Notice2024-30493
Interregional Transfer Capability Study: Strengthening Reliability Through the Energy Transformation
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Published
December 27, 2024
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Energy DepartmentFederal Energy Regulatory Commission
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[Federal Register Volume 89, Number 248 (Friday, December 27, 2024)]
[Notices]
[Pages 105790-105983]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2024-30493]
[[Page 105789]]
Vol. 89
Friday,
No. 248
December 27, 2024
Part III
Department of Energy
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Federal Energy Regulatory Commission
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Interregional Transfer Capability Study: Strengthening Reliability
Through the Energy Transformation; Notice
Federal Register / Vol. 89, No. 248 / Friday, December 27, 2024 /
Notices
[[Page 105790]]
DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
Interregional Transfer Capability Study: Strengthening
Reliability Through the Energy Transformation
Notice of Request for Comments
On November 19, 2024, the North American Electric Reliability
Corporation (NERC) submitted to the Federal Energy Regulatory
Commission (Commission) an Interregional Transfer Capability Study (ITC
Study) pursuant to section 322 of the Fiscal Responsibility Act of 2023
(Fiscal Responsibility Act).\1\ On November 25, 2024, the Commission
issued a Notice of Request for comments stating that all interested
persons are invited to file comments on this ITC Study. This
supplemental notice is issued to include the ITC Study and associated
NERC transmittal letter.\2\ Comments should be filed no later than 60
days after the date of publication of this supplemental notice in the
Federal Register. We request the public to submit comments in the
format indicated below.
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\1\ Fiscal Responsibility Act of 2023, Public Law 118-5, 137
Stat 10, sec. 322 (2023).
\2\ The full text of this document is available on eLibrary in
PDF and Microsoft Word formats (with color graphics) for viewing,
printing, and/or downloading.
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In June 2023, Congress passed the Fiscal Responsibility Act, which
requires the Commission-approved Electric Reliability Organization
(i.e., NERC),\3\ in consultation with each regional entity and each
transmitting utility \4\ that has facilities interconnected with a
transmitting utility in a neighboring transmission planning region, to
conduct a study of total transfer capability \5\ between transmission
planning regions. The Fiscal Responsibility Act requires the ITC Study
to include:
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\3\ Federal Power Act (FPA) section 215 provides that the
Commission may certify an Electric Reliability Organization, the
purpose of which is to develop mandatory and enforceable Reliability
Standards, subject to Commission review and approval. 16 U.S.C.
824o(c). The Commission subsequently certified NERC as the Electric
Reliability Organization. N. Am. Elec. Reliability Corp., 116 FERC ]
61,062, order on reh'g and compliance, 117 FERC ] 61,126 (2006),
aff'd sub nom. Alcoa, Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009).
\4\ Transmitting utility is defined in 16 U.S.C. 796 as ``an
entity (including an entity described in section 824(f) of [title
16]) that owns, operates, or controls facilities used for the
transmission of electric energy--(A) in interstate commerce; (B) for
the sale of electric energy at wholesale.''
\5\ 18 CFR 37.6(b)(1)(vi) (2024).
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(1) Current total transfer capability between each pair of
neighboring transmission planning regions.
(2) A recommendation of prudent additions to total transfer
capability between each pair of neighboring transmission planning
regions that would demonstrably strengthen reliability within and among
such neighboring transmission planning regions.
(3) Recommendations to meet and maintain total transfer capability
together with such recommended prudent additions to total transfer
capability between each pair of neighboring transmission planning
regions.
The Fiscal Responsibility Act requires NERC to submit the ITC Study
to the Commission no later than 18 months after the date of enactment
of the Act (i.e., by December 2, 2024). After the ITC Study is
submitted to the Commission, the Commission must publish the study for
public comment and, no later than 12 months after the end of the public
comment period, submit a report on its conclusions to Congress and
include recommendations, if any, for statutory changes.\6\
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\6\ Fiscal Responsibility Act of 2023, Public Law 118-5, 137
Stat 10, sec. 322 (2023).
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Comments may be filed electronically via the internet.\7\
Instructions are available on the Commission's website <a href="http://www.ferc.gov/docs-filing/efiling.asp">http://www.ferc.gov/docs-filing/efiling.asp</a>. For assistance, please contact
FERC Online Support at <a href="/cdn-cgi/l/email-protection#9adcdfc8d9d5f4f6f3f4ffc9efeaeaf5e8eedafcffe8f9b4fdf5ec"><span class="__cf_email__" data-cfemail="70363522333f1e1c191e15230500001f020430161502135e171f06">[email protected]</span></a> or toll free at 1-
866-208-3676, or for TTY, (202) 502-8659. Although the Commission
strongly encourages electronic filing, documents may also be paper-
filed. To paper-file, submissions sent via the U.S. Postal Service must
be addressed to: Federal Energy Regulatory Commission, Office of the
Secretary, 888 First Street NE, Washington, DC 20426. Submissions sent
via any other carrier must be addressed to: Federal Energy Regulatory
Commission, Office of the Secretary, 12225 Wilkins Avenue, Rockville,
Maryland 20852.
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\7\ See 18 CFR 385.2001(a)(1)(iii) (2024).
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For more information about this Notice, please contact Jessica L.
Cockrell at <a href="/cdn-cgi/l/email-protection#b9d3dccacad0dad897dad6dad2cbdcd5d5f9dfdccbda97ded6cf"><span class="__cf_email__" data-cfemail="b1dbd4c2c2d8d2d09fd2ded2dac3d4ddddf1d7d4c3d29fd6dec7">[email protected]</span></a> or 202-502-8190. For legal
information, please contact Gonzalo E. Rodriguez at
<a href="/cdn-cgi/l/email-protection#3c5b5352465d5053124e53584e555b4959467c5a594e5f125b534a"><span class="__cf_email__" data-cfemail="bed9d1d0c4dfd2d190ccd1daccd7d9cbdbc4fed8dbccdd90d9d1c8">[email protected]</span></a> or 202-502-8568.
Dated: December 17, 2024.
Debbie-Anne A. Reese,
Secretary.
Requested Format for ITC Study Comments
We request that commenters use the following format, based on the
correlated headings in the ITC Study submittal, to indicate which
aspects of the submittal are being addressed in a comment. Commenters
need not address all headings outlined below.
