This study is a preliminary analysis to help state decision makers determine whether to pursue more detailed analyses of IREZ corridors that are relevant to them. This report could not fully account for all the case-specific details that would affect the configuration of a transmission project. Nevertheless, if a corridor examined in this study has a high benefit-to-cost ratio based only on energy cost savings, a follow-on study focusing on that corridor might expand the economic analysis to include local factors that we were not able to address here. A guiding premise behind the IREZ analysis is that states will ultimately take the lead in deciding whether to pursue IREZ development.

This study develops a model using renewable energy zones to address the new challenges of interregional transmission planning. An interregional renewable energy zone (IREZ) is an area comprising a very high concentration of very low-cost developable renewable energy potential. An IREZ hub is a collection point on the bulk power system to which renewable energy plants built in the IREZ can connect easily. The hub anchors an IREZ corridor that consists of a dedicated high-voltage transmission path from the IREZ hub to a major load center.

We have identified and quantified several high-value IREZ corridors that affected states might consider for interregional transmission planning. Our analysis suggests that these corridors can be valuable tools for reducing carbon emissions in a manner that uses known technologies, has relatively small net impact on customers’ electricity bills, improves resource adequacy, and provides the grid with an additional measure of resilience against major disruptions related to climate change and other causes.

​Benefits could include assumptions about local tax receipts and indirect economic development effects in the IREZ state, payments to landowners for the acquisition of right-of-way (ROW) along the transmission path, net savings in energy costs for customers at the receiving end of the corridor, and enhanced resilience against extreme weather events.

Grain Belt Express is also making procedural headway at the Federal Energy Regulatory Commission.

Grain Belt asserts that, with respect to the reasons for delaying the In-Service Date of the GBX Line, Ameren Missouri did not mention that its affiliate, Ameren Transmission Company of Illinois, was awarded a number of transmission facilities under MISO’s Long-Range Transmission Planning process, which it is constructing with planned In-Service Dates of 2028 and 2030. 

In a notice of intent to prepare an environmental-impact statement for the Grain Belt Express, the Energy Department notes that the project could create “local safety risks associated with electromagnetic fields, power surges, risk of increased lightning strikes, and line-induced fires.”

Of course, the risks associated with climate change are much more serious.

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The Routing Team developed specific routing criteria in identifying, evaluating, and selecting routes, attempting to minimize:

Route length, circuity, cost, and special design requirements.

The removal or substantial interference with the use of existing residences.

The removal of existing barns, garages, commercial buildings, and other nonresidential structures. 

Substantial interference with the use and operation of existing schools, existing and recognized places of worship, existing cemeteries, and existing facilities used for cultural and historical, and recreational purposes.

Substantial interference with economic activities.

Crossing of designated public resource lands such as national and state forests and parks, large camps and other recreation lands, designated battlefields or other designated historic resources and sites, and wildlife management areas.

Crossing large lakes and large wetland complexes, critical habitat, and other scarce, distinct natural resources.
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Substantial visual impact on residential areas and public resources.

Avoid double-circuiting or crossing existing 765 kV lines.

Do not parallel existing 765 kV lines for more than 1 mile in any particular location.

Minimize the crossing of 345 kV and 500 kV transmission lines.

Minimize paralleling corridors with more than one existing 345 kV or 500 kV circuit.
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Maintain 200 feet of centerline-to-centerline separation when paralleling existing 345 kV, 500 kV, and 765 kV transmission lines.

Maintain 150 feet of centerline-to-centerline separation when paralleling 138 kV or lower voltage transmission lines.

Minimize angles greater than 65 degrees and sloping soils more than 30 degrees (20 degrees at angle points).

Do not triple-circuit lines of 345 kV or greater voltage. 

In these cases, the existing transmission corridor already runs through theses areas, and in order to keep the height of the structures lower, the Applicant would work with the holders of these easements to modify them in order to acquire approximately 105 feet of additional ROW. 

The Ameren upgrades involve two new 345 kV Montgomery-Burns transmission lines for which GBX will pay $126.5 million. The total cost of all upgrades that GBX is funding under the TCA is $217 million. In addition to permitting the two new Ameren transmission lines, Ameren mentioned some concerns about scheduling outages in connection with these lines and coordinating with AECI, which is an Affected System. 

Constructability (or buildability) is a concept that denotes ease of construction. It can be central to project management techniques to review construction processes from start to finish during pre-construction phase. Buildability assessment is employed to identify obstacles before a project is actually built to reduce or prevent errors, delays, and cost overruns.

Overall, the ROW risk for the new West cluster transmission line components in this proposal is medium-high to high, as the proposed new transmission lines are routed parallel to an existing ROW for majority of their alignment. 

