, I think this is
implied, but let's just state it, because we're in a period of
incredibly large scale rapid change in that very system, in what
sources are coming online and retirements are accelerating all
this growing load because of electrification, et cetera, et
cetera.


So it's just crazy that your regional planning involves no
regional planning.


Rob Gramlich


Exactly right. And that's a striking thing about the official
record evidence in this case of like so many, I mean, scores of
utilities in states came in and say, "yeah, we basically think
all these changes are happening and we need to plan for them."
And those entities, states and utilities and others come from a
variety of political perspectives about whether they want those
changes to be happening faster or slower. But they all kind of
acknowledge some baseline. And of course I'm sure in the details
their estimates are different, but they're all pretty much in the
ballpark and directionally all entirely consistent, that, for
example, there's just going to be dramatic wind and solar and
storage growth in every region, and that's when it's in the
interconnection queue and every other evidence of what the
changes are going to be.


So there was a remarkable alignment in the record about the
changes happening that need to be planned for. And so, yes, first
and foremost, if your listeners have to shut off the podcast now,
please don't. But that's the number one, just very basic thing
that this rule would require.


David Roberts


Number one requirement for planning process involve planning.


Rob Gramlich


Right. Plan for the future, right. It seems radical, but yeah.
Planning for the past — no, no, don't plan for the past — we're
planning for the future. Radical idea.


David Roberts


So then number two is consider all the benefits holistically. To
say a little bit about sort of like what current practice is and
what that would mean.


Rob Gramlich


Transmission has multiple benefits. There's reliability,
resilience. It reduces congestion on the grid, which is sort of
the day to day cost that consumers have to pay when you have to
ramp up expensive generators because of transmission constraints
—


David Roberts


Or curtail solar.


Rob Gramlich


Or curtail wind and solar, absolutely. And it's very hard to
often separate out all these benefits. I mean, you build
transmission for one purpose and it has all these other benefits
for other purposes. Well, this is where the proposed rule got
kind of weak. It sort of, here's all these benefits. But then it
kind of goes back through and says, "well, those are sort of
optional.


You can look at this one or that one. It's sort of up to you."
Well, the problem with that is that's not a regulatory
requirement. That's just giving — based on the power structure of
a region. If they choose not to do any of this stuff, it's giving
them a get-out-of-jail-free card to not do this, to say, "well,
we're just going to pick and choose our benefits." And what
happens is it's like if you think of a really basic benefit cost
analysis, if you're allowed to say, "well, I'm only going to
consider one of the four or five or more types of benefits
compared to all of the costs," you're almost guaranteed to not
have the transmission lines pencil out.


David Roberts


Right.


Rob Gramlich


It's sort of like if you bought your car only for the basis of
its benefit to drive to the grocery store, but not all the other
reasons you use a car, you're probably not going to buy a car
because it's not worth it just for that.


David Roberts


And also, let's just say there was nothing in place preventing
them from considering these benefits. So telling them
voluntarily, you may consider these benefits like, yeah, they
could have been considering these benefits and they aren't. So
clearly there's a reason they aren't, so clearly they need to be
pushed to do it, not just allowed.


Rob Gramlich


Exactly. Right. So what's the point of a federal rule if it's
just an encouragement to do what you're able to do before?


David Roberts


Right. So this would be a requirement that in those cost benefit
analyses run on a particular transmission project, that all the
benefits of the transmission project, including resilience,
emission reductions, reliability, cost, et cetera, all be put on
the benefit side of the ledger.


Rob Gramlich


Yes, that's right. Now, in the details, there are some issues.
FERC didn't even go into a carbon benefit or any number of
benefits you could get to that are sort of a little bit outside
of normal FERC Federal Power Act jurisdiction. And without going
too far into this, there's a little bit more that FERC can sort
of allow and accept from regions as opposed to what it would
require if it's doing a nationwide rule. So again, what I'm
suggesting and what a lot of different clean energy and
environmental groups suggested is very modest in terms of just
doing the basics within traditional FERC regulatory domain about
reliability, resilience, and congestion cost, traditional
economic regulatory things that couldn't be misconstrued as
making FERC be an environmental regulator for the country.


David Roberts


Right. So, require the basics and then maybe allow extras like
emission reduction. So that's number two, consider all the
benefits. Number one, plan. Number two, consider all benefits.
Number three is when you are looking for solutions to congestion,
etc., consider all the possible solutions. So a new transmission
line is not the only possible solution to the problems solved by
transmission lines. So, explain that one just a little bit.