Appendix A: Interregional Transfer Capability Study 2024
A. Chapter 1: The Reliability Value of Transfer Capability
B. Chapter 2: Overview of ITC Study Scope and Terminology
1. ITC Study Scope
2. Stakeholder Participation
3. General Comments on the ITC Study Scope and Terminology
C. Transfer Capability Analysis (Part 1)
1. Chapter 3: Transfer Capability (Part 1) Study Process
2. Chapter 4: Transfer Capability (Part 1) Study Results
3. Other Comments on the Transfer Capability Analysis (Part 1)
D. Recommendations for Prudent Additions To Transfer Capability
(Part 2) and Recommendations To Meet and Maintain Transfer
Capability (Part 3)
1. Chapter 5: Prudent Additions (Part 2) Inputs
2. Chapter 6: Prudent Additions (Part 2) Process, Including
Energy Margin Analysis Results
3. Chapter 7: Prudent Additions (Part 2) Recommendations
4. Chapter 8: Prudent Additions (Part 2) Sensitivity Analysis
5. Chapter 9: Prudent Additions (Part 2) Transmission Planning
Region-Specific Results
6. Chapter 10: Meeting and Maintaining Transfer Capability (Part
3)
7. Other Comments on Prudent Additions (Part 2)
8. Other Comments on Meeting and Maintaining Transfer Capability
(Part 3)
E. Future Work
F. ITC Study Appendices (A-J)
G. Additional Comments Outside the Specific Report Sections
United States Of America Before the Federal Energy Regulatory
Commission
North American Electric Reliability Corporation, Docket No. _____
North American Electric Reliability Corporation
Interregional Transfer Capability Study as Directed in the Fiscal
Responsibility Act of 2023
Candice Castaneda, Senior Counsel, North American Electric
Reliability Corporation, (202) 400-3000, <a href="/cdn-cgi/l/email-protection#6f0c0e010b060c0a410c0e1c1b0e010a0b0e2f010a1d0c41010a1b"><span class="__cf_email__" data-cfemail="a4c7c5cac0cdc7c18ac7c5d7d0c5cac1c0c5e4cac1d6c78acac1d0">[email protected]</span></a>.
Counsel for the North American Electric Reliability Corporation.
November 19, 2024.
Table of Contents
I. Executive Summary
I. Introduction to NERC and the ERO Enterprise
II. Overview of the Interregional Tranfer Capability Study
a. Calculating Current Total Transfer Capability
[[Page 105791]]
b. Identifying Prudent Additions to Transfer Capability to
Demonstrably Strengthen Reliability
c. Recommendations To Meet and Maintain Sufficient Transfer
Capability
III. Consultation With Regional Entities and Transmitting Utilities
IV. Conclusion
Appendix A--Interregional Transfer Capability Study 2024
Appendix B--List of Stakeholder Engagement Activities
Appendix C--Letters to Transmitting Utilities Regarding
Interregional Transfer Capability Study
Appendix D--Advisory Group Roster, ITCS Study Team Roster, and
Schedule of Monthly Public Advisory Group Meetings
United States of America Before the Federal Energy Regulatory
Commission
North American Electric Reliability Corporation, Docket No. _____
North American Electric Reliability Corporation
Interregional Transfer Capability Study as Directed in the Fiscal
Responsibility Act of 2023
The North American Electric Reliability Corporation (``NERC'')
respectfully submits the Interregional Transfer Capability Study
(``ITCS'' or ``Study'') directed by the United States (``U.S.'')
Congress in the Fiscal Responsibility Act of 2023 (``Fiscal
Responsibility Act'') for Federal Energy Regulatory Commission
consideration.\8\ The ITCS was prepared by NERC as the Electric
Reliability Organization (``ERO'') \9\ in consultation with NERC's
six Regional Entities (together with NERC, the ``ERO Enterprise'')
\10\ and transmitting utilities.
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\8\ Fiscal Responsibility Act, H.R. 3746 (2023) [hereinafter
Fiscal Responsibility Act]. See Section 322 of the Fiscal
Responsibility Act (providing, ``The Electric Reliability
Organization . . . in consultation with each regional entity . . .
and each transmitting utility (as that term is defined in section
3(23) of such Act) that has facilities interconnected with a
transmitting utility in a neighboring transmission planning region,
shall conduct a study of total transfer capability as defined in
section 37.6(b)(1)(vi) of title 18, Code of Federal Regulations,
between transmission planning regions that contains the following:
(1) Current total transfer capability, between each pair of
neighboring transmission planning regions.
(2) A recommendation of prudent additions to total transfer
capability between each pair of neighboring transmission planning
regions that would demonstrably strengthen reliability within and
among such neighboring transmission planning regions.
(3) Recommendations to meet and maintain total transfer
capability together with such recommended prudent additions to total
transfer capability between each pair of neighboring transmission
planning regions.'').
\9\ Rules Concerning Certification of the Electric Reliability
Organization; and Procedures for the Establishment, Approval, and
Enforcement of Electric Reliability Standards, Order No. 672, 114
FERC ] 61,104, order on reh'g, Order No. 672-A, 114 FERC ] 61,328
(2006) [hereinafter Order No. 672]. NERC was certified by the
Commission as the ERO, pursuant to Sec. 215(c) of the Federal Power
Act (``FPA''), by Commission order issued July 20, 2006. Order
Certifying the North American Electric Reliability Corporation as
the Electric Reliability Organization and Ordering Compliance
Filing, 116 FERC ] 61,062 (2006) [hereinafter NERC ERO Certification
Order].
\10\ The Regional Entities are (i) Midwest Reliability
Organization (``MRO''); (ii) Northeast Power Coordinating Council,
Inc. (``NPCC''); (iii) ReliabilityFirst Corporation
(``ReliabilityFirst''); (iv) SERC Reliability Corporation
(``SERC''); (v) Texas Reliability Entity, Inc. (``Texas RE''); and
(vi) Western Electricity Coordinating Council (``WECC''). Please
note, unless otherwise defined herein, all capitalized terms should
be assigned the meanings reflected in the NERC Glossary posted on
NERC's website.
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Over the past 15 months, NERC has developed the attached ITCS
(Appendix A) in consultation with stakeholders to provide:
(i) Current total transfer capability (``TTC'' or ``transfer
capability'') between each pair of neighboring transmission planning
regions in the U.S.; \11\
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\11\ In addition, results that include transfer capabilities
between the U.S. to Canada and between Canadian provinces is planned
for the first quarter of 2025. While evaluating Canada is outside
the specific congressional mandate, the interconnectedness of the
North American BPS warrants analysis of Canada.
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(ii) Recommendations for technically prudent additions to TTC
between pairs of neighboring transmission planning regions where
these additions would demonstrably strengthen reliability; \12\
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\12\ Prudence means whether the recommendations are the type
that a reasonable entity would make in good faith under the same
circumstances, and at the relevant point in time. See infra Section
II.b. The ITCS is not an evaluation of economics, siting, or
environmental impacts.
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(iii) Recommendations on how to meet and maintain TTC now and as
enhanced in response to the ITCS findings.