Environmental Risk Analysis
46a – 502 Junction to Black Oak OH 500 kV Line
Route crosses West Virginia and MD Department of Natural Resource (DNR)-recognized public lands and is also within a short distance of residential areas.
4CA – Black Oak to Woodside OH 500 kV Line
Route crosses through the Appalachian Mountains and intersects with VA Natural Heritage easements.
10C1A – Woodside to Gant (Segment 1) OH 500 kV Line
The proposed route for this line segment goes through several national scenic and historic trails (Harpers Ferry National Historical Park and the Appalachian Scenic Trail), and intersects public lands and conservation easements. This may require permission from the National Park Service (NPS) and require an Environmental Assessment (EA) pursuant to the National Environmental Policy Act (NEPA) to analyze the impacts to the environment and park resource, which could be a lengthy process. This route is also within a short distance of residential and commercial areas.
10C3 – Woodside to Gant (Segment 2) OH 500 kV Line
The proposed route for this greenfield line segment goes through highly developed residential and commercial developments, as well as state and local conservation easements. This route also crosses the Washington & Old Dominion (W&OD Trail), a regional park in northern Virginia. There is significant risk of public opposition to the proposed route, which may lead to rerouting this segment along the existing corridor from Doubs to Goose Creek.

Overall, for Proposal 853, medium-high constructability risks are assessed for the proposed line routes due to anticipated lengthy regulatory process, potential public opposition, construction difficulty, environmental constraints and property acquisition, which may have significant impacts on the cost and schedule for the proposed project.

Transmission Line Risk Analysis
Significant engineering and construction challenges are anticipated for the proposed lines to construct a total of 167 miles of new transmission through four states and will require parallel crews and construction where possible to mitigate schedule challenges that will be introduced by the anticipated lengthy permitting and land acquisition process.
For the rebuild portions of the proposed line routes, there are challenges with existing overhead transmission infrastructure components needing to be removed/salvaged before construction of proposed brownfield lines can commence, and potential design and ROW limitations for reuse of existing infrastructure/assets.
Other medium risks for this project involve the existing facility outages that will be necessary for the project, particularly for the line rebuild and substation upgrades. 

Schedule Review
The proposed in-service date of June 2027 is very aggressive for the proposed scope of the project considering the significant permitting and land acquisition challenges associated with the proposed 500 kV greenfield line routes through four states. Overall, the schedule risk is considered medium-high. 

Environmental Risk Analysis
Joshua Falls-Yeat 765 kV OH Line
The proposed line route has the potential to impact environmental and cultural resources including: the Southern Albemarle Rural Historic District, a FEMA High-Risk Flood Zone, wetlands and several waters subject to USACE Section 10 permitting, the most significant being the James River. The route also intersects local conservation easements and appears to co-locate with pipeline ROWs.
Warrenton-Wheeler 230 kV OH Line
The line crosses woodland, residential and agricultural parcels in Fauquier and Prince William counties in Virginia. The route intersects local conservation easements and potentially impacts environmental resources such as Auburn Battlefield Historic District, flood plains and wetlands.
There are medium constructability risks assessed for the proposed line routes due to anticipated lengthy land acquisition process, potential public opposition and environmental constraints, which will have impacts on the cost and schedule for the proposed project.
Transmission Line Risk Analysis
Transource has an optimistic schedule for several aspects of this component and would require a near perfect execution to maintain the proposed in-service date. Given the scale of the component, a 135 mile 765 kV line with everything from permitting to land acquisition to construction poses a risk for delay, the most critical being land acquisition.
For the 230 kV developments, Yeat-Clover Hill and Warrenton-Wheeler, these facilities will utilize BOLD (Breakthrough Overhead Line Design), which is a structure family developed by AEP. The design features a monopole structure with two arched crossarms to hold two circuits in a delta configuration. Benefits of BOLD include increased line capacity with lower-profile structures. However, utilizing this structure family poses risks to the schedule, specifically procurement of the arched crossarms, construction and maintenance of a non-typical design.
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Schedule Review
This proposal includes 765 kV substation and transmission line construction, as well as utilization of BOLD (Breakthrough Overhead Line Design) technology for the greenfield 230 kV lines. The sum of all components is a very aggressive undertaking to be completed within the proposed schedule. The primary risks for this proposal are related to the magnitude of the scope of work, procurement and construction of 765 kV equipment and BOLD structures, state permitting and land acquisition for both the 765 kV and 230 kV developments. These all pose a medium-high risk to the December 2029 in-service date proposed by Transource. 

There is significant risk of public opposition to the proposed route, which may lead to rerouting this segment along the existing corridor from Doubs to Goose Creek. 

PJM utilizes a hybrid cost allocation method, which the Commission found complies with Order No. 1000, for Regional Facilities and Necessary Lower Voltage Facilities that address a reliability need.  Under this method, PJM allocates 50% of the costs of Regional Facilities or Necessary Lower Voltage Facilities on a load-ratio share basis and the other 50% based on the solution-based distribution factor (DFAX) method.  PJM allocates all of the costs of Lower Voltage Facilities using the solution-based DFAX method.  Cost responsibility assignments pursuant to the Order No. 1000-compliant cost allocation method are included in Schedule 12-Appendix A of the Tariff. 

