CEN letter to FERC Commissioner Mark Christie


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RE: Docket No. RM21-17-000 

Dear Commissioner Christie, 

This letter is being sent to you from the Conservative Energy Network (CEN) regarding the Federal Energy Regulatory Commission’s (FERC or Commission) pending regional transmission and cost allocation rule. CEN exists to educate and lead conservatives on all conversations regarding a clean energy future. CEN works to encourage the development of an electric power grid, planning process, and regulatory framework that leverages the powerful forces of free markets over heavy-handed government mandates.  

Our national network, active in 24 states across the country, believes this market-based approach will lead to the most effective and efficient outcomes for consumers, the economy, and ultimately improve reliable grid operations. In our view, the proposed planning rule that FERC is considering will be a major step towards achieving that mission if implemented properly.

In your capacity as a Commissioner of the Federal Energy Regulatory Commission, we urge you to support the agency’s pending regional transmission planning and cost allocation rule as soon as practicable. As conservatives, CEN recognizes the importance of regulatory restraint when addressing challenges facing the nation, however, we find that this proposed rule is reasonable and in line with the duties of FERC. Strong leadership is needed regarding transmission planning to create a more secure and reliable energy grid. In the case of this proposed rule, FERC is well positioned to provide that leadership. FERC has undertaken extensive work on this proposal for well over two years and it is now time for the agency to issue a final rule strong enough to fulfill the NOPR’s promise to “remedy deficiencies in the Commission’s existing regional transmission planning and cost allocation requirements.”

We believe that any rule from the Commission should represent consensus and compromise which ensures strong, long-lasting, and future-focused reforms to transmission planning. Load, generation, and weather patterns are changing, as the grid resilience issues of the past year have demonstrated. FERC’s rule should make sure that these factors are addressed and accounted for accordingly by transmission planners. It is reasonable and imperative that the rule requires planning for the energy mix as it will look 20 years from today, not just its current formation. 

Further, economic and reliability energy-related benefits to electricity consumers must be specified to identify transmission investments that result in fair and reasonable rates. State input regarding cost allocation can and should be incorporated, along with a means of resolving disagreements and allocating costs to customers in a way that is “roughly commensurate” with the benefits noted above.

FERC’s rule should also consider potential future technology innovations as well as currently underutilized innovations for long term transmission and cost-allocation planning. The use of battery-storage sites within the transmission grid and the use of technology to improve line ratings are examples of how innovative technology may be incorporated in the planning process as it affects both the capital investment and consumer benefit elements of cost allocation. Taking a technology neutral stance and approach to rulemaking allows for the incentivized development and utilization of new transmission technologies while reinforcing the goal of planning for the future.

A weak rule – that is, any rule that does not include these features – will fail to support the modernized grid Americans need. A robust rule with these features will help grow the economy, keep people safe during extreme weather, and decrease consumer costs. The consequences of continued inaction are numerous and would be to the detriment of all. We stand ready to work with you to help finalize a strong regional transmission and cost allocation planning rule. 



John Szoka, CEO

Conservative Energy Network