As stated herein and detailed in the attached materials, the
ITCS is the first-of-its-kind assessment of transmission transfer
capability under a common set of assumptions.\13\ Transmission
assessments, like the ITCS, are crucial to mitigating future risks
to Bulk Power System (``BPS'') reliability, although other
approaches beyond transmission (such as local generation or demand-
side solutions) can also mitigate future energy risks. The ITCS
focuses on transfer capability in accordance with the congressional
directive, while acknowledging that other processes and pending
projects may help support a reliable future grid. The ITCS is not
designed to be a transmission plan or blueprint.
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\13\ Transfer capability or ``TTC'' is the amount of electric
power that can be moved or transferred reliably from one area to
another area of the interconnected transmission system by way of all
transmission lines (or paths) between those areas under specified
system conditions. 18 CFR 37.6(b)(1)(vi).
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The ITCS demonstrates that sufficient transfer capability and
resources exist at present to maintain energy adequacy under most
scenarios. As discussed below and in the attached ITCS, however,
when calculating current transfer capability and projected future
conditions,\14\ the ITCS identifies potential energy inadequacy
across several transmission planning regions in the event of extreme
weather. This finding confirms congressional and electric industry
concerns that North American transmission infrastructure may become
insufficient to maintain energy adequacy when considering the
changing resource mix, extreme weather events, and increasing
demand. Therefore, using the assumptions underlying the analysis,
the ITCS recommends an increase of 35 GW of transfer capability
across different regions as technically prudent additions to
demonstrably strengthen reliability. The ITCS bases its analysis of
prudence and the extent to which recommendations would demonstrably
strengthen reliability according to the anticipated impact of the
recommendations on BPS reliability in terms of energy adequacy.
Further, the ITCS recommends region-specific enhancements to
transfer capability, because a one-size-fits all approach across the
U.S. may be inefficient and ineffective.
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\14\ Via an energy margin analysis that uses a ten-year forward-
looking case that accounts for extreme weather, resources, and
demand growth as described below and detailed in Appendix A.
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The ITCS is an essential element of the continuing transmission
discussion in North America. The ITCS demonstrates a significant
opportunity to improve the use of surplus resources when they are
available during extreme weather events and shows how interregional
transmission can maximize the use of local resources, including
storage and demand response. Further, it highlights the continuing
importance of integrated transmission and resource planning, as
increasing transfer capability without surplus available energy
would be inefficient. NERC looks forward to the Commission's
proceeding to examine the ITCS, opportunities identified therein,
and stakeholder comments in anticipation of the Commission's report
to U.S. Congress.
I. Executive Summary
The Bulk Power System is a complex grid that has evolved over
the past several decades to include an integrated network of
generation, transmission, and distribution across vast geographic
areas. NERC is focused on assuring the reliability of the BPS
throughout the ongoing North American energy transformation. As the
grid modernizes, governmental authorities and the electric industry
are rising to the challenge to ensure that continued reliability
accompanies that growth.
On June 3, 2023, the President signed into law the Fiscal
Responsibility Act in which Congress (as part of measures associated
with the debt ceiling) required NERC to conduct an assessment by
December 2, 2024 of the total transfer capability between
transmission planning regions.\15\ The resulting ITCS analyzes the
amount of energy that can be moved or transferred reliably from one
area to another area of the interconnected transmission systems.
This transfer capability is a measure of the system's ability to
address energy deficiencies by relying on resources in neighboring
regions and is a key component of a reliable and resilient BPS.
Recent and
[[Page 105792]]
continuing resource mix changes require greater access and
deliverability of resources between neighboring systems to maintain
reliability, particularly during widespread, extreme weather
conditions.
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\15\ Supra note 1.
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Ensuring a transmission system with sufficient transfer
capability between transmission planning regions is important to
support energy adequacy. In the interest of public health, safety,
and security, the electric industry must continue advancing improved
planning to support reliable energy supplies under an evolving grid
with more frequent extreme weather conditions. As a result of the
changing resource mix and extreme weather, interregional energy
transfers play an increasingly pivotal role.\16\ NERC assessments
and experiences during recent events, such as the Western
Interconnection Heatwaves of 2020 and 2022, Winter Storm Uri in
2021, and Winter Storm Elliott in 2022, demonstrate that action is
warranted to support energy adequacy going forward. More transfer
capability and a carefully planned resource mix are desirable to
address these identified challenges (such as extreme weather,
existing resource retirements,\17\ and natural gas reliance), as
well as the ongoing electrification of the economy with its growing
transportation sector, industrial loads, and data centers. The ITCS
is an integral part of that discourse by providing an independent,
reliability-focused assessment of the extent of transfer capability
across the transmission system and opportunities to harness that
potential as we collectively prepare for the future.
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\16\ An explanation of the grid can be found on the U.S. Energy
Information Administration website. U.S. Energy Information
Administration, Electricity Explained (Mar. 26, 2024), <a href="https://www.eia.gov/energyexplained/electricity/">https://www.eia.gov/energyexplained/electricity/</a> (including detailed
subtopics under ``Also in Electricity Explained'').
\17\ See Appendix A, ITCS at p. 1 and Chapter 11 (summarizing
ITCS limitations and potential further considerations).
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In the first part of the ITCS, NERC calculates current transfer
capability in a manner that combines base transfer levels together
with first contingency incremental transfer capability for each of
the winter and summer seasons, (see infra Section II.a.). Based on
these calculations, NERC determines that transfer capability varies
widely across North America with import capability anywhere between
1% to 92% of the associated peak loads. The ITCS shows that transfer
capability varies seasonally, regionally, and under different system
conditions. The ITCS also generally finds lower transfer capability
in the Mountain States, Great Plains, Southwest, and Northeast, with
greater capability in the West Coast, Great Lakes, and Mid-Atlantic
areas. The magnitude of transfer capability is not itself a measure
of energy adequacy, however, these findings informed the second part
of the ITCS.
The second part of the ITCS contains an energy margin analysis
that enabled NERC to identify whether a particular transmission
planning region would be at risk for energy inadequacy considering
the calculated TTCs and extreme weather events. The ITCS
characterizes this risk for energy inadequacy as a ``deficiency.''
In each scenario where the ITCS identifies a deficiency in a
transmission planning region, NERC further applied a six-step
process to examine the extent to which additional transfer
capability could mitigate that deficiency and thereby demonstrably
strengthen reliability.\18\ The Part 1 TTC calculation (which
includes simultaneous import capability analysis) together with the
Part 2 prudent additions analysis (which includes energy margin
analysis of past weather events applied to the projected resource
mix and demand) ensure the reasonableness and therefore prudence of
ITCS recommended additions to transfer capability. The last part of
the ITCS provides recommendations to meet and maintain transfer
capability. The resulting recommendations identify directional
(rather than prescriptive) guidance for policymakers and industry.
