The undersigned 75 organizations from across the nation urge you to aggressively support electricity transmission competition, especially for projects that are 100 kV and larger. The FERC April 21, 2022 Notice of Proposed Rulemaking on transmission and planning rejects competition and protects incumbent monopoly utilities. Competition reduces costs for families and businesses that are captive consumers. Competition reduces inflation and is consistent with American values. Nationwide, from 2014 to 2020, RTO/ISO transmission costs increased by $74.9 billion, or 79 percent, while electricity demand was flat (see Figure 1). [1]

Support for transmission competition is consistent with President Biden’s comments during the State of the Union address on March 1, 2022, when he stated, “Capitalism without competition is exploitation” and his Executive Order on “Promoting Competition in the American Economy.” In fact, across the country, consumers are being exploited by incumbent electric utilities that have circumvented FERC Order 1000 that was supposed to usher in an era of competition. Studies show that only about 3 percent of electric transmission projects are competitively bid. [2]

Transmission competition is especially important given President Biden’s plans to decarbonize the economy, which is projected by some to require record transmission spending. Under one of the Princeton “Net Zero America” study scenarios the U.S. may need to spend $2.1 trillion by 2050 to build out the transmission grid. [3] Studies have shown that competition can reduce the cost of transmission projects by 20-30 percent. Therefore, a 25 percent savings would save consumers an estimated $525 billion.

FIGURE 1: Comparison of Transmission Investment by Region 2014 – 2020 ($ millions) [4] 

 

Year 

CAISO  FRCC  ISO-NE  MISO  NYISO  PJM  SERC  SPP  WECC

Yearly  

Total

2014  $7,964  $1,646  $6,347  $15,373  $22,896  $20,373  $7,504  $6,015  $7,044  $95,163 
2015  $11,533  $2,228  $7,043  $17,187  $23,858  $24,957  $8,007  $6,622  $7,395 $108,831 
2016  $13,015  $2,472  $7,665  $20,072  $24,303  $29,554  $8,616  $7,265  $7,859 $120,821 
2017  $15,137  $2,700  $8,259  $22,846  $25,645  $33,877  $9,003  $7,832  $8,227 $133,526 
2018  $15,594  $2,851  $8,823  $25,197  $26,660  $37,542 $10,067  $8,508  $8,543 $143,784 
2019  $16,217  $3,030  $9,545  $27,206  $27,740  $42,319 $10,834  $8,931  $8,950 $154,773 
2020  $17,481  $3,115 $10,269  $30,532  $29,796  $48,799 $11,568  $9,292  $9,240 $170,092 
Grand  Total  $96,941 $18,042 $57,950 $158,414 $180,899 $237,421 $65,600 $54,465 $57,257 $926,989 

 

Incumbent electric utilities oppose transmission competition and would have you believe that electricity electrons stop at a state’s border. The vast majority of transmission projects involve interstate commerce and that is why changes to FERC’s regulations are needed to ensure that consumers benefit from competition and lower costs.

We request that the Committee hold a hearing that would allow consumers to explain needed changes to FERC’s NOPR and its benefits. Thank you in advance for protecting consumers from monopoly power and higher costs.

Sincerely,
Paul N. Cicio
Chairman, Electricity Transmission Competition Coalition

MEMBERS OF THE ELECTRICITY TRANSMISSION COALITION
Alliance of Western Energy Consumers (AWEC)
American Forest & Paper Association
Ag Processing
Aluminum Association
American Chemistry Council
American Foundry Society
American Iron and Steel Institute
Ardagh Group
Arglass Yamamura
Arkansas Electric Energy Consumers, Inc.
Arkansas Forest and Paper Council
Association of Businesses Advocating for Tariff Equity
CalPortland Company
Can Manufacturers Institute
Carolina Industrial Group for Fair Utility Rates
Carolina Utility Customers Association, Inc.
Century Aluminum
Chemistry Council of New Jersey
Council of Industrial Boilers Organization
Coalition of MISO Transmission Customers
Commercial Metals Company
Delaware Energy Users Group
Digital Realty
Domtar Corporation
Eramet Marietta Inc.
Ford Motor Company
Formosa Plastics Corporation, USA
Foundry Association of Michigan
Glass Packaging Institute
Industrial Energy Consumers of America
Illinois Industrial Energy Consumers
Indiana Cast Metals Association
Indiana Industrial Energy Consumers
Industrial Energy Consumers of Pennsylvania
Industrial Energy Users-Ohio
Industrial Minerals Association-North America
Iowa Business Energy Coalition
Iowa Industrial Energy Group, Inc.
Iron Mining Association of Minnesota
Lehigh Hanson, Inc.
LS Power Development, LLC
Maine Industrial Energy Consumer Group
Marathon Petroleum Company
Metalcasters of Minnesota
Messer Americas
Michigan Chemistry Council
Midwest Food Products Association
Minnesota Large Industrial Group
Multiple Intervenors, NY
National Council of Textile Organizations
National Retail Federation
North Carolina Manufacturers Alliance
Office of the People’s Counsel for the District of Columbia Ohio Cast Metals Association
Ohio Energy Group
Ohio Manufacturers’ Association
Oklahoma Industrial Energy Consumers
Olin Corporation
Owens-Illinois
Pennsylvania Energy Consumer Alliance
PJM Industrial Customer Coalition
Portland Cement Association
Public Citizen, Inc.
R Street Institute
Resale Power Group of Iowa
Retail Industry Leaders Association
Riceland Foods, Inc.
Rio Tinto
Steel Manufacturers Association
Texas Cast Metals Association
Vallourec STAR LP
Vinyl Institute
Virginia Manufacturers Association
West Virginia Energy Users Group
Wisconsin Cast Metals Association
Wisconsin Industrial Energy Group

[1] Electricity, U.S. Energy Information Administration, https://www.eia.gov/electricity/ Nationwide demand was 3.76 billion MWh in 2014 and 3.72 billion MWh in 2020

[2] 2 Brattle Group: Cost Savings Offered by Competition in Electric Transmission, https://www.brattle.com/wp content/uploads/2021/05/16726_cost_savings_offered_by_competition_in_electric_transmission.pdf

[3] NET-ZERO AMERICA: Potential Pathways, Infrastructure, and Impacts, Princeton University,
https://netzeroamerica.princeton.edu/?explorer=year&state=national&table=2020&limit=200

[4] S&P Global Market Intelligence Regulatory Research Associates Regulatory Focus: An Overview of Transmission Ratemaking in the U.S. – 2021 Update