US DoE Reopening Congestion Study Process

The US Dept. of Energy has just published information about its periodic review of its national congestion studies for the designation of National Impact Electric Transmission Corridors or NIETCs.  This is a little surprising, considering that the federal 9th Circuit Court of Appeals voided DoE’s last congestion study.

DoE is required by the 2005 Energy Policy Act to update the congestion study every three years, so I guess they are just going ahead with it.  We all missed the last congestion study, which was seriously distorted because of a lack of critical public comments.

Here’s your chance.  Quit bitchin’ and file your comments.  Here’s the link to the announcement in the Federal Register.

The announcement includes the following information about the content of public comments:

All comments filed in response to today’s notice should be marked ‘‘Re Preparation of the 2012 Congestion
Study,’’ and sent to the Department in the manner indicated in the ADDRESSES section of this notice. In written comments in response to this notice and at the regional workshops, DOE requests States, utilities, regional transmission organizations (RTOs), independent system operators (ISOs), and other stakeholders to describe changes in their respective areas since 2009 that affect the location, duration, frequency, magnitude, and significance of transmission congestion, including related transmission constraints. Special attention should be given to the question of how to gauge the magnitude or significance of congestion using publicly available data, including FERC 890 filings. In addition, DOE is particularly interested in comments that speak to the most appropriate and effective methods for distinguishing between the effects of technical limits on line loadings and possible contractual limits on the use of those same lines.

This all looks rather technical, but don’t worry.  Let them know what you have learned from the PATH fight.  I’m going to focus on the impact of demand resources in PJM on reducing congestion in eastern load zones.

Here are deadlines and addresses for submitting your comments:

DOE requests that commenters submit such materials as they become available, but no later than January 31, 2012.
ADDRESSES: You may submit written comments to http://energy.gov/oe/congestion-study-2012, or by mail to the Office of Electricity Delivery and Energy Reliability, OE–20, U.S. Department of Energy, 1000 Independence Avenue SW., Washington, DC 20585. The following electronic file formats are acceptable: Microsoft Word (.doc), Corel Word Perfect (.wpd), Adobe Acrobat (.pdf), Rich Text Format (.rtf), plain text (.txt), Microsoft Excel (.xls), and Microsoft PowerPoint (.ppt).

You may also want to remind the DoE that the 9th Circuit Court of Appeals required them to complete a full environmental impact statement for any NIETCs that they designate as a result of the congestion study update.

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