PJM has told us that if we fail to approve those transmission projects in this RTEP driven by the closure of the Brandon Shores coal generating unit located in Maryland, the grid will likely suffer a severe voltage collapse in Baltimore and the surrounding zones, including Northern Virginia, the District of Columbia, Delaware and southeastern Pennsylvania. Such a result could be potentially catastrophic.
While these projects are very costly – and I take seriously the concerns expressed by the Organization of PJM States, Inc. (OPSI), Maryland Public Service Commission (MD PSC) and Maryland Office of People’s Counsel (OPC) – given this Hobson’s choice I concur with approving PJM’s RTEP filing.
While I concur, I note that this element of the RTEP filing raises more questions than it answers, and some of those questions are extraordinarily important.  

Let me emphasize that the State of Maryland, within its sovereign police powers, clearly has the authority to mandate any particular mix of generating resources it prefers.  Maryland’s new climate law is well within its inherent authority to enact.  Such policies are for Marylanders to choose, not RTOs or FERC.  But if the resulting transmission projects under protest in this RTEP filing are caused more by Maryland’s policy choices than by organic load growth and economic resource retirements, then a salient question that may be asked is whether these transmission projects are more accurately categorized as public policy projects, essentially the same as the transmission upgrades caused by New Jersey’s offshore wind projects?
And if they are more accurately categorized as public policy projects, should such projects be regionally cost-allocated, potentially to consumers in Pennsylvania, West Virginia, Ohio, et al.?

It is ultimately the job of each state to ensure resource adequacy to serve its consumers, even in a multi-state RTO. ​

Protect Our Winters, a group formed to safeguard outdoor recreation from the effects of climate change, is advocating a draft bill that would increase fees on Energy Department loans for transmission lines, with the new revenues going for infrastructure projects in communities where the new lines are built.

In doing so, the group is hoping to dispel a “not in my backyard” mentality that has been common in some rural communities, where transmission lines were seen as detriments to the aesthetics of the wilderness frequented by skiers, climbers and outdoor enthusiasts.

The group’s staff, along with outdoor athletes, are seeking support for the draft they partnered on with Rep. Ann McLane Kuster, D-N.H., hoping that it will garner bicameral, bipartisan support when it’s formally introduced. The group came to Washington last week to drum up support.

I saw and heard many statements today that a grant project must “be connected to”, “nearby”, or “have a nexus to” a transmission project.  In order to determine if applying for funding is even worthwhile, I need to have this explained.

1. DOE has not specifically defined a geographic distance from the project for eligibility purposes.  We anticipate that each project may differ in its scope and impact, therefore we have requested that each applicant should explain how their proposed project is eligible for support under this program. In addition, please note that the merit review criteria listed in the FOA at Section V states that applications for economic development activities will be assessed in part based on, “The extent and clarity of the connection described in the Application between the proposed activities and economic development benefits in communities that are likely to be impacted by a covered transmission project.”
   
   

How will “communities that may be affected by the construction and operation of a covered transmission project” be defined for eligibility purposes?  How far from the centerline of the transmission project does such a community extend?

1. As we anticipate that impacts may vary by project and by community, DOE has requested Applicants for Area of Interest 2 address how the project will promote economic development in areas that may be affected by the construction and operation of a covered transmission project. See Section IV.E.iii of the FOA.
   
   

What is considered an “affect” of construction and operation of the project?

1. For an understanding of how grants will be awarded, please refer to the merit review criteria for Area of Interest 1 (siting and permitting) and Area of Interest 2 (economic development) listed in the FOA at Section V. You may also refer to the “Standards for Application Evaluation” and “Other Selection Factors” including “Program Policy Factors” that are also referenced in Section V of the FOA. 
   
   

How will an economic development grant be expected to speed up siting and permitting?

1. While the funds associated with an economic development grant can only be disbursed once either the siting authority has approved the covered transmission project (if the applicant is a siting authority) or construction has commenced (if the applicant is a state, local, or Tribal governmental entity other than a siting authority), DOE may select awardees for economic development grants prior to a decision to site and permit the relevant transmission project and obligate federal funds for such awardees.  To the extent that the activities, if awarded, would accelerate transmission siting timelines and/or increase the chance that a transmission project would be developed, DOE will consider that as part of the established Merit Review Criteria.

Kuster, a member of the House Energy and Commerce Committee, noted in a statement that the U.S. may need to triple energy transmission capacity by 2050 to meet the target of net-zero carbon emissions by bringing more renewable electricity generation on line.

“In order to make that a reality, we must ensure that communities where transmission projects will be built are excited to host these lines,” Kuster said.  “By securing tangible benefits for the towns and cities that host these projects, like new schools, roads, or outdoor recreation facilities, in addition to improved electricity reliability, this legislation will help build support for transmission projects across the country.”