Siting Transmission Corridors— A Real Life Game of Chutes ...
6
Smart Grid jobs transmission electricity power generation energy storage reliability coal natural gas demand response nuclear solar wind geothermal biomass renewables hydroelectri megawatts vehicles siting FERC Congress efficiency supply sources fuel peak load future security utility urces development distribution technolo production wave states emissions tidal heating c local international substatio Siting Transmission Corridors— A Real Life Game of Chutes and Ladders*
Transcript of Siting Transmission Corridors— A Real Life Game of Chutes ...
Smart Grid
jobstransmission
electricity
power
generation
energy storage
reliability
coal
natural gas
demand response
nuclear
solar
wind
geothermal
biomass
renewables
hydroelectric
megawatts
vehicles
siting
FERC
Congress
efficiency
supply
sourcesfuel
peak load
future
security
utilityresources
development
distribution
technologyproduction
wave
states
emissions
tidal
heating
carbon
local
international
substation
Siting Transmission Corridors—
A Real Life Game of Chutes and Ladders*
1 3 5 7 9 11
21 19 17 15 13
23 25 27 29 31 33
43 41 39 37 35
45 47 49 51 53 55
65 63 61 59 57
67 69 71 73 75 77
87 85 83 81 79
89 91 93 95 97 99
109 107 105 103 101
111 113 115 117 119 121
131 129 127 125 123
133 135 137 139 141 143
153 151 149 147 145
155 157 159 161 163 165
175 173 171 169 167
177 179 181 183 185 187
197 195 193 191 189
199 201 203 205 207 209
219 217 215 213 211
221 223 225 227 229 231
241 239 237 235 233
243 245 247 249 251 253
265 267 269 271 273 275
263 261 259 257 255
12
34
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78
100
122
144
166
188
210
232
254
1 3333 77777777777 9
2222222222222222222111111111111 111111111111999999999999 111111111111777777777777 15 13
31
37 35
555555511111 53
59 57
6666666666677 69 773 75
81 79
89 97
111111100003 101
111 119
11111112225 123
133 141
111111144447 145
155 163
11111116669 167
177 185
111111191 189
199 201 203
219 217 22 11111111
221 223
241 239 33333333333
243 245
265 267
263 261 5555555555555
666 8 10
22 2222222222220000000000000 1111111111118888888888888 166 14
33330 32
36
552 54
66660 58
66888 74 76
88 80
999996 98
110 102
111111111118 120
132 124
11111114444440 142
154 146
1111111666662 164
176 168
1111111888884 186
198 190
200 202 2220000 00000000000000000000888888888
220 218 216
222 224 33333333300000000
242 240
244 246 555555555552222222
266 268 7777777777744444444
264 262
Transmission Planning Cost Allocation / FERC Rates
NewGeneration Load Growth
EquipmentRetirement Reliability
Other Federal Agency Approvals
Transmission Siting
Yes
Yes Yes
Yes
No
Yes
No
No
Yes
No
No
Yes
No
No
Yes
Yes
No
sYe
Does the line cross non-
federal lands?
Utility commission approval?
Does the line cross private
lands?
Landowner approval?
No
State court/commission approval?
No
FERC approval?
Obtain federal eminent domain
authority
Obtain eminent domain authority
Buy/obtain right-of-ways from each landowner
Yes
Apply to each state utility commission
6–12 months
END GAME
BUILD LINE!
1–2 years
3–5 years
3–5 years
Yes
No
Yes
Yes
No
No
Yes
Yes
No
Ye
No
No
No
Ye
Line neededfor reliability?
No
Include in Transmission Plan
Energysavings
greater than line cost?
Non-transmission alternatives available?
Non-transmission alternatives available?
END GAME
END GAME
Yes
Yes
No
No
No
Yes
Yes
No
Yes
Yes
Yes
No
No
No
No
No
Yes Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
Yes
Yes
YesYes
Explosive users permit
Yes
No
No
No
No
No
No
No
No
No
No
Potential environmental
impact?
Does the line cross navigable
waters?
Will line cross protected habitats?
Will line construction impact air quality?
Will line cross BLM-managed
lands?
Will line cross forest service
lands?
Will line cross federal
highways?
Will construction
involve explosives?
Transmission towers near runways?
Court challenges?
Prepare environmental
impact statement
Right-of-way grant, temporary
use permit, antiquities and cultural uses
permit, plan of development
Special use permit and
easement or lease
Encroachment permit
Form 7460-1
ToSiting
ArmyCorps of Engineers
approval?
