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15 March 2023

Invenergy’s interregional merchant transmission FERC petition

Invenergy has twice petitioned the Federal Energy Regulatory Commission (FERC) to hold a technical conference on the subject of interregional HVDC Merchant Transmission, also called MHVDC. Invenergy’s petitions came first in July and then again in November. Since then various companies and organisations have been filing dockets in support or opposition to this request, with many of these opinions voiced in the past week.

Invenergy’s November petition can be read or downloaded here or here.

The requested conference would explore ways to make grid reliability and resilience benefits, associated with MHVDC development, more widely available, as per the first petition, and would “remove barriers to the development” of MHVDC transmission, as per the second. As Invenergy argues, FERC transmission proposals have yet to address the challenges faced by interregional MHVDC proposals.

One point raised by Invenergy is the dearth of interregional transmission projects, and that past FERC measures have yet to change this. As the filing reads, “Unfortunately, no significant interregional transmission project has resulted from FERC Order No. 1000 in the last decade. Thus, it is important for the Commission to enable merchant transmission as an alternative to Order No. 1000 projects.” FERC Order 1000 was adopted in 2011, so has been “idle” since its conception. Merchant transmission is not paid for by charging customers more, but instead relies on selling its services to the two connected parties.

Another point raised by Invenergy is the lack of a regulatory framework for interregional transmission projects – “At present, there is significant regulatory uncertainty over the process used to interconnect merchant transmission. Some transmission providers require the project to enter the generator interconnection queue. Others have a wires-to-wires interconnection process. And some are not sure what to do when presented with a project. As a result, a MHVDC line may face two very different processes for interconnecting each end of its line.”

The third major point raised by Invenergy is cost allocation – arguing that large-scale transmission projects should be able to allocate some cost to the generators which profit from their use.

Most dockets filed have been supporting the Invenergy request – but one major filing in opposition came in last week, from the ISO-RTO Council, requesting that FERC dismiss the petition. The Council requested that FERC instead address the multiple pending proposals on such topics – interregional, regional, interconnection and cost allocation.

The ISO-RTO Council’s members, assorted Independent System Operators and Regional Transmission Organisations, cover around two-thirds of the US population. They are more or less accused by Invenergy of not properly remunerating MHVDC projects in accordance with their full value, which should consider roles such as stabilizing supply at the interregional level. It’s that topic which was most stressed by environmental NGOs such as the Sierra Club in its supportive filings. In return, the Council derogates Invenergy’s petition as “technology-specific,” in contrast with the many general questions which remain undecided by the Commission.

Invenergy is mostly a wind developer, with large fraction of gas and solar, active in Asia, Latin America and Europe as well the US. It is also currently developing the 800-mile, 5 GW, $7billion, 600 kV Grain Belt Express HVDC line, the first segment of which may be able to begin construction next year, with the whole project to require three years and 22,000 employees to build. The line would run from Indiana to Kansas and would enable a further $20 billion in renewable energy investment. The developer has only recently received approvals from the utility regulators of all four states.

Americans for a Clean Energy Grid (ACEG), whose stakeholders would benefit from the expansion of the US grid, filed a response with FERC in August supporting the request, stating that the questions raised by Invenergy were “critical.”

FERC is currently in a 2:2 Republican-Democrat balance, thanks to Senator Manchin, with Chairman Glick having stepped down in January, replaced only by an Acting Chairman, Willie Phillips. Despite this the Commission is not in a deadlock, so much as its decisions are currently born from compromise.

In October Invenergy and NextEra were among those who criticized a related planned FERC reform, to the interconnection process, calling it a “mixed bag.” These critics acknowledged the issue being addressed – a massive backlog of projects, many speculative, waiting in interconnection approval queues. But NextEra criticized the commercial readiness requirement for entry into the interconnection queue, arguing that this would favour utilities while other developers need the interconnection spot, with information on interconnection costs, before they can reach financial viability. The American Clean Power Association advocated readiness deposits as a compromise. Advanced Energy United, another trade group, complained that the interconnection process was “being bogged down by its de-facto role as a transmission planning process of last resort.”

The Biden Administration’s direct fiscal support for grid transmission has included a $2.5 billion electricity purchase commitment on new power lines, power which would be resold to utilities. It’s an efficient concept, and one that may be expanded this year according to comments made in May by Patricia Hoffman, the Principal Deputy Assistant of the Department of Energy Office of Electricity. If spent in a lump, it would only pay to build one transmission line handling a few GW for a distance of a few hundred miles.