How FERC Can Fix Transmission Planning

To deploy the clean energy projects customers want and enable a cost effective and reliable transition to the carbon-free electricity grid of the future, we must fix regional and interregional transmission planning. 

One of the most telling data points is a September 2022 Princeton University study that found unlocking the full potential of the Inflation Reduction Act (IRA) and achieving an economy-wide 40% reduction in greenhouse gas emissions by 2035 would require the nation’s transmission network to double or triple in size. If the nation continues at a business-as-usual pace in transmission development, over 80% of emission reductions the IRA could deliver by 2030 will be unrealized.  

In 2021, the Federal Energy Regulatory Commission (FERC), realizing the depth of this need, released an Advance Notice of Proposed Rulemaking on transmission planning. CEBA submitted initial and reply comments to this proceeding, laying out expansive recommendations and support. 

In April 2022, FERC released a Notice of Proposed Rulemaking (NOPR) on Transmission Planning (Docket No. RM21-17) to address long-term regional transmission planning processes. CEBA represented the customer voice in submitting initial comments and reply comments on the proceeding that highlight the need for open, coordinated, and transparent regional transmission planning processes.  

Overall, the NOPR is a positive step. However, FERC left many issues and recommendations on the table, such as cost allocation and the use of an Independent Transmission Monitor (ITM). We hope these issues will be addressed in future rulemakings. 

With over 200 stakeholders making initial comment submissions to FERC, CEBA’s comments gained attention and received coverage from several news outlets (including Utility Dive and S&P Global). A half dozen stakeholders also cited CEBA’s initial comments in their reply comments. 

At FERC’s Technical Conference on Regional Transmission Planning and Cost Management this past October, Adrienne Mouton-Henderson, CEBA’s director of market and policy innovation, spoke on a panel about regional transmission planning for reliability, demonstrating the industry importance of CEBA’s voice. Her comments at the conference were covered by national and energy trade press, including E&E News and Utility Dive, as well as States Newsroom, a syndicated news service, whose article appeared in newspapers across the country. 

What’s Next?

We continue the dialogue with FERC commissioners about transmission planning and reform and anticipate the release of subsequent rulemakings. Many future FERC decisions will hinge on who the commission’s next chair will be. Beyond FERC, we are engaging with the U.S. Department of Energy on Bipartisan Infrastructure Deal provisions such as the National Transmission Planning Study, and we remain active in federal discussions on reforming transmission permitting and siting.

Acknowledgments and Get Involved

We commend our members who worked with CEBA staff to express the customer voice in our comments. If you are interested in getting involved in CEBA’s regulatory work on transmission, email  

Learn more

Check out CEBA’s other advocacy for transmission expansion and planning reforms at the federal energy regulatory commission from October 2021 and December 2021.