U.S. Fish & Wildlife
approval?
EPA approval?
BLM approval?
USFS approval?
DOT FHA approval?
BATFE approval?
Federal Aviation Administration
approval?
Court requires new analysis?
Repeat approvals process at state
level
Council on Environmental
Quality approval?
END GAME
OO
RESTART
Project added to Federal Infrastructure Permitting Dashboard
Yes Yes Yes
No
NoYes
No
No
NoYes
Yes
Yes
Y
Line increases reliability or is
needed for public policy?
Line decreases congestion
cost?
Receive FERC rate approval
Line uses advanced
technology?
Projectfaces great siting,
technology, or financing
risks?
Added incentives
END GAME
No
YYes
NoYesY N
No
Line increases reliability or is
needed for publicpolicy?
Line decreasescongestion
Line usesadvanced
technology?END GAME
YProposedline is result ofa fair and open
planning process?
NoNo
YeYes
No
Proposed line is part a
regional transmission plan?
Ye
Yes
es
No
es
YY
Satisfies regional cost
allocationprinciples?
Yes
Yes
Noo
IncludTransmiss
Notransm
No
Line neededfor public policy
purposes?
Oh, for the simplicity of Chutes and Ladders!
Despite electricity’s fundamental role in our way of life, the policies affecting the movement of electricity from generation to end-use are complex, disjointed, burdensome, outdated, and at various times redundant or conflicting.
As America strives to meet its citizens’ demand for more electricity, it encounters federal, state, and local policies that govern the development of transmission corridors and the power lines that are built within them. They are both obstacles and opportunities—chutes and ladders—in our efforts to power the American economy and way of life.
No matter how we generate electricity—coal, natural gas, nuclear, water, wind, or solar—we must be able to efficiently deliver it to the consumer. Energy entrepreneurs, transmission developers, public utilities, and federal and state regulators are all engaged in getting power from the generator to the consumer. While they may all differ on the specifics of siting these transmission lines, proponents and opponents agree—load growth, construction permits, wildlife protection, property rights, and other concerns must all be addressed before lines can be built.
While the childhood game of Chutes and Ladders can provide hours of fun and relies on luck, the real life challenge of Siting Transmission Corridors can take years of skillful navigation with tens of millions of dollars, thousands of manufacturing and construction jobs, and the reliability of our electrical grid all at stake.
In the game, a ladder enables a player to advance quickly through the maze; a chute sends him backward. Players move their game pieces through a series of consecutively numbered spaces, with the goal of being the first to finish.
In Siting Transmission Corridors, the goal is to overcome financial and regulatory challenges in order to gain final approval for construction of a transmission line. Ladders include minimal environmental impacts, use of advanced technology, and demonstrable reliability gains. Chutes, on the other hand, could be rejections by federal, state, or local agencies; financing risks; rate denials; and litigation.
So, grab a marker and wind your way through Siting Transmission Corridors. You will see that establishing a national transmission siting policy for planning, permitting, and payment would ensure that we climb more ladders and slide down fewer chutes.
1 3 5 7 9 11
21 19 17 15 13
23 25 27 29 31 33
43 41 39 37 35
45 47 49 51 53 55
65 63 61 59 57
67 69 71 73 75 77
87 85 83 81 79
89 91 93 95 97 99
109 107 105 103 101
111 113 115 117 119 121
131 129 127 125 123
133 135 137 139 141 143
153 151 149 147 145
155 157 159 161 163 165
175 173 171 169 167
177 179 181 183 185 187
197 195 193 191 189
199 201 203 205 207 209
219 217 215 213 211
221 223 225 227 229 231
241 239 237 235 233
243 245 247 249 251 253
265 267 269 271 273 275
263 261 259 257 255
12
34
56
78
100
122
144
166
188
210
232
254
1 3333 77777777777 9
2222222222222222222111111111111 111111111111999999999999 111111111111777777777777 15 13
31
37 35
555555511111 53
59 57
6666666666677 69 773 75
81 79
89 97
111111100003 101
111 119
11111112225 123
133 141
111111144447 145
155 163
11111116669 167
177 185
111111191 189
199 201 203
219 217 22 11111111
221 223
241 239 33333333333
243 245
265 267
263 261 5555555555555
666 8 10
22 2222222222220000000000000 1111111111118888888888888 166 14
33330 32
36
552 54
66660 58
66888 74 76
88 80
999996 98
110 102
111111111118 120
132 124
11111114444440 142
154 146
1111111666662 164
176 168
1111111888884 186
198 190
200 202 2220000 00000000000000000000888888888
220 218 216
222 224 33333333300000000
242 240
244 246 555555555552222222
266 268 7777777777744444444
264 262
Transmission Planning Cost Allocation / FERC Rates
NewGeneration Load Growth
EquipmentRetirement Reliability
Other Federal Agency Approvals
Transmission Siting
Yes
Yes Yes
Yes
No
Yes
No
No
Yes
No
No
Yes
No
No
Yes
Yes
No
sYe
Does the line cross non-
federal lands?