The ITCS provides a roadmap for understanding where it may be
beneficial to enhance transmission to support a reliable future
grid, without mandating specific projects or a minimum level of
transfer capability.
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\18\ The energy margin analysis (which identified the
deficiencies) constitutes steps 1 and 2 of the 6-step process.
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The ITCS is a unique assessment centered on reliability.
Transmission planners, regional transmission organizations/
independent system operators (``RTOs/ISOs''), and policymakers might
consider other factors such as economics, environmental effects, and
broader policy objectives when deciding which solutions to implement
to address reliability issues. Different markets, RTOs/ISOs, or
regions of the U.S. may have different approaches to evaluate
transfer capability and prudent additions thereto. The ITCS, for
example, in some instances subdivided RTO/ISO and Commission Order
No. 1000 areas to avoid masking issues between neighboring
transmitting utilities within the scope of the Congressional
directive. The ERO Enterprise approach was specifically designed to
evaluate TTC and potential prudent additions to transfer capability
that would demonstrably strengthen reliability without regard to
specific market structures, economic considerations, or policy
matters in the expectation that the Commission, U.S. Congress,
States, and industry will use NERC's ITCS as part of this broader
evaluation.
Based on the analysis in Part 2 of the ITCS, NERC identifies
that in the present year, there are relatively few deficiencies
across transmission planning regions. As a result, the ITCS suggests
that existing infrastructure is generally sufficient at this time to
maintain energy adequacy under most scenarios (barring severe
conditions such as limitations on gas generation performance during
cold weather and natural gas production and transportation
challenges for electric generators). This conclusion also
establishes 2024 as a useful reference point for future comparisons.
Nevertheless, when examining the ten-year forward-looking case
that accounts for the future resource mix and forecasted load,
energy inadequacy was identified across almost half of the studied
transmission planning regions.\19\ This confirms congressional and
electric industry concern that, given the changing resource mix,
extreme weather, and anticipated demand, transmission infrastructure
may place a strain on energy adequacy in the future. As a result,
based on calculated deficiencies and the broader six-step approach
to identify prudent additions to demonstrably strengthen
reliability, the ITCS recommends 35 GW of additional transfer
capability across different areas of the U.S. As discussed in
Section II.b. below, transmission planning regions across North
America would benefit from increased transfer capability. Since the
needed import capability, as analyzed, varied significantly across
the U.S., a one-size fits all requirement or approach to additional
transfer capability is expected to be inefficient and ineffective.
The increased transfer capability recommended in the ITCS, in
addition to other measures outside of its scope, such as resource
adequacy and fuel assurance, would demonstrably improve energy
adequacy under reasonably anticipated extreme conditions.\20\
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\19\ Specifically, 11 out of 23 transmission planning regions.
\20\ NERC highlights that transmission and TTC are part of a
more expansive equation underlying energy adequacy in a modern grid,
which includes matters such as available generation. The ITCS
relies, for example, on future resource assumptions. If these change
it could impact the energy margin analysis underlying the Part 2
analysis.
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Part 3 of the ITCS also provides recommendations how to meet and
maintain transfer capability. See infra Section II.c. These
recommendations should be taken, together with remainder of the
ITCS, as foundational insights for further discussions and decisions
on regulatory and legislative solutions. Planners, for example,
should consider conditions impacting their systems and those of
neighboring transmitting utilities while also considering resource
adequacy.\21\ The ITCS also does not evaluate particular projects.
Rather, under a holistic approach, the Study recommends how much
additional transfer capability at each interface would strengthen
the grid.
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\21\ Please see the ITCS for discussion of additional factors
that stakeholders may analyze.
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I. Notices and Communications
Notices and communications with respect to this filing may be
addressed to:
Sonia Rocha, Senior Vice President, General Counsel, and Corporate
Secretary, North American Electric Reliability Corporation, 1401 H
Street NW, Suite 410, Washington, DC 20005, 202-400-3000 office,
<a href="/cdn-cgi/l/email-protection#acdfc3c2c5cd82dec3cfc4cdecc2c9decf82c2c9d8"><span class="__cf_email__" data-cfemail="a9dac6c7c0c887dbc6cac1c8e9c7ccdbca87c7ccdd">[email protected]</span></a>
Candice Castaneda, Senior Counsel, North American Electric
Reliability Corporation, 1401 H St. NW, Suite 410, Washington, DC
20005, 202-400-3000, <a href="/cdn-cgi/l/email-protection#6102000f050802044f02001215000f040500210f0413024f0f0415"><span class="__cf_email__" data-cfemail="eb888a858f82888ec5888a989f8a858e8f8aab858e9988c5858e9f">[email protected]</span></a>
I. Introduction to NERC and the ERO Enterprise
Electricity is a key component of the fabric of modern society.
NERC's mission is to assure the effective and efficient reduction of
risks to the reliability and security of the grid. The vision of the
ERO Enterprise is a
[[Page 105793]]
highly reliable and secure North American BPS. The Regional Entities
help NERC support reliability across various interconnections with
differing needs and characteristics.\22\
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\22\ NERC's relationship with the Regional Entities is governed
by Regional Delegation Agreements or ``RDAs'' filed with the
Commission every five years. 18 CFR 39.8. A delegation agreement
shall not be effective until it is approved by the Commission. See
also, N. Am. Elec. Reliability Corp., 133 FERC ] 61,061 (2010),
order denying reh'g, 134 FERC ] 61,179 (2011), order on compliance
filing, 137 FERC ] 61,028 (2011). N. Am. Elec. Reliability Corp.,
153 FERC ] 61,135 (2015) (approving pro forma and individual RDAs,
subject to compliance filing) and N. Am. Elec. Reliability Corp.,
Docket No. RR15-12-001 (Mar. 23, 2016) (delegated letter order)
(accepting final pro forma and individual RDAs) (collectively ``2015
RDA Order''); and Order Conditionally Approving Revised Pro Forma
Delegation Agreement and Revised Delegation Agreements with Regional
Entities, 173 FERC ] 61,277 (2020).
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When Congress enacted the Energy Policy Act of 2005 \23\ and
section 215 of the Federal Power Act, it entrusted the Commission
with: (i) approving and enforcing rules to ensure the reliability of
the BPS; and (ii) certifying an ERO that would be charged with
developing and enforcing mandatory Reliability Standards, subject to
Commission approval, and with assessing reliability and adequacy of
the BPS in North America.\24\ Section 215 and Commission regulation
reflect certification of an ERO subject to Commission oversight.\25\
In 2006, the Commission certified NERC as the ERO.\26\
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\23\ Public Law 109-58, title XII, Sec. 1211(b), Aug. 8, 2005,
119 Stat. 946.
\24\ 16 U.S.C. 824o(a)(2). See also Sec. 824o(c) (providing the
ERO certification criteria). See also Public Law 109-58, title XII,
Sec. 1211(b), Aug. 8, 2005, 119 Stat. 946 (clarifying, ``[t]he
Electric Reliability Organization. . . and any regional entity
delegated enforcement authority. . . are not departments, agencies,
or instrumentalities of the United States Government.'').
