Tricks, Treats, and Transmission: Bringing Equity to Grid Planning

The past year has shown how the climate emergency and severe weather test the transmission system with hurricanes, wildfires, flooding, and increased demand for power from extreme temperatures. The current transmission system is failing these tests. In some cases, extended power outages after extreme weather have tragically increased the death toll. These extended outages disproportionately harm low-wealth communities and communities of color, as detailed by the Initiative for Energy Justice.

As the Federal Energy Regulatory Commission (FERC) explores improving transmission planning, we have an opportunity to address critical equity concerns. Recently, nearly 200 comments were submitted to FERC in response to its advanced notice of proposed rulemaking on transmission planning reform. As reflected in these comments, FERC needs a new approach for a transmission system that supports decarbonization, provides the resilience needed to address the effects of a changing climate, and facilitates an equitable and just clean energy transition.

There is a strong connection between energy justice and transmission reform, highlighted by the comments of attorneys general, organizations such as the Center for Biological Diversity, and others. The current system has left us with large, fossil fuel-fired power plants that operate disproportionately in low-wealth communities and communities of color. And as it currently stands, the power generation sector remains a top contributor to U.S. greenhouse gas emissions. In addition, a recent EPA analysis found that communities of color are disproportionately located “in areas where the analyses project the highest levels of climate change impacts with 2 degrees C of global warming.” Concentrated pollution sources, racist redlining policies, and other factors contribute to the distinct health threats that climate change poses to communities of color and low-income communities. Addressing these issues, Massachusetts Attorney General Maura Healey emphasized that as we weigh the costs and benefits of new approaches to transmission, we also must recognize “the ongoing costs of the existing system if no reforms are implemented.”

Transmission planning can also drive the equitable deployment of cleaner resources. The grid should be planned to maximize energy efficiency, resilient distributed generation, and other non-wires alternatives. Programs to promote access to storage resources can reduce emissions and build resiliency for communities. As the Center for Biological Diversity discussed in their comments, rooftop and community-owned solar, combined with storage and microgrids, can empower communities disproportionately harmed by the current system, reduce urban heat island effects, and offer climate resilience.

A more transparent, inclusive transmission planning process is also vital to achieving an equitable transformation of the grid. Commenters urged FERC to seek early and diverse stakeholder engagement, including through the new Office of Public Participation. They also called for increased transparency and stakeholder engagement from regional transmission organizations and independent system operators, who run complex planning processes that would benefit from meaningful nonprofit and public sector participation. FERC should also explore providing funding for stakeholders to hire the professional expertise necessary to participate. Eleven state attorneys general told FERC in multistate comments: “We can’t expect residents from disadvantaged communities to participate for free while everyone else in the room is being compensated to be there.”

What are the next steps? FERC will hold a technical conference on November 15 and will be accepting comments in response to the initial round of comments on its advanced notice of proposed rulemaking until November 30. You can visit the State Impact Center’s new web resource to find the latest news and developments in the world of transmission reform.