Utility commission approval?
Does the line cross private
lands?
Landowner approval?
No
State court/commission approval?
No
FERC approval?
Obtain federal eminent domain
authority
Obtain eminent domain authority
Buy/obtain right-of-ways from each landowner
Yes
Apply to each state utility commission
6–12 months
END GAME
BUILD LINE!
1–2 years
3–5 years
3–5 years
Yes
No
Yes
Yes
No
No
Yes
Yes
No
Ye
No
No
No
Ye
Line neededfor reliability?
No
Include in Transmission Plan
Energysavings
greater than line cost?
Non-transmission alternatives available?
Non-transmission alternatives available?
END GAME
END GAME
Yes
Yes
No
No
No
Yes
Yes
No
Yes
Yes
Yes
No
No
No
No
No
Yes Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
Yes
Yes
YesYes
Explosive users permit
Yes
No
No
No
No
No
No
No
No
No
No
Potential environmental
impact?
Does the line cross navigable
waters?
Will line cross protected habitats?
Will line construction impact air quality?
Will line cross BLM-managed
lands?
Will line cross forest service
lands?
Will line cross federal
highways?
Will construction
involve explosives?
Transmission towers near runways?
Court challenges?
Prepare environmental
impact statement
Right-of-way grant, temporary
use permit, antiquities and cultural uses
permit, plan of development
Special use permit and
easement or lease
Encroachment permit
Form 7460-1
ToSiting
ArmyCorps of Engineers
approval?
U.S. Fish & Wildlife
approval?
EPA approval?
BLM approval?
USFS approval?
DOT FHA approval?
BATFE approval?
Federal Aviation Administration
approval?
Court requires new analysis?
Repeat approvals process at state
level
Council on Environmental
Quality approval?
END GAME
OO
RESTART
Project added to Federal Infrastructure Permitting Dashboard
Yes Yes Yes
No
NoYes
No
No
NoYes
Yes
Yes
Y
Line increases reliability or is
needed for public policy?
Line decreases congestion
cost?
Receive FERC rate approval
Line uses advanced
technology?
Projectfaces great siting,
technology, or financing
risks?
Added incentives
END GAME
No
YYes
NoYesY N
No
Line increases reliability or is
needed for publicpolicy?
Line decreasescongestion
Line usesadvanced
technology?END GAME
YProposedline is result ofa fair and open
planning process?
NoNo
YeYes
No
Proposed line is part a
regional transmission plan?
Ye
Yes
es
No
es
YY
Satisfies regional cost
allocationprinciples?
Yes
Yes
Noo
IncludTransmiss
Notransm
No
Line neededfor public policy
purposes?
Oh, for the simplicity of Chutes and Ladders!
Despite electricity’s fundamental role in our way of life, the policies affecting the movement of electricity from generation to end-use are complex, disjointed, burdensome, outdated, and at various times redundant or conflicting.
As America strives to meet its citizens’ demand for more electricity, it encounters federal, state, and local policies that govern the development of transmission corridors and the power lines that are built within them. They are both obstacles and opportunities—chutes and ladders—in our efforts to power the American economy and way of life.
No matter how we generate electricity—coal, natural gas, nuclear, water, wind, or solar—we must be able to efficiently deliver it to the consumer. Energy entrepreneurs, transmission developers, public utilities, and federal and state regulators are all engaged in getting power from the generator to the consumer. While they may all differ on the specifics of siting these transmission lines, proponents and opponents agree—load growth, construction permits, wildlife protection, property rights, and other concerns must all be addressed before lines can be built.
While the childhood game of Chutes and Ladders can provide hours of fun and relies on luck, the real life challenge of Siting Transmission Corridors can take years of skillful navigation with tens of millions of dollars, thousands of manufacturing and construction jobs, and the reliability of our electrical grid all at stake.
