Americans for a Clean Energy Grid calls for EPA to recognize the value of high-voltage transmission in Clean Power Plan

In comments submitted December 1 to the Environmental Protection Agency, Americans for a Clean Energy Grid (ACEG) emphasized the role of high-voltage transmission as a prerequisite to achieving the goals set out in the proposed Clean Power Plan rulemaking.

One of EPA’s “building blocks” to meeting the emissions standards calls for increased volumes of zero carbon-emitting energy resources, but these resources cannot be delivered to users without the necessary electricity infrastructure. EPA’s proposed rule calls for a fundamental overhaul of the nation’s power generation infrastructure, but ignores the related upgrades and expansions of the grid such changes to power sources would require.  Left unaddressed, the nation’s high-voltage system constrains the potential generation options, and leaves the lead-time mismatch of renewable projects (~2 years to completion) versus transmission lines (~10 years to completion) in place, a serious deterrent to anyone contemplating building transmission to connect renewable energy to markets.  Transmission lines may be “outside the fence,” ACEG points out, but without them nothing can happen “inside the fence” that matters, so it is self-evident that EPA should pay attention to their necessary planning, development, and integration as a key facet of the strategies states and utilities – which have jurisdiction and control over most transmission lines – must identify to curtail carbon emissions.  EPA failed to do so.

ACEG argues that states and utilities should be able to receive credit for providing the infrastructure necessary to unlock the nation’s most robust renewable resources. ACEG also argues that states should be required to work with utility and regional transmission planners to analyze transmission upgrades and expansions; that clear guidelines for quantifying, monitoring and verifying the effect of transmission upgrades and expansions could and should be established; that inclusion of transmission upgrades and expansions in state and regional plans should be incentivized; and that expedited processes for siting and permitting of transmission lines should also be incentivized.

In addition to the U.S.’s shorter-term commitments to reducing greenhouse gas emissions, the Obama Administration has adopted a longer-term goal based on the consensus of climate scientists of 80% reductions to U.S. greenhouse gas emissions by 2050. Without major infrastructure added to provide access to utility-scale renewable resources, there is no currently foreseeable pathway to reaching such goals. Not only is recognizing the value of transmission necessary to meet standards set under the law, but it will also put us on the only available path towards necessary future emissions reductions.

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