\25\ Order No. 672 at PP 183-191.
\26\ See NERC ERO Certification Order.
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Consistent with NERC's responsibility to ``conduct periodic
assessments of the reliability and adequacy of the bulk-power system
in North America'' \27\ such as NERC's Long-Term Reliability
Assessment (``LTRA''), Summer Assessment, Winter Assessment, and
special assessments, the Fiscal Responsibility Act tasked NERC with
preparing the ITCS in consultation with the Regional Entities and
transmitting utilities.
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\27\ 16 U.S.C. 824o(g).
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II. Overview of the Interregional Tranfer Capability Study
The Fiscal Responsibility Act requires the ERO, in consultation
with the Regional Entities and transmitting utilities with
facilities neighboring another in a neighboring transmission
planning region (referred to generally as ``neighboring transmitting
utilities''), to conduct a study of total transfer capability (also
known as ``TTC'') between transmission planning regions that
contains:
(1) Current total transfer capability between each pair of
neighboring transmission planning regions.
(2) A recommendation of prudent additions to total transfer
capability between each pair of neighboring transmission planning
regions that would demonstrably strengthen reliability within and
among such neighboring transmission planning regions.
(3) Recommendations to meet and maintain total transfer
capability together with such recommended prudent additions to total
transfer capability between each pair of neighboring transmission
planning regions.\28\
---------------------------------------------------------------------------
\28\ Supra note 1.
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Consistent with NERC's collaborative process and congressional
directive, the ITCS was prepared over a 15-month period with
significant stakeholder engagement, as discussed in Section III
below and reflected in Appendices B through D. The ITCS examined
current TTC as Part 1 of the analysis. Part 2 of the Study completed
an energy margin analysis that compared TTC against 12 weather years
(including extreme weather) to identify transmission planning region
energy deficiencies that warrant prudent additions to TTC to
demonstrably strengthen reliability.\29\ As Part 3 of the ITCS, the
ITCS recommended methods to meet and maintain current TTC and
enhanced TTC. These recommendations interpreted the ITCS as part of
the broader discourse between the Commission, U.S. Congress, States,
other policymakers, and the electric industry to leverage the ITCS
findings along with more specific regional, policy, market,
economic, and environmental considerations. Finally, the ERO
Enterprise plans to continue regular assessments of transfer
capability that will consider the latest developments in resource
mixes, transmission infrastructure, new load projections, and
changing weather and climate patterns.
---------------------------------------------------------------------------
\29\ The 12 weather years to ensure the ITCS examined extreme
weather were selected from 2007-2023 and are non-contiguous.
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a. Calculating Current Total Transfer Capability
In accordance with the Fiscal Responsibility Act, the
fundamental question of the ITCS is the ability of the BPS to
support transfers of energy between transmission planning regions
when needed to ensure adequate energy to meet demand. The first
required component of the ITCS is calculating current transfer
capability, or TTC, between pairs of neighboring transmission
planning regions.\30\
---------------------------------------------------------------------------
\30\ Supra note 1.
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To calculate TTC, the ITCS study team, comprised of ERO
Enterprise staff and consultants, first determined appropriate
transmission planning regions for purposes of the Study after
coordinating with the ITCS Advisory Group. To establish transmission
planning regions for purposes of the Study, NERC, working with the
Regional Entities, selected a set of interfaces that included all
pairs of neighboring transmission planning regions to enable the
ITCS performance of transfer analysis from source (exporting) region
to sink (importing), and vice versa. Only electrically connected
neighboring systems were evaluated to identify the transmission
planning regions for purposes of Part 1 of the ITCS.\31\ The ITCS
regions were smaller than the Commission's Order No. 1000 regions
and those that RTOs/ISOs might use to provide a more granular
analysis of potential TTC limitations and to enable the ITCS to
identify key constraints to interregional TTC.
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\31\ Some geographic neighbors that were not electrically
connected were evaluated as potential new connections in Part 2 of
the ITCS as NERC evaluated potential recommendations to enhance
transfer capability.
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As reflected in NERC's August 2024 posted materials, the
transmission planning regions were established as follows:
[[Page 105794]]
[GRAPHIC] [TIFF OMITTED] TN27DE24.052
After the identification of transmission planning regions, the
ITCS calculated TTC according to the following steps: \32\
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\32\ See ITCS Appendix A (providing detailed explanation on the
Study and its design).
---------------------------------------------------------------------------
(i) Select base cases using relevant Eastern Interconnection and
Western Interconnection base cases created through Reliability
Standard MOD-032-1 processes; \33\
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\33\ Base cases are computer models that simulate the behavior
of the electrical system under various conditions as a snapshot in
time. Base cases were not required for ERCOT and Qu[eacute]bec
Interconnections for purposes of the ITCS as they were only tied
with the Eastern Interconnection via dc ties. Also, small ERCOT dc
ties to Mexico were omitted from evaluation and the ERCOT-Mexico
interface was outside the scope of the document.
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(ii) Calculate TTC using Area Interchange method as the sum of
base transfer levels together with first contingency incremental
transfer capability; \34\
---------------------------------------------------------------------------
\34\ Contingencies were based on NERC Reliability Standard TPL-
001-5.1 category P1 contingencies (100 kV and above).
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(iii) Adjust for facility monitoring criteria and thresholds to
prevent undue limitation of transfer capability results based on
heavily loaded, electrically distant elements to avoid the
appearance of artificially constrained TTC;
(iv) Ensure special interface considerations (such as pertinent
remedial action schemes) are understood and properly reflected in
study results; and
(v) Analyze total import capabilities of each transmission
planning region (although not required under the Fiscal
Responsibility Act) as technically requisite to appropriately model
system capability for purposes of the Part 2 analysis of any prudent
enhancements to TTC.
This analysis identified current TTC as illustrated in the maps
discussed in more detail in the ITCS at Appendix A. These TTC
results are highly dependent on the base cases and modeling
assumptions described in the ITCS. The ITCS did not attempt to
optimize dispatch or topology to maximize TTC, just as it also was
designed to avoid underestimating TTC. The ITCS used the steps
highlighted above to avoid the appearance of artificially
constrained TTC.\35\
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\35\ As this is a study, observed TTC may differ from the
conclusions in the ITCS based on operational conditions.