In the game, a ladder enables a player to advance quickly through the maze; a chute sends him backward. Players move their game pieces through a series of consecutively numbered spaces, with the goal of being the first to finish.
In Siting Transmission Corridors, the goal is to overcome financial and regulatory challenges in order to gain final approval for construction of a transmission line. Ladders include minimal environmental impacts, use of advanced technology, and demonstrable reliability gains. Chutes, on the other hand, could be rejections by federal, state, or local agencies; financing risks; rate denials; and litigation.
So, grab a marker and wind your way through Siting Transmission Corridors. You will see that establishing a national transmission siting policy for planning, permitting, and payment would ensure that we climb more ladders and slide down fewer chutes.
1 3 5 7 9 11
21 19 17 15 13
23 25 27 29 31 33
43 41 39 37 35
45 47 49 51 53 55
65 63 61 59 57
67 69 71 73 75 77
87 85 83 81 79
89 91 93 95 97 99
109 107 105 103 101
111 113 115 117 119 121
131 129 127 125 123
133 135 137 139 141 143
153 151 149 147 145
155 157 159 161 163 165
175 173 171 169 167
177 179 181 183 185 187
197 195 193 191 189
199 201 203 205 207 209
219 217 215 213 211
221 223 225 227 229 231
241 239 237 235 233
243 245 247 249 251 253
265 267 269 271 273 275
263 261 259 257 255
12
34
56
78
100
122
144
166
188
210
232
254
1 3333 77777777777 9
2222222222222222222111111111111 111111111111999999999999 111111111111777777777777 15 13
31
37 35
555555511111 53
59 57
6666666666677 69 773 75
81 79
89 97
111111100003 101
111 119
11111112225 123
133 141
111111144447 145
155 163
11111116669 167
177 185
111111191 189
199 201 203
219 217 22 11111111
221 223
241 239 33333333333
243 245
265 267
263 261 5555555555555
666 8 10
22 2222222222220000000000000 1111111111118888888888888 166 14
33330 32
36
552 54
66660 58
66888 74 76
88 80
999996 98
110 102
111111111118 120
132 124
11111114444440 142
154 146
1111111666662 164
176 168
1111111888884 186
198 190
200 202 2220000 00000000000000000000888888888
220 218 216
222 224 33333333300000000
242 240
244 246 555555555552222222
266 268 7777777777744444444
264 262
Transmission Planning Cost Allocation / FERC Rates
NewGeneration Load Growth
EquipmentRetirement Reliability
Other Federal Agency Approvals
Transmission Siting
Yes
Yes Yes
Yes
No
Yes
No
No
Yes
No
No
Yes
No
No
Yes
Yes
No
sYe
Does the line cross non-
federal lands?
Utility commission approval?
Does the line cross private
lands?
Landowner approval?
No
State court/commission approval?
No
FERC approval?
Obtain federal eminent domain
authority
Obtain eminent domain authority
Buy/obtain right-of-ways from each landowner
Yes
Apply to each state utility commission
6–12 months
END GAME
BUILD LINE!
1–2 years
3–5 years
3–5 years
Yes
No
Yes
Yes
No
No
Yes
Yes
No
Ye
No
No
No
Ye
Line neededfor reliability?
No
Include in Transmission Plan
Energysavings
greater than line cost?
Non-transmission alternatives available?
Non-transmission alternatives available?
END GAME
END GAME
Yes
Yes
No
No
No
Yes
Yes
No
Yes
Yes
Yes
No
No
No
No
No
Yes Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
Yes
Yes
YesYes
Explosive users permit
Yes
No
No
No
No
No
No
No
No
No
No
Potential environmental
impact?
Does the line cross navigable
waters?
Will line cross protected habitats?
Will line construction impact air quality?
Will line cross BLM-managed
lands?
Will line cross forest service
lands?
Will line cross federal
highways?
Will construction
involve explosives?
Transmission towers near runways?
Court challenges?
Prepare environmental
impact statement
Right-of-way grant, temporary
use permit, antiquities and cultural uses
permit, plan of development
Special use permit and
easement or lease
Encroachment permit
Form 7460-1
ToSiting
ArmyCorps of Engineers
approval?
U.S. Fish & Wildlife
approval?
EPA approval?
BLM approval?
USFS approval?
DOT FHA approval?
BATFE approval?
Federal Aviation Administration
approval?
Court requires new analysis?
Repeat approvals process at state
level
Council on Environmental
Quality approval?
