Comments of Joint Customers on Transmission Planning and Cost Management
Transmission Planning and Cost Management | Docket Nos. AD22-8-000
Joint Federal-State Task Force on Electric Transmission | AD21-15-000
Post-technical Conference Comments of Joint Customers
I. Issue Summary and ECA Introduction
On October 6, 2022, the Federal Energy Regulatory Commission (FERC or Commission) convened a technical conference on transmission planning and cost management. On December 23, 2022, the Commission issued a notice inviting post-technical conference comments, especially in five areas: local transmission planning and asset management, project implementation and variance analysis, independent transmission monitor, formula rates and prudence practices, and federal and state regulation of transmission facilities. These issue areas have important synergies with separate reforms proposed by the Commission in the April 2022 Notice of Proposed Rulemaking (Regional Planning NOPR) on improving regional transmission planning, cost allocation and generator interconnection.3 The Electricity Customer Alliance (ECA) has a keen interest in transmission planning and costs because it aggregates perspectives across diverse transmission customer groups responsible for incurring the costs of new transmission development.
The Citizens Utility Board of Illinois, Electricity Consumers Resource Council, Maryland Office of People’s Counsel, New Jersey Division of Rate Counsel, Office of the People’s Counsel for the District of Columbia, Greg Poulos-Executive Director of Consumer Advocates of PJM States, acting in his individual capacity, Public Citizen, Inc., and R Street Institute are signing onto this comment, not as official members of ECA but as part of its broader mission to align diverse commercial, industrial, and residential electricity customers, retail consumer advocates, trade associations, and public interest groups who want to increase transparency and accountability, specifically to ensure that customers are able to better participate and adapt to meet the needs of a changing electric grid. As a coalition, ECA also seeks to convene, harness, and scale an aligned customer voice to improve the nation’s electricity systems, providing increased value to all energy customers.