---------------------------------------------------------------------------
The ITCS found that transfer capability varies seasonally and
under different system conditions that limit transmission loading so
that it cannot be represented by a single number. Transfer
capability also varies widely across North America, with total
import capability between 1% and 92% of peak load. Transfer
capabilities were observed as generally higher in the West Coast,
Great Lakes, and mid-Atlantic areas, while relatively lower in the
Mountain States, Great Plains, Southeast, and the Northeast regions.
In addition, the ITCS found limited transfer capability between
Interconnections (Western Interconnection, Eastern Interconnection,
ERCOT Interconnection (``ERCOT''), and Qu[eacute]bec). As NERC
discussed these Part 1 results with industry during the Summer of
2024, it explained that the findings suggested that Part 2 analysis
would probably identify prudent additions to TTC to strengthen
reliability. NERC underscored that the magnitude of transfer
capability is not itself a measure of energy adequacy. Rather, the
identified TTC provides the foundation for subsequent energy margin
analysis in Part 2 of the ITCS.
b. Identifying Prudent Additions to Transfer Capability to
Demonstrably Strengthen Reliability
The Fiscal Responsibility Act requires NERC to consider and
recommend prudent additions to TTC ``between each pair of
neighboring transmission planning regions that would demonstrably
strengthen reliability within and among such neighboring
transmission planning regions.'' \36\ For the purposes of
determining a ``prudent addition,'' NERC looked to the standard used
in Commission precedent in electric utility ratemaking proceedings,
which provides that ``prudence'' means a determination of whether
(1) a reasonable entity (2) would have made the same decision, (3)
in good faith, (4) under the same circumstances, and (5) at the
relevant point in time.
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\36\ Supra note 1.
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Determining exactly how much additional transfer capability is
``prudent'' can depend on the totality of factors and circumstances.
For example, as part of examining the totality of circumstances, the
Commission has considered matters such as whether activities
[[Page 105795]]
have enhanced the ability to restore service, achieved significant
efficiencies, reduced costs or time delays, and/or made efficient
use of resources to ensure reliability.\37\ As discussed immediately
below, NERC applied a six-step process to ensure that the ITCS's
tailored recommendations for prudent additions to transfer
capability for certain pairs of neighboring transmission planning
regions are those that a reasonable entity would have made in good
faith under the same circumstances and at the same point in time
considering reliability of the system as the driving factor.
---------------------------------------------------------------------------
\37\ See, e.g., New England Power Co., 31 FERC ] 61,047 at
61,084 (1985); and Potomac-Appalachian Transmission Highline, LLC,
140 FERC ] 61,229 at P 82 (Sept. 20, 2012).
---------------------------------------------------------------------------
NERC underscores that nothing in the ITCS should be used as
justification for a particular project and that no part of the ITCS
is intended as evidence regarding prudence in any ratemaking
proceeding. The ITCS does not include economic assessments, project-
specific recommendations, transmission expansion analysis,
operational mitigation or capacity expansion planning. A holistic
view of the BPS and a thorough understanding of its behavior will be
essential when calculating or increasing transfer capability.
The ITCS particularly examined the extent to which recommended
enhancements would be reasonably expected to demonstrably strengthen
reliability of the BPS. To do so, the ITCS examined whether the
potential recommendation would strengthen reliability, serve load
under extreme conditions, and avoid creating unintended reliability
concerns as follows:
1. Strengthen Reliability: Provides a potential solution that
enables more flexibility between transmission planning regions and
access to resources that may be available during local energy
deficits.
2. Serve Load Under Extreme Conditions: Provides a solution that
serves future demand during extreme conditions, which is a more
restrictive design basis than current resource adequacy constructs.
3. Does Not Create Unintended Reliability Concerns:
Recommendations for larger connections between transmission planning
regions will require detailed system studies to assure system
stability.
[GRAPHIC] [TIFF OMITTED] TN27DE24.053
Under Part 2 of the ITCS, the ITCS conducted energy margin
analysis of resource availability and interregional transfers across
12-years of meteorological conditions and extreme weather data to
examine whether the transfer capability calculated for a pair of
neighboring transmission planning regions would be unable to meet
energy needs under times of stress, being thus ``deficient'' and
reflecting a risk of energy inadequacy for those regions.
As a result, where the ITCS energy margin analysis found a
deficiency and corresponding risk, NERC led a further layer of study
that applied several considerations and criteria under a six-step
process to evaluate whether, and how much, additional transfer
capability would mitigate the potential risk of energy inadequacy
created by the deficiency.
The six-step process entails the following and is discussed in
detail in Chapter 6 of the ITCS at Appendix A:
i. Identify hours of resource deficiency
ii. Quantify the maximum resource deficiency
iii. Prioritize constrained interfaces
iv. Allocate additional transfer capability
v. Iterate until resource deficiencies are mitigated
vi. Finalize prudent level of transfer capability
A diagram of the analysis will help explain further:
[[Page 105796]]
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[[Page 105797]]
The ITCS recommended prudent additions to transfer capability to
the extent that results reflected that enhanced transfer capability
would assuage the risk of energy inadequacy (as reflected by the
deficiencies shown after energy margin analysis).
In total, across various regions of the U.S., the ITCS
recommends 35 GW of additional transfer capability to demonstrably
strengthen reliability. These recommendations are detailed in the
ITCS at Appendix A and break down according to the following table
Table ES.1: \38\
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\38\ In two cases, it was not possible to eliminate all energy
deficiencies, even by increasing transfer capability, due to wide-
area resource shortages. In ERCOT and California North, resource
deficiencies remained even after increasing transfer capability by
14 GW and 1 GW, respectively.
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In making these recommendations, NERC acknowledges that transfer
capability is only one part of the overall equation and that other
elements such as generation resource availability, new load
projections, additional weather information, and demand response
should also be taken into account.\39\ Moreover, these
recommendations do not account for economic, environmental,
permitting or policy considerations that the Commission, U.S.
Congress, other policymakers, and the electric industry may apply
following the ITCS.
---------------------------------------------------------------------------
\39\ Please see NERC's website for more information regarding
these issues. See also, ITCS, Appendix A, Chapter 11 (providing
further considerations). NERC has focused the ITCS on transfer
capability in accordance with Congressional directive.
---------------------------------------------------------------------------
c. Recommendations To Meet and Maintain Sufficient Transfer
Capability
The final requirement of the Fiscal Responsibility Act of 2023
is to develop recommendations to meet and maintain transfer
capability together with recommended prudent additions.\40\ The ITCS
provided recommendations to support transfer capability in the
future without specifying a particular set of projects or approach.
This recognizes that increased transfer capability is one of many
options for addressing the identified energy deficiencies. Such
options at a high level include:
---------------------------------------------------------------------------
\40\ Supra note 1.
