UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Competitive Transmission Development)Docket No. AD16-18-000

Technical Conference)

RESPONSE OF THE EASTERN INTERCONNECTION PLANNING

COLLABORATIVE TO POST-TECHNICAL CONFERENCE QUESTIONS ON
PANEL No. 4: INTERREGIONAL PLANNING COORDINATION ISSUES

I.Introduction

The Eastern Interconnection Planning Collaborative (“EIPC”) hereby responds to the
Commission’s “Notice Inviting Post-Technical Conference Comments” issued on August 3,
2016. EIPC’s response focuses on the questions regarding Panel No. 4: Interregional
Transmission Coordination, which are especially relevant to our members who are Planning
Coordinators in both ISO/RTO and non-ISO/RTO regions in the Eastern Interconnection.

II.Statement of Interest

The EIPC is an organization formed by NERC-registered Planning Coordinators in the
Eastern Interconnection to perform interconnection-wide transmission analysis. As an example,
the EIPC has successfully completed a U.S. Department of Energy-funded analysis of the
electric transmission system in eastern North America looking 20 years into the future, as well as
an analysis of the interface between the electric transmission system and the natural gas delivery
system. The EIPC also develops transmission system models of combined regional transmission
plans and performs interregional scenario analyses on those combined models to identify stress
points on the Eastern Interconnection-wide system and identify gaps in the combined plans.
Formed under an agreement by 19 planning authorities from the Eastern United States and

Canada,1 the EIPC has developed a “bottom-up” approach to transmission planning, starting with a roll-up of the existing grid expansion plans of electric system planning authorities in the
Eastern Interconnection. The EIPC provides a forum to connect broad interregional issues with potential interregional solutions.

In addition to completing the five-year DOE interconnection studies project in 2015, the
EIPC continues to refine NERC interconnection-wide transmission models for interregional
studies. Most recently, the EIPC completed development of roll-up and integration cases for the
2025 summer and winter time frames. The development process included a gap analysis and
study of interregional power transfer capabilities. The EIPC is also developing a production cost
database to match those power flow cases for interregional studies. Completion and testing of
the improved production cost data base is planned for 2017. The EIPC also provides an
interconnection-wide perspective on issues of interest to the industry including the DOE’s
Annual Transmission Data Review and Transmission Congestion Studies.

1 The EIPC membership includes Alcoa Power Generating, Inc.; Duke Energy Carolinas, Duke Energy

Florida, and Duke Energy Progress; Louisville Gas & Electric Company and Kentucky Utilities Company; Florida Power & Light Company; Georgia Transmission Corporation (An Electric Membership Corporation); ISO New England, Inc.; JEA; Midcontinent Independent Transmission System Operator, Inc.; Municipal Electric Authority of Georgia; New York Independent System Operator, Inc.; PJM Interconnection; PowerSouth Energy Cooperative; South Carolina Electric & Gas Company; South Carolina Public Service Authority; Southern Company Services Inc., as agent for Alabama Power Company, Georgia Power Company, Gulf Power Company, and Mississippi
Power Company; Southwest Power Pool, Inc.; and the Tennessee Valley Authority.

III.Comments

Panel Four: Interregional Transmission Coordination Issues

1. What factors have contributed to the lack of development of interregional

transmission facilities (i.e., a transmission facility that is located in two or more transmission planning regions)? Are there actions the Commission could take to facilitate such development?