END GAME
OO
RESTART
Project added to Federal Infrastructure Permitting Dashboard
Yes Yes Yes
No
NoYes
No
No
NoYes
Yes
Yes
Y
Line increases reliability or is
needed for public policy?
Line decreases congestion
cost?
Receive FERC rate approval
Line uses advanced
technology?
Projectfaces great siting,
technology, or financing
risks?
Added incentives
END GAME
No
YYes
NoYesY N
No
Line increases reliability or is
needed for publicpolicy?
Line decreasescongestion
Line usesadvanced
technology?END GAME
YProposedline is result ofa fair and open
planning process?
NoNo
YeYes
No
Proposed line is part a
regional transmission plan?
Ye
Yes
es
No
es
YY
Satisfies regional cost
allocationprinciples?
Yes
Yes
Noo
IncludTransmiss
Notransm
No
Line neededfor public policy
purposes?
Oh, for the simplicity of Chutes and Ladders!
Despite electricity’s fundamental role in our way of life, the policies affecting the movement of electricity from generation to end-use are complex, disjointed, burdensome, outdated, and at various times redundant or conflicting.
As America strives to meet its citizens’ demand for more electricity, it encounters federal, state, and local policies that govern the development of transmission corridors and the power lines that are built within them. They are both obstacles and opportunities—chutes and ladders—in our efforts to power the American economy and way of life.
No matter how we generate electricity—coal, natural gas, nuclear, water, wind, or solar—we must be able to efficiently deliver it to the consumer. Energy entrepreneurs, transmission developers, public utilities, and federal and state regulators are all engaged in getting power from the generator to the consumer. While they may all differ on the specifics of siting these transmission lines, proponents and opponents agree—load growth, construction permits, wildlife protection, property rights, and other concerns must all be addressed before lines can be built.
While the childhood game of Chutes and Ladders can provide hours of fun and relies on luck, the real life challenge of Siting Transmission Corridors can take years of skillful navigation with tens of millions of dollars, thousands of manufacturing and construction jobs, and the reliability of our electrical grid all at stake.
In the game, a ladder enables a player to advance quickly through the maze; a chute sends him backward. Players move their game pieces through a series of consecutively numbered spaces, with the goal of being the first to finish.
In Siting Transmission Corridors, the goal is to overcome financial and regulatory challenges in order to gain final approval for construction of a transmission line. Ladders include minimal environmental impacts, use of advanced technology, and demonstrable reliability gains. Chutes, on the other hand, could be rejections by federal, state, or local agencies; financing risks; rate denials; and litigation.
So, grab a marker and wind your way through Siting Transmission Corridors. You will see that establishing a national transmission siting policy for planning, permitting, and payment would ensure that we climb more ladders and slide down fewer chutes.
Transmission Planning
Transmission corridors move electricity from generating sources to the electrical distribution grid. Current transmission lines are overburdened and their locations reflect an outdated energy paradigm. Energy demand is growing and new generating capacities are poised to meet that demand. Ideally, one solution would be to transmit more power through existing corridors. But current infrastructure simply cannot accommodate this increase. In addition, renewable energy sources are often located in remote areas, far from existing transmission lines.
The first ladder to climb, then, is that of transmission planning, with each rung defined by a permit. Are new lines needed? Are potential savings greater than costs? Which utilities are involved? Does this require authorization or cooperation by regional or interstate authorities? Does the project face siting, technology, or financing risks? Are non-transmission alternatives available? Can energy storage or demand response strategies be implemented?
Delays in these responses are akin to waiting your turn in Chutes and Ladders. Considering that each permit may take one to six months, the wait between turns can add up to years.
Cost Allocation and FERC Rates
The Federal Energy Regulatory Commission (FERC), an independent agency that regulates the interstate transmission of natural gas, oil, and electricity, must first determine if the proposed line is the result of a fair and open planning process. It provides regulatory certainty through consistent approaches and timely actions.
But the process isn’t easy. It may involve corporate mergers, acquisitions, and transactions; licensures and inspections; mandatory reliability standards; and countless environmental matters.
There are also areas outside of FERC’s jurisdiction: state public utility commissions and rural electric cooperatives; regulation of retail electricity; power marketing agencies; construction of generation facilities; and regulation by other agencies, like the Nuclear Regulatory Commission.
By its very nature, approval is an arduous, multi-year process full of ladders that reach from one approval process to another, as well as chutes that result from unanticipated costs, actions by interstate planning authorities, or court challenges that can drive a circular process lasting years.