<bullet> Increase transfer capability to neighbors with surplus
resources
<bullet> Construct local generation
<bullet> Increase demand response resources
<bullet> Accept the identified risks during extreme events (assuming
other reliability thresholds are met)
Timing for these approaches may vary, so further studies are
needed for implementation. Grid operators must also be prepared to
maintain BPS reliability through emergency measures (including
rotating outages if necessary) meanwhile.
If planners elect to increase transfer capability to meet the
recommendations listed in the ITCS, options to consider include:
<bullet> Upgraded transmission infrastructure: Such as building
new lines and reconductoring existing lines or raising existing
tower structures where feasible.
<bullet> Remedial action schemes (``RAS''): Increasing transfer
capability via adjustments to RAS may be helpful in the short-term
while other solutions are implemented. RAS are not advised as a
long-term solution as these schemes introduce higher operational
complexity.
<bullet> Dynamic line ratings (``DLR''): DLR could use real-time
and forecasted weather conditions to continuously calculate the
thermal capacity of transmission lines and may at times facilitate
increased transfer capability during favorable weather conditions.
However, DLR may not be suitable in all situations.
<bullet> Power flow control devices: Power flow control devices
with newer digital control
[[Page 105798]]
technology that allows for faster responses to system needs may help
support transfer capability and enhance the transmission planning
process.
With regard to maintaining transfer capability, the ITCS
explained that actual transfer capability available during real-time
operations may be different from that calculated due to system
conditions during actual operations. A certain level of transfer
capability cannot always be maintained due to those changing system
conditions and, therefore, the ITCS focused on what can be
accomplished during the planning horizon. These recommendations to
maintain transfer capability include:
<bullet> Coordination Agreements: Strong coordination procedures
and agreements can maximize available support during stress
conditions (such as extreme weather events). This coordination could
include rigorous maintenance activities and coordinated maintenance
to avoid overlapping with periods of increased stress.
<bullet> Future Studies:
[cir] ERO Enterprise Studies: The ERO Enterprise, working with
industry, is planning to conduct regular assessments rolled into
future Long-Term Reliability Assessment reports that will consider
developments in this area. NERC is also considering the issues as
part of its Energy Assessment Strategy.
[cir] Planning/Maintenance: Planners can evaluate changes in
transfer capability as part of regular processes.
<bullet> Regulatory and Policy Mechanisms:
[cir] The ITCS noted that a uniform minimum transfer capability
requirement may not be an effective or efficient approach to ensure
energy adequacy.
[cir] The ITCS recommended that policy makers consider
mechanisms to address existing challenges associated with siting/
permit approvals, cost-allocation, and multi-party operating and
maintenance agreements.
<bullet> Reliability Standards:
[cir] The ITCS clarified that it is not NERC's intent to develop
Reliability Standard modifications to require entities to meet and
maintain a certain transfer capability, without prejudice to NERC's
consideration of modifications in the future of matters such as
assessments associated with planned transfer capability.
[cir] NERC has two standard development projects (Project 2022-
03 Energy Assurance with Energy-Constrained Resources and 2024-02
Planning Energy Assurance) related to energy assurance and the
assessment of energy adequacy.
System studies are urged to ensure careful deployment of ITCS
recommendations. To give these recommendations meaning, transmission
planners and planning coordinators will need detailed studies to
select projects or actions that take advantage of the opportunity
identified in the ITCS without inadvertent consequences. The ITCS
explained limitations on its scope as well as steps that
stakeholders could take to further build on the opportunities
identified therein.\41\ As highlighted throughout the ITCS and this
filing, the ITCS is intended as a launch-pad to further North
America's efforts to plan infrastructure and coordination that
supports a modern grid.
---------------------------------------------------------------------------
\41\ Without limitation on future analysis or action, NERC does
not recommend any Reliability Standards changes at this time as a
result of the ITCS.
---------------------------------------------------------------------------
NERC urges policymakers and industry to carefully consider how
to leverage the recommended additions to transfer capability
outlined in the ITCS. As mentioned above, the recommendations
identify directional, rather than prescriptive, guidance. The ITCS
provides a roadmap for understanding where transmission may benefit
from enhancement, without mandating specific projects or a minimum
level of transfer capability. While the ITCS recommends increased
transfer capability on particular interfaces, NERC does not endorse
projects or particular approaches. This is intentional because
planners must evaluate potential downstream impacts of increased
transfer capability. For example, while greater transfer capability
can improve energy adequacy, there can be situations where a large
transfer of energy has consequences for other aspects of reliable
system operations such as system stability, voltage control, and
measures to minimize the potential for cascading outages.
Transmission planning regions must coordinate system enhancements to
support rational and effective implementation of the ITCS findings.
Further, planners might consider other options not within the scope
of the ITCS. While the ITCS focuses on transfer capability per
congressional directive, regions might construct additional
resources or increase demand response resources. Further, the ITCS
acknowledges that existing or planned projects may also be
responsive to the opportunities and recommendations identified in
the ITCS. As stated above, the ITCS findings should be considered
foundational insights for further discussions and decisions.
III. Consultation With Regional Entities and Transmitting Utilities
The Fiscal Responsibility Act requires that NERC conduct the
ITCS in consultation with the six Regional Entities and neighboring
transmitting utilities.\42\ Consultation is understood as a
meaningful exchange of information prior to final decision-
making.\43\ Consistent with Congressional directive and NERC's
regular collaborative process as the ERO Enterprise coordinating
with stakeholders to ensure reliability, NERC frequently consulted
with the Regional Entities and transmitting utilities throughout the
design and execution of the ITCS.
---------------------------------------------------------------------------
\42\ Supra note 1.
\43\ See, e.g., Envtl. Def. Ctr., Inc. v. U.S. Envtl. Protection
Agency, 344 F.3d 832 (9th Cir. 2003) (highlighting that consultation
was reflected by activities such as circulating a draft report to
stakeholders, establishing an advisory committee, holding several
meetings as part of that advisory committee, and obtaining input
from State and municipal representatives on drafts); and South
Carolina v. United States, 329 F. Supp. 3d 214 (2018) (finding that
the Department of Energy engaged in a meaningful exchange of
information and views with governor prior to the decision); cf. Cal.
Wilderness Coalition v. U.S. Dep't of Energy, 631 F.3d 1072, 1087,
1080, 1085) (2011) (explaining that consultation entails a
meaningful exchange and more than public comment).