Rob Gramlich


So, there are different technology options that are available
today, which is great. There are grid enhancing technologies, and
I know you had a recent podcast on that.


David Roberts


Volts listeners are familiar with these ways of getting more
throughput from existing transmission.


Rob Gramlich


So, I recommend going there. And so those technologies were
recommended. A little bit of back and forth about the exact list.
Hopefully, that turns out in a good place to consider all those
technologies. So that's kind of the category of like squeezing
more out of the existing wires. And then another category is new
wires. There's new types of conductors, high-performance
conductors, I call them.


David Roberts


That's called reconductoring existing lines. That's what that's
about?


Rob Gramlich


Yeah, that's one way to do it where you can just put a different
wire on an existing tower, or you can take the towers out and put
a different type of maybe bigger, heavier cables. You can have
superconductors, you could have composite core. There are
different opportunities for that. So there's conductors as well,
and then more broadly, there are just other technology options.
And so FERC proposed these, and I think various parties are just
trying to make sure that the commission requires full
consideration of these technologies, in part because, look,
nobody wants to have to go to new rights of way when you don't
need to.


David Roberts


You say maybe like from a social perspective, we don't
necessarily want to do new rights of way because they're
difficult and they take a long time. But it's worth saying here
that the utilities, the reason this needs to be made mandatory is
that the utilities make money by spending money. Right. This is
something I come back to over and over again. Like from a
utilities perspective, they get a big rate of return if they
build a brand new transmission line, whereas some of these other
technologies, I think, fall under kind of maintenance costs that
they don't get a rate of return on.


So this is one of those areas where utilities probably prefer
building more hardware when there are alternative solutions that
could avoid the need to build that. Is that accurate?


Rob Gramlich


That is an issue. There are a lot of utilities that are doing a
lot of great stuff on their system, but it's also true that this
is a regulated monopoly industry. There's a reason we have
economic regulators, and their job is to ensure that we get
reliable service at affordable, just, and reasonable rates. And
the reason we have this whole regulatory system is because the
incentives are not aligned with consumers' interests if left
unregulated. And so that's just sort of what regulators are
supposed to be doing. And they're supposed to make sure, and they
do this at the state level and the federal level, they're
supposed to make sure that the right technology is deployed and
it makes sense to get that reliable service at a reasonable rate.


So consumer interests are very persuasive and important at FERC
on this. They want to make sure, particularly because a lot of
these are very low-cost technologies. They want to make sure that
these technologies are deployed in the right way at the right
time. I think a lot of the folks communicating with FERC feel the
same way. And again, from those who are concerned about land use
have the same type of concern. They don't want to disturb
previously undisturbed land with new rights of way if they don't
have to. So this is where these technologies can really come in
and help maximize what we get out of existing rights of way and
existing transmission assets.


David Roberts


And so then the fourth, and this, I think, is a little bit more
to wrap your head around. The fourth is that these organizations
should select, rather than doing these cost-benefit analyses one
at a time on proposed projects, FERC should require them to work
on a portfolio and to do the cost-benefit analysis basically on
the portfolio. So instead of choosing an individual project to
maximize benefits, you're choosing the portfolio that maximizes
net benefits. Is that accurate?


Rob Gramlich


Yeah, that's right. There are a lot of efficiencies there that
can be uncovered when you look at all the transmission options
and configurations together and find the right portfolio or the
right suite of upgrades. There could be just a substation
expansion or upgrade that solves a problem more efficiently than
a new line would. Or when you put some technologies along with a
substation here and reconductoring over there and a new line over
there, the portfolio has a lot of efficiencies because it is a
network. The whole thing is an integrated network. So treat it as
a network, plan it as a network.


And so that's kind of another sort of best practice transmission
planning feature that historically — I mean, if you ask the
planning engineers from 50 years ago, when we actually planned
big transmission before, they would say, "of course, we do that.
How could you do it any other way?"


David Roberts


This is another thing that, like, "duh" —


Rob Gramlich


Right.


David Roberts


Okay, so to just summarize here in the planning portion of these
recommendations of this upcoming rule number one, plan for the
future actually forecast what's going to happen and plan for
that. Number two, consider all the benefits, not just singular
benefits, not just the benefits you pick and choose three,
consider all possible solutions, not just new lines, but also new
ways of getting more of existing lines. And then four, apply all
this to portfolios rather than individual projects. So you want
considering all benefits and all solutions to different
portfolios so that you can maximize the aggregate benefits of
this.


