A North American Electric Reliability Corporation Interregional Transfer Capability Study “provides substantial evidence that the need for, and benefits of, interregional transfer capability varies substantially around the country” and, at the same time, does not identify a need for any new reliability standards for meeting or maintaining transfer capability between regions, the American Public Power Association and Large Public Power Council said.
APPA and LPPC recently submitted comments to the Federal Energy Regulatory Commission to aid the Commission in preparing its report to Congress on conclusions that can be drawn from the ITC Study and recommendations, if any, for statutory changes, as required by the Fiscal Responsibility Act of 2023 (Docket No. AD25-4-000).
APPA and LPPC said they generally support the scope and overall study methodology that NERC adopted in the ITC Study.
Consistent with NERC’s mandate and expertise, the “sole focus” of the ITC Study is “reliability, in the form of energy adequacy and operating reliability,” they said.
While there are many aspects of reliability, NERC’s focus on energy adequacy -- which it defines as “the ability of the bulk power system (BPS) to meet customer demand at all times” -- is the appropriate starting point for the analysis conducted in this study, they said.
“The limited scope of the ITC Study confirms that it cannot be used to justify any new or upgraded transmission facilities. Instead, the ITC Study can inform the resource and transmission plans of load-serving entities, RTO/ISOs, and regional planning entities. Those entities can evaluate and address the essential economic and planning issues that are affirmatively outside the scope of the ITC Study,” APPA and LPPC said.
“The ITC Study itself makes clear that it cannot be translated directly into project recommendations.”
The groups identify three high-level conclusions in their comments.
First, they said the ITC Study provides substantial evidence that the need for, and benefits of, interregional transfer capability varies substantially around the country.
“Any uniform requirement—such as a minimum transfer capability between regions—would lead to inefficient investment in some areas and inadequate reliability in others.”
Second, the ITC Study indicates that load-serving entities, regional transmission organizations/independent system operators, and regional planning entities should evaluate the most economically prudent way to address the potential energy deficiencies that NERC has identified.
“By its own terms, the ITC Study is not a transmission planning study, nor does it recommend any new or upgraded transmission facilities,” the groups said.
Although it does recommend prudent additions to transfer capability between regions, the ITC Study concludes that increasing transfer capability is one of many options for addressing identified energy deficiencies, APPA and LPPC noted.
Furthermore, the ITC Study “does not evaluate whether any of its recommended transfer capability additions is economically prudent or more cost effective than alternate options.
“In contrast to the ITC Study, regional planning processes can and will use economic data, evaluate regional policy priorities and project feasibility, and based on current and evolving data, evaluate the most cost-effective combination of resource additions, transmission enhancements, demand management, and other tools to maintain reliability.”
Third, the ITC Study does not identify a need for any changes to the Federal Power Act, nor does the ITC Study identify a need for any new reliability standards for meeting or maintaining transfer capability between regions, they added.