---------------------------------------------------------------------------
As illustrated below, the stakeholder engagement process
included 14 Advisory Group meetings, three letters to transmitting
utilities seeking input and feedback, presentations at NERC Board of
Trustee (``Board'') meetings and over 100 industry and trade group
meetings. In addition, to facilitate these conversations and ongoing
exchange of perspectives as NERC led the ITCS, NERC publicly
published scoping documents and quarterly updates associated with
the ITCS on NERC's ITCS web page. Further, NERC published the parts
of the ITCS via a series of three reports (an introductory Overview
report, transfer capability analysis Part 1 report, and prudent
recommended additions to transfer capability Part 2 and 3 report)
prior to finalizing and consolidating these portions into the
attached ITCS (Appendix A).
[[Page 105799]]
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This consultation process is consistent with the ITCS Framework
that NERC published in the summer of 2023. That Framework
established NERC's plan to engage with its executive leadership,
Regional Entities across different levels of leadership and
technical expertise, and industry. This plan included the ERO
Enterprise's coordination with an ITCS Advisory Group comprised of
diverse industry experts (including, for example, those from the
Department of Energy (``DOE''), the Commission, and transmission
planners from across the BPS), as well as additional outreach to
transmitting utilities. See, Appendix B (list of stakeholder
engagement activities), Appendix C (letters to transmitting
utilities for feedback); and Appendix D (Advisory Group and ITCS
Study Team Rosters and List of Public Meetings).
[[Page 105800]]
[GRAPHIC] [TIFF OMITTED] TN27DE24.057
In accordance with the Framework illustrated above, NERC
involved Regional Entities in the ITCS on a weekly basis to design
and execute the ITCS and has met with the Advisory Group
approximately every month to obtain input on ITCS design, execution,
and findings. These groups were also asked to provide feedback on
draft materials, such as the initial draft Framework, subsequent
scope documents for different parts of the ITCS, and the portions of
the ITCS that were rolled out in phases and culminated in the ITCS
attached at Appendix A. All Advisory Group meeting presentations
were publicly posted on NERC's ITCS web page. Comments from Advisory
Group members on various parts of the ITCS were also posted on
NERC's ITCS web page along with NERC's consideration and responses.
The process ensured that NERC received input during each stage of
the ITCS from its initial framing to more detailed scoping and
throughout the ITCS while the ERO Enterprise study team examined the
issues and finalized decisions.\44\
---------------------------------------------------------------------------
\44\ Examples included the decision to study simultaneous import
capability and use 2024/2025 system conditions (or ``base cases'')
to calculate current total transfer capability.
---------------------------------------------------------------------------
To maximize the opportunity for stakeholder consultation, NERC
published draft portions of the ITCS on its web page (after seeking
Advisory Group feedback) in stages. First, NERC published an
Overview report introducing the ITCS and its approach in June 2024.
Second, NERC published its calculated total transfer capability in
August 2024. Third, in November 2024, NERC published its proposed
recommended prudent additions to total transfer capability in
certain regions of the U.S. and recommended means to meet and
maintain transfer capability today and as enhanced after
consideration of the ITCS recommendations. (Part 2 & 3 Report).
These three parts were consolidated after final revisions into the
attached ITCS (Appendix A). NERC plans to issue a fourth report in
2025 studying transfer capabilities from the U.S. to Canada and
between Canadian provinces.\45\
---------------------------------------------------------------------------
\45\ While this part is outside the specific congressional
mandate, the interconnectedness of the North American BPS warrants
analysis of Canada.
---------------------------------------------------------------------------
In addition, NERC sent three sets of letters to all transmitting
utilities in 2024 to obtain feedback on the ITCS.\46\ The first
letter was sent in January of 2024 seeking input generally on the
ITCS, posted framework, and scope documents. The second letter was
sent in September of 2024 to solicit input from transmitting
utilities on the ITCS Overview report, total transfer capability
report (Part 1), and Advisory Group materials (which included
material on considerations and criteria to determine any recommended
prudent additions to transfer capability). NERC's third letter to
transmitting utilities was issued November 4, 2024, after the final
in-person Advisory Group meeting, to solicit input on NERC's
proposed recommended prudent additions and recommendations on how to
meet and maintain current total transfer capability and transfer
capability as enhanced by any additions (the Part 2 & 3 report).
NERC's preliminary recommendations for prudent additions were also
shared with the Advisory Group in September 2024 with publicly
posted materials available on the ITCS web page to provide ample
opportunity for comments before the Part 2 and 3 publication and
before finalizing a final report.
---------------------------------------------------------------------------
\46\ The Fiscal Responsibility Act required NERC to consult with
neighboring transmitting utilities, however, to facilitate the
broadest opportunity for consultation NERC sent these letters to all
transmitting utilities.
---------------------------------------------------------------------------
NERC takes this opportunity to thank all those stakeholders and
members of the ERO Enterprise who participated in the ITCS. This
feedback has been instrumental in developing a nuanced study that is
unique in terms of its geographic magnitude and overall approach to
assessing energy adequacy under extreme conditions.
IV. Conclusion
Therefore, for the reasons set forth above, NERC hereby submits
this ITCS to the Commission as directed by the U.S. Congress in the
Fiscal Responsibility Act. The ITCS finds that while current total
transfer capability is largely sufficient to support energy adequacy
at present, when calculating energy margin analysis and extreme
weather over a forward-looking ten-year outlook, there may likely be
insufficient transfer
[[Page 105801]]
capability. Based on the identified deficiencies that reveal certain
transmission planning regions at risk for energy inadequacy, the
ITCS recommends 35 GW of additional total transfer capability as a
prudent measure to demonstrably strengthen reliability subject to
coordination between governmental authorities, policy makers, and
industry. NERC also plans to continue evaluating transfer capability
as a regular part of its assessments going forward such as the LTRA.
NERC on behalf of itself and the full ERO Enterprise, looks forward
to continuing to participate in this discourse and preparing North
America to meet the needs of the modern grid.
Respectfully submitted,
/s/Candice Castaneda
Candice Castaneda, Senior Counsel, North American Electric
Reliability Corporation, 1401 H St. NW, Suite 410, Washington, DC
20005, (202) 400-3000, <a href="/cdn-cgi/l/email-protection#a1c2c0cfc5c8c2c48fc2c0d2d5c0cfc4c5c0e1cfc4d3c28fcfc4d5"><span class="__cf_email__" data-cfemail="96f5f7f8f2fff5f3b8f5f7e5e2f7f8f3f2f7d6f8f3e4f5b8f8f3e2">[email protected]</span></a>.
Counsel for the North American Electric Reliability Corporation.
Date: November 19, 2024.
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[FR Doc. 2024-30493 Filed 12-26-24; 8:45 am]
BILLING CODE 6717-01-C
</pre><script data-cfasync="false" src="/cdn-cgi/scripts/5c5dd728/cloudflare-static/email-decode.min.js"></script></body>
</html>Indexed from Federal Register on December 27, 2024.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.