All of those, as you say, seem like things that are obvious and
that anything going by the term regional planning would already
be doing, but it is not happening. And so, FERC has an
opportunity here to basically require RTOs to do this. So that's
the big planning section. And that, I think, is the main event
here. Those four alone, I think, would be transformative. But
then we come to the second knot of the planning-paying-permitting
Troika, which is cost allocation, which is a kind of
unnecessarily technical term for just if you're going to build a
regional transmission line that crosses boundaries from one
utility to the next, from one state to the next, that crosses
over all these lines, it is not obvious how to pay for it, or
rather, who should pay for it.


Who should pay for these lines? Is it the people building them?
The people who will benefit from them? And right now, the loose
rule is roughly people should pay according to the amount of
benefits they get from it. But this is not, like the rest of the
process, working very well. So tell us a little bit about how
FERC should be trying to tweak cost allocation to work better?
And is part of this just by having a formula or some sort of cost
allocation formula that can be applied to every project rather
than kind of like a bespoke process for every line?


So just talk a little bit about cost allocation and how FERC's
trying to solve it.


Rob Gramlich


The basic problem is, as you say, it's essentially a public good.
Everybody benefits to some extent. And like with other public
goods, classic public goods, like national defense or bridges and
roads and public transportation, everybody would rather have the
other guy pay for it and get to use it. And that's just natural.
And that's why we have usually public financing right through our
taxes, all of those things. Now, the electric industry is
different, and it's generally a private industry, not public. And
FERC isn't about to completely change that, nor is there really
reason to. But we just have to figure out a way to allocate the
costs in a fair way, just to make sure that sufficient
infrastructure gets paid for so that it can be built.


So that's why we have this challenge called cost allocation and
one of the three Ps, the paying part of the three P's. So FERC's
main need here and proposal here is to make sure that a decision
gets made. Okay. It sets up like a process at the regional basis
where the states get a chance to weigh in and figure out a
solution. And hopefully that leads to agreement on how to
allocate the cost of a transmission plan. Maybe they'll decide to
have one formula that stays in place for all time, or maybe
they'll review it based on each plan every couple of years when
it comes through.


But the risk now, if FERC doesn't clarify this in the final rule,
is that if they don't agree, it just gets stuck. Well, that
obviously doesn't solve the problem or get infrastructure built.
So at the end of the day, there has to be a way to resolve a
disagreement between states. And so that's pretty much all it is,
just recognizing that, "look, this can be hard, it's never easy,
but at the end of the day, a decision has to be made."


David Roberts


Well, can FERC say in this rule, you must make a decision?


Rob Gramlich


Yes, yeah. And that's essentially what hopefully they will say.


David Roberts


This is, you know, continuing a theme from the previous section.
But also I noticed the recommendations are that they should be
assessing costs also based on portfolios, portfolios of projects
maybe, rather than like who's paying for this individual project?
This individual project considering a portfolio and then sort of
the aggregate costs —


Rob Gramlich


That's right.


David Roberts


Doing cost allocation based on that.


Rob Gramlich


Yeah. And that helps with the cost allocation challenge. If you
do all the assets and upgrades together, then the chances are
greater that everybody benefits a little bit, as opposed to when
you just kind of come in and say, "hey, I got a line from here to
here." Well, guess what? The people in all the other places on
the region say, "well, I don't want to pay a dollar."


David Roberts


You end up with a mire there because it's like, where to draw the
line around those benefits, as you say, mostly will be on either
side of that line. But also in some second order way, a regional
benefit, also in some second order way, a national benefit, I
mean, benefit to humanity, to where you draw that line is
somewhat arbitrary. So I think it's helpful to take at least a
bigger unit of analysis.


Rob Gramlich


There's no magic bullet here where could say, "here's the best
formula, now everybody do it." Because some regions, when I go,
and I don't know, I was in the Pacific Northwest and they're
like, "yeah, we could really put together something, but we need
flexibility to — everybody needs to poke and prod at the benefits
evaluation and come to the table and support it. In other words,
get to a bespoke cost allocation agreement among parties,"
whereas other regions are like, "oh, man, if we had to go back
and relitigate the benefits and cost allocation with every
regional plan, we'd never get anything done."