EIPC Response

The Commission’s question is based on the premise that there has been a “lack of

development of interregional transmission facilities” and that FERC needs to take additional

action at this time to drive more interregional transmission facilities. EIPC wishes to point out to
the Commission that there are many factors that will either accelerate or slow down the
designation of interregional transmission projects. As an entity made up of each of the Planning
Coordinators in the Eastern Interconnection, EIPC is uniquely able to observe transmission needs
among all of the planners of the Eastern Interconnection. Since the issuance of Order No. 1000,
both load growth and resulting congestion have significantly declined, leading to lengthening the
horizon over which new transmission will be needed. Although certain states such as New York
have undertaken specific, state-driven initiatives which may compel new transmission
investment, traditional drivers such as reliability and market efficiency have been impacted by
the decline in load growth and congestion. The pace of interregional project development is
also significantly affected by factors such as the uncertainty of the future of the Clean Power
Plan, and individual states examining whether or not, and how, they may wish to undertake
regional approaches to environmental compliance. Accordingly, the Commission should not be
quick to take action, as these issues cannot be addressed simply by regulatory directive. EIPC,
through its system modeling roll-up work,2 will continue to provide an interconnection-wide
view that all stakeholders can use to examine trends and identify efficiencies that may result
from consideration of interregional projects.

Furthermore, the perceived lack of interregional transmission projects arising through the new Order No. 1000 coordination process does not necessarily mean that there are any unmet needs. Experience has shown that most regional transmission needs can be addressed by
regional or local solutions. In addition, the merchant transmission model, together with buildouts required under existing agreements between adjacent systems, represent additional means to develop interregional transmission projects.3

2 EIPC “rolls up” the regional models of its Planning Coordinator members to conduct interconnectionwide analyses.

3 EEI reported in October 2015 that investor owned electric utilities had spent $73 billion over the past five
3

Finally, as a matter of regulatory process, it should be pointed out that Order No. 1000
introduced major changes for transmission providers in both ISO/RTO and non ISO/RTO
regions when it was issued in July 2011. Interregional compliance filings were made during
2013, and the Commission issued numerous compliance orders through the end of 2015.4 Since
Order No. 1000 has directed new inter-regional planning coordination requirements that are
based upon the regional transmission planning processes of neighboring regions, implementation
of these new interregional requirements is just getting underway in many parts of the Eastern
Interconnection. Therefore, it is premature at this time to draw any conclusions regarding the
effect of these new requirements on the development of interregional transmission facilities.
Accordingly, FERC should continue to monitor the regions’ progress in the implementation of
interregional transmission coordination under Order No. 1000 and refrain from proposing any
major changes at this time. EIPC stands ready to be an informational resource to the
Commission and stakeholders in providing interconnection-wide data to support such
monitoring.

2. What would be the advantages and disadvantages to the use of common models and
assumptions by public utility transmission providers in regions in their interregional
coordination processes? Are there problems that such an approach would solve or
create? If such common models and assumptions could be developed, how should
they be developed and by which entity or entities?

EIPC Response

While more uniformity in study assumptions and modeling used for interregional

transmission coordination is a desirable goal, its achievement would be no small task due to the
significant regional differences that exist across the Eastern Interconnection. “Assumptions” can
refer to a wide array of values used in transmission planning, many of which can be highly
variable in the longer term, depending on such variables as market/investment structures,
jurisdictional preferences and uncertainty, network topology, and resource performance. The

years and projected spending over $85 billion in the next four years for upgrades and replacement of transmission
facilities, system hardening and resiliency, fundamental improvements to comply with evolving transmission
reliability and compliance standards, expansion of the transmission system to integrate renewables and other
generation. See http://www.eei.org/issuesandpolicy/transmission/Pages/transmissionprojectsat.aspx

4 Some regions have not yet received final orders from the Commission regarding their interregional planning

compliance filings. See Midcontinent Independent System Operator, Inc., et al., Compliance Filing for Order No.
1000 Regarding Interregional Coordination with PJM, Docket Nos. ER13-1943-005, et al. (June 20, 2016) (pending
Order No. 1000 interregional compliance filing concerning revisions to the Joint Operating Agreement between the
Midcontinent Independent System Operator and PJM Interconnection, L.L.C.); PJM Interconnection, L.L.C., Order
No. 1000 Interregional Compliance Filing, Docket Nos. ER13-1944-004, et al. (June 20, 2016) (same).

concept of standard assumptions may not be practicable or useful; however, the regions involved
in Order No. 1000 interregional planning processes should be the forums to develop such
assumptions in the first instance. EIPC can provide a useful forum for the coordination of
assumptions or a range of assumptions for a specific targeted study purpose in the Eastern
Interconnection.

