Governing the grid for the future: The case for a Federal Grid Planning Authority - Shelley Welton

Recognizing the importance of forward what system upgrades are necessary to connect the planning to the development of adequate transmis- project to the grid.28 Most of the time, these upgrades sion capacity in the right places, FERC has long re- are participant funded, meaning that the develop- quired utilities to engage in transmission planning.38 Its er requesting interconnection is responsible. [...] a plan to cost-effectively and efficiently support the To build the grid that the public needs and de- country’s energy future by developing a blueprint of serves, a more fundamental reclamation of the “pub- interregional and regional transmission line additions lic” in public utility law is in order. [...] I propose systemic, structural reforms that FERC Congress should complement the creation of the and the DOE could undertake in the absence of legis- FGPA with a mandate that all regional planning en- lation to address the governance challenges impeding tities under FERC’s jurisdiction must accept the the creation of a cost-effective and forward-looking national plan as the baseline for their regio. [...] The legal precedent is clear: All that is re- give the job of grid planning to one of the DOE’s relevant quired to render a cost allocation method acceptable preexisting offices, either the Office of Grid Deploy- is that the beneficiaries of transmission roughly share ment or the Office of Electricity. [...] A revival of these principles of structural access to the open systems of public utilities on the separation would not cure the ills that plague grid gov- former’s adherence to the planning and cost allocation ernance, but it might help prevent some cross-affiliate requirements.”180 Nevertheless, reports of less-than- gaming of the systems in place.