So there is this tension that FERC is going to have to balance
between the bespoke and the formulaic approach here. And there's
not a good answer that works well in every region. You know, I
think they can provide very helpful guidance. They can narrow
down the funnel of the things that people can agree or disagree
about and get to much greater alignment about how to measure the
benefits. So those types of things, as well as the process with
the states, I think could be helpful.


David Roberts


And as you say, just requiring a decision, "you can't leave the
dinner table until your plate is clear," type of thing.


Rob Gramlich


Way to give it a really bad taste in people's mouths. Now
everybody's thinking about the bad brussels sprouts, but, yeah,
no, you got to have a decision at the end of the day.


David Roberts


All right, so that's planning and cost allocation, planning and
paying. So then the third section of recommendations, I think are
really interesting. And my instinct, and maybe tell me if I'm
wrong, is that this might be the most uncomfortable for FERC, or
maybe you might find the most resistance within FERC. Tell me if
I'm wrong about this, but this is just a section about FERC
oversight. Basically, the recommendation is like FERC needs to
take a more active hand here in ensuring that this regional
planning process is being done well. It's being done in a
cost-effective way, which is just going to be a little bit more
active governance, a little bit more active oversight.


And quoting from the report, "eliminate the multi-stage process
that currently prevents inter-regional projects from being
constructed." So tell us a little bit about what role you
envision for FERC here, what these recommendations are about,
greater oversight and sort of like what the political valence is
of those recommendations.


Rob Gramlich


Right. Well, again, FERC is the transmission regulator of the
nation, and the courts have clarified that over recent years. And
so I think the main thing here is to put these planning
approaches out there, put it into regulations, require them
nationwide. Sure, there's going to be regional flexibility and
each region has a different set of institutions that will come
into play and be used. I think FERC can sell this whole rule as
providing plenty of regional variation and flexibility. But at
the end of the day, you've got to do these planning practices and
FERC has to oversee that they happen.


So with any nationwide rule from a regulator, there's always the
risk of you put it out, you require compliance filings, and then
you kind of loosen things up on compliance and then over time
they get away with things. And the regulator isn't making sure
that the rule was followed.


David Roberts


Right. The rule only matters if there's some stick, some element
of enforcement.


Rob Gramlich


Right. And the industry does follow it. I mean, look, there were
plenty of opponents of open access in the mid 90s. Now they all
have open access tariffs and they follow them like they're
contracts. And anybody can bring a case to FERC enforcement if
the tariff is not being followed, the tariff being like the
public contract. And so the same would be the case here. And so
just one hopes that FERC would follow through in implementation
and make sure that all these practices are followed.


David Roberts


Well, what can FERC do, though, if I'm an RTO and I'm not
following these practices and someone brings a case before FERC
saying "this, such and such RTO isn't doing what you said." What
sticks does FERC have in its backpack?


Rob Gramlich


Well, in some cases they do have enforcement authority and
financial penalties. That's more in the market manipulation
realm, but with the regional transmission organizations, and I
should also say the planning entities that are not in the RTOs.
Right, because we've got the Southeast and the West where there
is no RTO, but they would also be subject to this rule. FERC just
simply has to tell them — it's not a great answer to your
question, but they set the rules and they are the regulator of
these entities and FERC enforcement can get involved if they
don't comply.


David Roberts


So if it comes to it, then FERC can penalize them financially.
That's basically what it's got in its.


Rob Gramlich


I don't know the extent of that on something like a transmission
planning practice, but they do have some penalty authority that
came up in the interconnection context. So there may be some of
that.


David Roberts


Another thing mentioned in this section is the possibility that
FERC could impose performance-based rate making on some of these
entities. Is that a significant possibility?


Rob Gramlich


I think there is some possibility there in certain contexts. It's
not within the scope of this particular rule. There are forms of
incentives. FERC got all this incentive authority in EPAC of 2005
and they haven't really — well, they've used some of it. It's
been sort of back and forth. And there are definitely
opportunities, like in the grid enhancing technology case to use
incentives to reward utilities. And they are the economic
regulator. So they have the ability to penalize utilities and say
you get less rate of return if you don't do these things. So
there's opportunity there. I don't think there's like a great
proposal for how to kind of do that across their whole set of
operations.


I think there's some very narrow, tailored approaches for that.
But again, FERC would have to do that in another proceeding.


David Roberts


Just say a little bit about how, say, FERC took this to heart,
implemented this rule with these requirements for a better
planning process, guidance on the cost allocation, and then this
more active governance and oversight. Describe a little bit how
that would look to you. What would you like to see in your dream
world? What would a more active FERC look like? What would that
involve? A more vigorous oversight from FERC.


