Tanmay Shukla

Better Transmission: Ensuring Renewables & Nature Aren’t at Odds

We can connect renewables to the grid fast without sacrificing habitats and communities. The key is to select transmission projects with better siting plans in the first place.

The Federal Energy Regulatory Commission (FERC) is in the midst of the largest rewrite of electric grid policy in a decade. The rulemaking is expected to address a major hurdle to clean energy goals: our country’s outdated, congested, and underutilized transmission system. To fully decarbonize our electricity system, we’ll need a lot of new local, community-based renewables and a lot of new utility-scale wind and solar farms. Large wind and solar plants are usually sited in remote areas and need to be “hooked up” to the energy grid. As a result, we need to create more space on the transmission system to carry renewable energy to the places it’s needed most. This requires two complementary approaches: (1) getting better performance from the transmission system we already have, by using advanced transmission technologies such as battery storage, dynamic line rating, power flow control, and distributed energy solutions; and (2) constructing new, smart, and cost-effective transmission lines that carry renewable energy to population centers.

The need for rapid expansion of transmission has led to a renewed focus on siting, or deciding where these new transmission lines should go. At the moment, transmission lines cannot be built until state authorities hear local communities’ concerns and determine that the developer’s siting plan is in the public interest. This siting review process takes some time, but it plays an important role in protecting habitats and vulnerable communities. In a bid to speed up transmission projects, however, some have suggested that siting and environmental review must be watered down.

The existing rules fail to filter out projects with bad siting plans that cause avoidable harms to habitats and communities.

That’s a false choice. In recent filings with FERC, ELPC and a diverse coalition of conservation and renewable energy advocates—including the Center for Renewables Integration, Defenders of Wildlife, the National Audubon Society, the National Wildlife Federation, the Nature Conservancy, and Vote Solar—pointed out that siting disputes usually occur because of broken planning and project selection rules at the regional level. The existing rules fail to filter out projects with bad siting plans that cause avoidable harms to habitats and communities. Predictably, these projects get tied up in protracted siting disputes down the line.

Our coalition proposed a simple fix: FERC should require regional planners to consider siting at the front end, and develop rules of thumb to weed out projects that are likely to lead to unnecessary siting disputes later.

Regional transmission planning is siting-blind

The current regional planning rules are a recipe for protracted siting disputes. Consider, for example, one regional planner: the Midcontinent Independent Systems Operator (MISO), which oversees transmission in portions of 15 states. MISO calculates the cost of siting on the assumption that each proposed transmission line charts a “straight-line” path between substations. It does add a 30% cost adder to account for “routing constraints,” but the adder is the same for all projects, regardless of actual conditions on the ground. Of course, actual conditions directly affect the likelihood of delays and cost-overruns during siting proceedings. But at the project-selection stage, these costs remain hidden.

FERC should require regional planners to consider siting at the front end.

The “straight-line” method not only creates avoidable disputes down the line, but also creates perverse incentives. A fair and competitive market would reward developers who take care to avoid land-use impacts and devise innovation solutions, even if the short-term costs of their projects are higher. For example, all else equal, project selection rules should favor a developer who proposes to build within existing transmission corridors, or relies on non-transmission alternatives such as energy storage. Under the current regime, however, developers have no path to translate innovation into success.

Our recommendation: FERC should require regional transmission planners to select projects that are less likely to cause siting concerns down the line.

Fortunately, there is a fix: FERC should require regional transmission planners to disfavor projects with avoidable land-use impacts, and favor projects with desirable characteristics. In FERC-speak, planners should be required to develop “siting-based criteria for project selection.” FERC should also require transmission developers to include energy storage and other advanced transmission technologies to minimize the footprint of new high-voltage transmission infrastructure where possible and appropriate, as ELPC discusses in its recent Beyond Wires Report.

The time is ripe to adopt this approach. Front-end siting planning is more feasible today than ever before.

As ELPC and our coalition partners point out, the time is ripe to adopt this approach. Front-end siting planning is more feasible today than ever before. In the last few years, several organizations have developed detailed databases to identify siting conflicts, including wildlife conservation and cultural resource conflicts. Transmission planners can simply rely on these pre-existing databases to develop granular siting criteria. Siting planning also dovetails with FERC’s renewed focus on non-wires transmission alternatives, such as “smart grid” technologies and energy storage. A principal benefit of non-wires solutions is that they avoid siting impacts altogether. A planning regime that take cognizance of siting impacts will reward non-wires solutions for their siting benefits.


FERC’s ambitious reworking of the rules for regional transmission planning presents a unique opportunity to solve a longstanding problem with transmission siting policy. Regional transmission planners currently do not weed out proposed projects that have avoidable land-use impacts and are likely to be delayed in siting proceedings at the back end. This dynamic creates a false choice between rapid decarbonization on the one hand, and conservation and equity goals on the other. FERC can fix the problem by requiring planners to consider siting at the front end, while planning and selecting regional transmission projects. This is a win-win: transmission projects that have fewer conservation and environmental justice impacts are also less likely to be tied down in litigation.

FERC is expected to announce its final rule some time in 2023.

Read ELPC’s full comments here.

Tanmay Shukla,

Associate Attorney

Tanmay Shukla is an associate attorney with the Environmental Law & Policy Center working on energy law, clean water, and climate adaptation issues.

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