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Stakeholders and power market participants have begun submitting responses to federal regulators regarding an Advance Notice of Proposed Rulemaking on transmission improvements, with one group contending transportation and space heating electrification will increase power demand above what the current grid can handle.

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The Federal Energy Regulatory Commission on July 15 issued the ANOPR (RM21-17) that was designed to gather industry feedback on the potential need for reforms to existing regulations to improve the electric regional transmission planning and cost allocation and generator interconnection processes as the US power grid undergoes significant change.

Specifically, FERC said the power generation fleet is shifting from resources located close to population centers toward resources, including renewable energy resources, that may be located far from load centers, while the growth of new resources seeking to interconnect to the transmission system, along with the differing characteristics of those resources, are creating new demands on the transmission system.

Comments are due Oct. 12 and reply comments are due Nov. 9.

Improved demand modeling needed

Consultant Competitive Energy Services, or CES, submitted comments late Oct. 8 that mostly pertain to a solar power pilot project in the Boothbay, Maine Region and subsequent modeling and analysis of the transmission and distribution grid in the greater Portland, Maine Region.

The consultants argued that the "handwriting was on the wall" ten years ago when utility-scale renewable generation projects were failing to be completed for "lack of a pathway to interconnection," while at the same time, distributed generation resource developments in high fossil-fuel cost regions like Hawaii "overwhelmed local distribution systems, leading to moratoria for new solar development."

A similar situation could be observed in the present once the available surplus interconnection capacity of the electric grid is allocated to new generation projects. "Further generation resource development could grind to a halt under outdated and unreasonable generator interconnection processes and transmission cost allocation rules," CES said.

Except for losses, every kilowatt hour of electricity generated must be used in some end-use device at a specific geographic location, according to the filing.

Beneficial electrification that seeks to convert transportation, space heating and industrial processes from fossil fuels to electricity "is recognized by most experts as the only viable pathway to achieve significant reductions in greenhouse gas levels," CES said.

US electric loads will "undergo their most extensive transformation in the last 70 years" and possibly in the modern grid's history, the consultants said, and as a result, load forecasts that do not extend beyond business-as-usual to incorporate state adopted pathways to lower greenhouse gas emissions could be "fundamentally flawed."

Specifically, converting all transportation, space heating and industrial processes to electricity will more than double electric loads in temperate regions of the country where space heating requirements are low and increase loads by as much as a factor of four in the more northern US climate zones, CES said.

"These additional loads will greatly exceed the physical carrying capacity of today's electric transmission and distribution grids, requiring hundreds of billions of dollars of investments to expand and redefine these grids," the consultants said.

For example, Synapse Energy Economics found that converting 90% of Maine's light-duty vehicle fleet to electrification by 2050 and 90% of Maine households to Air Source Heat Pumps over this same period would increase total electricity use from 12 TWh a year to 29 TWh a year.

The same report found that meeting target environmental goals across the six New England states would increase annual electricity use in the ISO-New England control area from 127 TWh to 222 TWh and peak demand from 26 GW to 50 GW, CES said.

The filing recommends updating the way loads are forecast in reliability modeling to recognize consumption increases from beneficial electrification that extend as far as 30 years out.

Additionally, it will be important to aggregate forecast loads and assign them to existing service points on the transmission grid, usually to a specific substation, the consultants said.

The filing acknowledged that these transmission planning changes would likely shift transmission upgrade costs from generators to load, but since most, if not all, future generation and battery storage projects will be developed "pursuant to one form or another of state-sponsored and ratepayer-supported contract, whether transmission upgrades are paid for by generators or load is a distinction without a difference."