Rob Gramlich


So let's take any region, I mean, the Midwest — MISO is the RTO
there. They're doing a lot of this now, as is California, which
is they look out at 20 years. They estimate generation, additions
and retirements and load growth. They might do a scenario on
electrification, like are we going to have a high EV deployment
in this region or lower middle? And they'll put all that together
and this can happen in any region.


David Roberts


MISO is actually one of the better — like MISO is a leader,
right?


Rob Gramlich


They're doing a lot of this now. Yeah, MISO and California ISO
are doing a fair amount. Some other regions have done some things
lately. New York has done some things lately, and they're all
talking about doing it partly just because FERC is driving this.
And you know how, and you've talked about this many times about
the two terawatts of generation in the interconnection queue. So
this proposal is not about necessarily saying, let's take every
proposed generator that anybody ever imagined and plan for that —
because we're not going to get two terawatts by 2030 or whatever.


So it's really more like start with kind of from a consumer
standpoint or a load serving entity standpoint of what is needed
to serve that load with the types of resources they say they want
or their law says they need, and let's kind of work from that. So
you make a reasonable, just objective estimate of the new
generation, the retired generation, the expanded load, and those
are the main factors. And then you take that set of inputs and
give them to the transmission planners and say, "okay,
transmission planning engineers, plan me the most efficient,
reliable grid based on all that" — planning engineers, they know
exactly what to do with that. That's not hard for them.


Granted, they haven't been doing it for very long, and the people
who did that retired ten years ago. So there's a little bit of a
human resource challenge there. But generally they know how to do
that. And that's essentially the vision, which, consistent with
everything we've talked about here, really isn't rocket science.
It's just planning for the future. And then get the transmission
experts to say the right transmission grid for that future. And
then what is the FERC — you're asking about the FERC role here?
So FERC can kind of say, "hey, wait a minute, you didn't actually
factor in these factors."


Or parties can appeal to FERC and say, "wait a minute, my state
has this policy," or "all of the consumers are saying they're
buying this much energy. Or the load serving entities have sort
of testified here or provided information about the resource mix
they're going to be utilizing based on their, whatever it is,
their utility targets. And you haven't factored that in." —
regional planning entity. So then FERC can say, "hey, regional
planning entity, do that, put all that in there." And that's how
they — you know, they're not directing the outcome. They're not
saying, "you need a DC line from over here to over there", but
they're saying "you didn't follow the practice that we required."


David Roberts


Right. And I should just say, by background, I mean, maybe
listeners already understand this, but the sort of background
here is that the Federal Power Act requires utilities to set just
and reasonable rates. That's sort of the engine of all this. The
idea here is that if you're not doing this planning process in a
rational way, then the resultant rates you decide on will not be
just and reasonable. So, if you're reasonable, you would do these
things. That's kind of the driver in the background.


Rob Gramlich


Exactly right. Exactly right. And that's a good point to kind of
highlight the cost-benefit issue here, which is transmission is
not cheap. Right? Nobody's claiming it's cheap. Sure, there's
technology, ways to get a cheaper portfolio, but none of it's
free. But the thing is, for just and reasonable rates, if you
really look at it, we're actually doing things the most expensive
way possible right now.


David Roberts


Right. Which is not reasonable.


Rob Gramlich


Right. Which is not reasonable or just for anybody. A lot of
consumer groups are saying this now to FERC, which is that, "hey,
look, maybe we'd even prefer zero be spent on anything. But the
reality is we're spending money on each incremental request that
comes in, both on the generation and the load side, and then
we're serving that need in only that need, the minimum required
to serve that need. Well, it turns out with an industry that has
massive economies of scale, you're necessarily doing something
that costs way more per delivered megawatt than if you plan just
a little bit ahead.


And at the scale, like maybe the 230 kV line should be a 345 kV
line or a 500 or 765. We got to call a stop to the current
practice. Just can't keep doing things —"


David Roberts


That's kind of the root of FERC's authority here is that the
current practice is not just and reasonable.


Rob Gramlich


That's right.


David Roberts


One other thing, which I probably should have covered up front,
but let's just say a quick word about now. I think listeners know
that our electricity system in its wisdom is sort of split.
There's these restructured regions that have wholesale power
markets and that are governed — where the transmission is
governed by these regional bodies, RTOs. But then there's this
other half of the country, notably the South and the West, the
Southeast and the West, which are not wholesale power markets and
do not have regional transmission organizations. Does all this
apply to those regions just as well?


