Overall, Niskanen believes that updating the categorical exclusions as proposed to better reflect current technologies and industry practices will help facilitate the transition to a more efficient, resilient, and clean grid, while retaining vital environmental and community safeguards. [...] The DOE’s triennial National Transmission Needs Study1 is “an assessment of publicly available data and more than 120 recently published reports that consider current and anticipated future needs given a range of electricity demand, public policy, and market conditions.”2 The DOE Needs Study concluded “that all combinations of new generation will require increased transmission deployment to remove. [...] Niskanen commends DOE for the thoughtful and comprehensive drafting of the NOPR and associated proposed regulations on categorical exclusions. [...] In particular, we support removing the 20-mile limitation9 and adding relocation flexibilities to the categorical exclusion for upgrading and rebuilding existing transmission lines under B4.13.10 The elimination of an arbitrary mileage 6 Net-Zero America: Potential Pathways, Infrastructure, and Impacts, Final Report Summary, Princeton University at 27-29 (Oct. [...] Lastly, Niskanen supports the proposal to eliminate acreage limits for solar photovoltaic installations under B5.16, as similar to the findings leading to the amendment of B4.13, it appropriately reflects that potential adverse impacts relate more to the presence of sensitive local resources rather than absolute size.
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