In 2009, for example, the U.S. Court of Appeals for the Fourth Circuit ruled that federal law does not apply to a state’s authority to make decisions on major interstate transmission lines within its borders. The U.S. Supreme Court declined to hear an appeal, generating uncertainty over FERC’s authority to override a state’s denial of a siting permit.
Federal Agency Approvals
Here’s where the game gets interesting. What is the potential environmental impact? Do transmission lines cross navigable waters or protected habitats? Is approval needed by the Army Corps of Engineers or Bureau of Land Management? Will construction require explosives? Environmental impact statements alone can mire a project for years.
No matter how cost-effective and equitable any federal agency’s management practices may be, plotting a course through this matrix of federal agency approvals is tedious and time-consuming. Each rung of this ladder may initiate critical adjustments to planning, cost allocation, and siting processes. These changes require an applicant to re-evaluate if it is worthwhile to continue moving ahead with the project.
Transmission Siting
Three to five years later, after obtaining all federal approvals, the final challenge is crossing non-federal land. State properties and private land issues can lead to purchased rights, eminent domain, and even more court challenges. Building interstate and interregional transmission facilities can take years.
As with any game, there may be bonus rounds and extra turns: favorably litigated outcomes, attractive rates, or tax incentives.
Winning the Game
Siting Transmission Corridors is not child’s play.
We need a clear national policy that is up to the task of modernizing our electrical infrastructure, improving its capacity, increasing its reliability and security, and diversifying our energy portfolio.
NEMA supports greater federal authority in the siting of transmission corridors, as well as lead agency status for FERC in the federal environmental review process.
A clear, nationwide transmission policy will streamline the approval processes, facilitate construction, and create domestic jobs.
*Chutes and Ladders is a trademark of Hasbro, Inc. for its board game.
Designed by NEMA Communications
Cost Allocation and FERC Rates
The Federal Energy Regulatory Commission (FERC), an independent agency that regulates the interstate transmission of natural gas, oil, and electricity, must first determine if the proposed line is the result of a fair and open planning process. It provides regulatory certainty through consistent approaches and timely actions.
But the process isn’t easy. It may involve corporate mergers, acquisitions, and transactions; licensures and inspections; mandatory reliability standards; and countless environmental matters.
There are also areas outside of FERC’s jurisdiction: state public utility commissions and rural electric cooperatives; regulation of retail electricity; power marketing agencies; construction of generation facilities; and regulation by other agencies, like the Nuclear Regulatory Commission.
By its very nature, approval is an arduous, multi-year process full of ladders that reach from one approval process to another, as well as chutes that result from unanticipated costs, actions by interstate planning authorities, or court challenges that can drive a circular process lasting years.
In 2009, for example, the U.S. Court of Appeals for the Fourth Circuit ruled that federal law does not apply to a state’s authority to make decisions on major interstate transmission lines within its borders. The U.S. Supreme Court declined to hear an appeal, generating uncertainty over FERC’s authority to override a state’s denial of a siting permit.
Federal Agency Approvals
Here’s where the game gets interesting. What is the potential environmental impact? Do transmission lines cross navigable waters or protected habitats? Is approval needed by the Army Corps of Engineers or Bureau of Land Management? Will construction require explosives? Environmental impact statements alone can mire a project for years.
No matter how cost-effective and equitable any federal agency’s management practices may be, plotting a course through this matrix of federal agency approvals is tedious and time-consuming. Each rung of this ladder may initiate critical adjustments to planning, cost allocation, and siting processes. These changes require an applicant to re-evaluate if it is worthwhile to continue moving ahead with the project.
Transmission Siting
Three to five years later, after obtaining all federal approvals, the final challenge is crossing non-federal land. State properties and private land issues can lead to purchased rights, eminent domain, and even more court challenges. Building interstate and interregional transmission facilities can take years.
As with any game, there may be bonus rounds and extra turns: favorably litigated outcomes, attractive rates, or tax incentives.
Winning the Game
Siting Transmission Corridors is not child’s play.
We need a clear national policy that is up to the task of modernizing our electrical infrastructure, improving its capacity, increasing its reliability and security, and diversifying our energy portfolio.
NEMA supports greater federal authority in the siting of transmission corridors, as well as lead agency status for FERC in the federal environmental review process.
A clear, nationwide transmission policy will streamline the approval processes, facilitate construction, and create domestic jobs.
*Chutes and Ladders is a trademark of Hasbro, Inc. for its board game.
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