And if so, who does it apply to? Who does regional planning in a
region that's just balkanized utilities? Who do all these
requirements apply to in those areas?


Rob Gramlich


Yeah, it does apply to all regions. And there are regional
planning entities even in the regions without regional
transmission organizations that were set up under Order 1000 in
2011. So, for example, there's Northern Grid and WestConnect out
in the West. So it's not clear what the final rule will say. It
could be those groups or they could allow different groups to do
it. But it is important for this to cover the entire country.


David Roberts


Right. And let's just say, although, as you say, this is in a
completely different pod, but let's just say it would be sure be
convenient if the Southeast and the West would just get their
s**t together and form regional power markets and RTOs of their
own so that at least we could have consistent entities across the
country when we're trying to regulate things. So just to sort of
review here, there's this upcoming FERC rule. It's been proposed.
It's going to be finalized soon, ideally and likely finalized in
a FERC with three commissioners, two of which are Democrats.


It's going to require a better planning process, better cost
allocation, and it's going to boost FERC's sort of authority and
oversight. That is, this rule will do those things if these
recommendations are accepted and taken to heart. So maybe
actually two final questions, I should never say final question.
Who's the really decision maker here? What's the sort of
political valence of all this in terms of the commissioners? All
of this sounds so obvious and sensible in such a way that it's
difficult to kind of imagine who doesn't want this? Who doesn't
want sane regional planning that takes a holistic view, et
cetera, et cetera.


So what's the resistance here? Who needs to be persuaded on the
commission?


Rob Gramlich


Chairman Phillips is the leader of the commission and on the
timing and the substance, and he's going to work with his
colleagues to make all the final policy calls and all the things.
So he's the primary person here, and he wants to do this. He's
been consistent in his public statements and his comments in the
Oversight Committee hearings in Energy and Commerce and Senate
Energy about this, that this is a priority for him, and I believe
it is. But there's just a lot of details in here. There are
powerful entities that don't want FERC rules on things.


They might be utilities or they might be incumbent generators or
others, and the commissioners all hear from them. And like,
everybody's a little bit nervous about spending too much money
because everybody wants low electricity rates. So in that
uncertainty about exactly how much transmission is needed and
where, I think there's a lot of room for parties to push the
commission in different directions and for commissioners to say,
well, yes to this and no to that. So this is so important to get
right. I get nervous about those details. But all the things
we've discussed on this podcast, these are the high-level things
that really are important.


And that would, I would just think, I mean, any average person on
the street would think, "of course they got to do those things."


David Roberts


Not that complicated. It's just like any planning, that's what
planning is, right?


Rob Gramlich


That's what planning is. And yeah, I don't know if you had
radical ideas about how you would do networks without the need to
plan and just wanted all like market-based system without
regulations, who knows? But the industry, this is an
interconnected, large, regional, multistate network.


David Roberts


Just iconically network. And all the things, all the sort of
design principles that apply to networks apply here, really
iconic form. And I can sort of imagine individual entities with
narrow pecuniary interest in stopping this. But I can't imagine a
sort of like public interest argument against, like, I can sort
of imagine a utility saying, "this will reduce our profits some,"
but I can't even conceive of what the kind of public interest
argument against this stuff is.


Rob Gramlich


Well, remember, this is happening in Washington. We're recording
this right before a potential, another government shutdown. So
getting basic things done —


David Roberts


Okay, a really final question. There's a lot to be said about
this too, but just quickly sort of, it seems unlikely that any
legislation is going to pass DC ever again of any kind, really,
but especially transmission. It seems a little bit like this is
getting, it shouldn't be, but it is getting a little bit
polarized. It seems like it's getting to be more of a Democrat
versus Republican thing, even though that makes no sense. Such is
our politics. But are there in your sort of realist, if we're
taking a purely realist perspective here, are there legislative
things that could be done that have some glimmer of chance of
having bipartisan support and actually getting through a divided
Congress?


And if those — what are those things?