Currently, the EIPC membership serves approximately 95% of the electric load in the
Eastern Interconnection. In that regard, the EIPC has already established practices for data
sharing to support the refinement of NERC network models into Eastern Interconnection wide
study-specific power flow models which have been used for the past six years to inform the
regional plans of its members and to analyze the bulk electric system in the Eastern
Interconnection based upon mandatory reliability standards. The results of the EIPC’s analysis
can be found at www.eipconline.com. In addition, the EIPC is also in the process of developing
a database for production cost analysis. Given NERC’s modeling process and EIPC’s
considerable work through the system modeling roll-up process in harmonizing individual plans,
the EIPC members do not see a need at this time for any additional effort to develop “common
models.”

3. Should the Commission revisit Order No. 1000’s requirement that an interregional
transmission facility be selected in the regional transmission plan of all transmission
planning regions where the facility will be located before it is eligible for
interregional cost allocation? Why or why not?

EIPC Response

Under Order No. 1000, the foundation for interregional planning coordination lies with
the regional planning processes of the respective regions. Without the support of at least two
regions, an interregional transmission project is unlikely to succeed. Requiring all regions where
the project is located to select the project in their regional plan is appropriate and consistent with
Order No. 1000’s interregional cost allocation principles and should not be changed by the
Commission.

4. What reforms, if any, could the Commission adopt to facilitate the identification of
shared interregional transmission needs?

EIPC Response

The key to the identification of shared interregional transmission needs is the initial,

periodic identification of the Regional needs and solutions, coupled with joint analysis through
the interregional coordination process in the same general planning timeframe. This would
enable stakeholders in adjacent Regions to consider if there are more efficient or cost effective

interregional solutions. This is a key component of the existing Order No. 1000 interregional planning requirements and should not be changed.

5. Do interregional cost allocation methods accepted by the Commission, such as the
“avoided cost only” method, impede interregional transmission coordination? If so,
are there alternative cost allocation methods that could better facilitate interregional
transmission development? Would those methods be consistent with interregional
transmission coordination processes or would the interregional transmission
coordination processes need to change to accommodate such alternative cost
allocation methods?

EIPC Response

EIPC notes that the avoided cost allocation methodology for interregional transmission
projects, while not the only cost allocation methodology in use by EIPC members for
interregional planning, is consistent with the interregional coordination processes of all the EIPC
members. The avoided cost methodology is a transparent and defensible approach to
determining if an interregional transmission project is more efficient or cost effective. EIPC also
notes that the avoided cost methodology is aligned with the process by which a region examines
the benefits of an interregional project through its own regional planning processes, each of
which can then be harmonized through the applicable interregional cost allocation methodology.

IV.Conclusion

WHEREFORE, the EIPC respectfully requests that the Commission consider these

comments in this proceeding.

Dated: October 3, 2016

Respectfully submitted,

/s/ Timothy E. Ponseti

Timothy E. Ponseti

Vice President, Transmission Operations & Power Supply, Tennessee Valley Authority

Chairman, Executive Committee

Eastern Interconnection Planning Collaborative 1101 Market Street, MR 1B

Chattanooga, TN 37402 (423) 751-2699

teponseti@tva.gov

David Whiteley, Executive Director

Eastern Interconnection Planning Collaborative

12000 Heatherdane Drive St. Louis, Missouri 63131 (314) 753-6200

d.a.whiteley@att.net

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each person

designated on the official service list compiled by the Secretary in this proceeding in accordance with the requirements of Rule 2010 of the Rules of Practice and Procedure, 18 C.F.R. §385.2010.
Dated at Rensselaer, NY this 3rd day of October 2016.

/s/ Joy A. Zimberlin

Joy A. Zimberlin

New York Independent System Operator, Inc.

10 Krey Blvd.

Rensselaer, NY 12144 (518) 356-6207