Comments of the R Street Institute 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 the R Street Institute
I. Issue Summary
On Oct. 6, 2022, the Federal Energy Regulatory Commission (FERC or Commission) convened a technical conference on transmission planning and cost management. On Dec. 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 (NOPR) on improving regional transmission planning, cost allocation and generator interconnection. The R Street Institute (RSI) submits these comments independently and will also file jointly with the Electricity Customer Alliance and Independent Transmission Monitor Coalition.