Rob Gramlich


Yes, I do think there is some possibility for bipartisan action,
and I think the Senate Energy Committee is thinking and taking
seriously a lot of those things. I've had very encouraging
conversations, many, many conversations with both Republicans and
Democrats on the Senate Energy Committee. And the one area that I
think resonates with everybody is the interregional case, which
again, is not so much the subject of this rule. And partly the
idea is, while FERC's doing the intraregional right now, but I
think there's pretty broad recognition that in the interregional
case, really across between these large areas of the country, the
industry historically did not grow up with any way to get those
types of lines built.


David Roberts


Yeah. Can I just ask in that case, because everything we've
discussed, I can see how it could be applied relatively
straightforwardly to the interregional setting, with one
exception, which is, what are the entities in question? What are
the planning entities to whom all these rules apply in the
interregional setting?


Rob Gramlich


Yeah, that's right. Applying a rule to many dozens of entities is
hard to hold anyone accountable for not doing —


David Roberts


Right. Is there a prospect on the table of creating such
entities, or would just this just be a matter of, like, RTOs
cooperating with other RTOs, like interregionally? Who's doing
that?


Rob Gramlich


Well, yeah. So there's two main options there. First of all, it
will be helpful to, I think if we get some kind of recognition
that that is the need, this large interregional case, we'll see
what happens.


David Roberts


There's plenty of evidence at this point. I mean, the DOE itself
had that gigantic report that showed the benefits of national
network.


Rob Gramlich


That's right. So then there's two policy things to do about that.
One is a process like require — you could have legislation
directing FERC to set up a process with many of the same planning
practices we've just discussed and apply them in the
interregional case, recognizing that, who exactly is the
regulated entity and who do you hold accountable for not doing
it? That's not easy, but it's not totally unfamiliar to FERC
either. So that's one thing is a process requirement. Another is
a minimum transmission capacity requirement between the regions.
Just say, well, we don't necessarily know the optimum level, but
let's just make sure we have a minimum level and set that level
at some percentage.


David Roberts


Between regions?


Rob Gramlich


Between regions. Right. And they do that actually in Europe.


David Roberts


Wasn't that on the table recently or developed recently? I feel
like I heard about that in the background.


Rob Gramlich


Yeah, exactly. A lot of people probably heard about that in the
context of the debt ceiling deal back in late spring, or —


David Roberts


It didn't happen.


Rob Gramlich


Yeah, it kind of had a glimmer of hope and it sort of had some
bipartisan support. So it almost got in there.


David Roberts


And then it got summarily executed, I think, by utilities in
their Republican catspaws.


Rob Gramlich


No comments. The fingerprints were removed, but yeah, it just
turned into a report, unfortunately. But there was this big wires
bill that Senator Hickenlooper and Representative Peters had
introduced in their respective chambers, and that still is
kicking around. It's got the bill, the idea, anyway, has a lot of
support from a lot of stakeholders. So that's another
possibility. Some version of that.


David Roberts


Okay, well, we're overtime, and this has been so fascinating. So,
this is something that has come up on Volts over and over again.
The need for more planning. I mean, not just in transmission, but
just like, it feels like every topic I get into, you pull the
string long enough, you end up in two places. One, utilities are
screwing everything up, and two, we need better planning. I feel
like those are the themes I end up no matter what topic I take
on. So this is an opportunity here, right in front of us to do
better planning.


So I know people don't necessarily pay a lot of attention to FERC
on a day to day basis, but this is like "rubber hits the road"
time right now. So it's really important, I think, that people
tune into this and do what they can to encourage FERC to go big
here and to do well by this rule. By the way, is there anything
like an average listener, it all seems so distant, is there
anything average people can do to poke or prod FERC to do well
here?


Rob Gramlich


For those who might have a way to engage at the state level or
the regional level, that's important. No transmission really
moves forward without strong support in the region. And so
governors can be influential, encouraging governors to get
supportive of this. I think that type of thing is useful. Even
state legislators are weighing in. The National Caucus of state
legislators, about 200 of them wrote a letter to FERC. So there
are sort of indirect ways to encourage FERC or to encourage the
regional planning entity in the region or encourage the governor
or others involved in those processes to get on board with the
agenda.


David Roberts


All right, we will leave it there. Rob, thanks for coming on and
walking through this with us. It's funny when I get into these
topics that seem sort of like forbiddingly technical from the
outside, and then you dig in a little bit and it's like FERC
wants regional planners to plan. It's like, that's not really —
turns out it wasn't that technical.


Rob Gramlich


Now you know, and it's not that hard.


David Roberts


All right, thanks a lot, Rob.


Rob Gramlich


Great to be with you, David. Thanks.


David Roberts


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