Comments to FERC on Transmission Incentives

Here is a link to FERC’s May 19 press release on the reconsideration of their transmission incentive program.  The press release states “Comments are due [60] days after publication in the Federal Register.”

Here’s what FERC posted in the Federal Register.  The Notice of Inquiry has blanks where the comment deadline should be.  The Notice of Inquiry is dated May 19, so I am assuming that the comment period opened on May 19 and will run for 60 days — unless the actual publication date in the Federal Register is a little later, meaning that the comment period has not started yet.

Whatever the dates are, you will be pretty safe if you send comments in a couple of weeks.  The Notice of Inquiry provides links and instructions for posting comments.

So now is the time to let FERC know about how bad you think the transmission incentive program is.  Here are a few things that I have learned in the PATH fight –

  1. The US electrical system does not need new long distance transmission capacity at all.  What we need is new, small scale, non-polluting generation capacity AT the point of electrical load.
  2. Incentives are needed only for installation of new small scale solar and wind facilities in local communities, on businesses and at residences.  FERC should also be incentivizing new business and cooperative structures to support the new distributed electrical systems we need to support this new wave of innovation.
  3. Incentives should not go to new transmission projects.  FERC should be focusing on rebuilding existing transmission infrastructure with technologies that use innovative equipment and materials to increase thermal and current capacities without the seizure of new rights of way.
  4. The transmission incentive system was created in the 2005 Energy Policy Act when the US was in the middle of an economic bubble which has since collapsed.  It is also clear that the long term trend in both residential and industrial electrical demand is falling in the US.  There is simply no need to build new transmission capacity when rebuilding existing lines will provide the smaller incremental capacity the US really needs to transition to a renewable, distributed generation system.
  5. The cost of coal is rising.  The disaster at the Fukushima nuclear plant in Japan has demonstrated that nuclear power generation remains untested and inherently unsafe.  Any transmission incentives that FERC approves should not provide any incentives for the continuation or expansion of coal or nuclear power and should focus exclusively on the promotion of renewable sources, in particular, solar, wind and hydro-electric power.
  6. FERC-granted transmission incentives should immediately terminate when the project is dropped from the long term planning of the regional transmission organizations that govern the project.  Currently, there is no FERC process for terminating transmission incentives.  As time goes on, if this situation continues, the US will be littered with dead transmission projects that are continuing to generate obscene profits for their owners with no new transmission construction “incentivized” or happening.  If a project returns to the RTO plan, a new application must be filed.

If you want to file your comments in a good old fashioned letter, here is a template which includes all the information you need to properly file the comment with FERC, just add your own comments in the body of the letter.

If you don’t like FERC’s incentive program, now’s the time to quit bitching and start writing.