Transmission Tales: PG&E Underground, Texas Transmission Autarky, State Interconnection Rules

San Francisco’s Pacific Gas & Electric – devastated by recent wildfires – is looking to bury some 10,000 miles of electric transmission lines over the next decade in order to prevent its often elderly overhead equipment from starting fires, at a cost of $15 billion to $30 billion, according to NBC Bay Area News. The giant utility, the largest in the state, announced that goal last year, after the 2018 Paradise fire claimed some 80 lives and pushed PG&E in 2019 into its second Chapter 11 bankruptcy proceeding in 20 years.

This year, PG&E is looking to bury some 350 miles of transmission and aiming for 2,000 miles placed underground by the end of 2026. According to the company, by October 10 the utility had energized 137 miles of the 350-mile target. “Our team has learned and accomplished so much in the past two and a half years since we announced our 10,000-mile Undergrounding Program,” said Peter Kenny, PG&E’s senior vice president of major infrastructure delivery, which includes undergrounding.

spools of covered conductor at an Edison site

But there is a significant obstacle to the company’s undergrounding goals: the California Public Utilities Commission. PG&E has proposed a four-year budget for the undergrounding project of about $6 billion, or $3.40 per month for the average bill.

That’s too much for the state utility regulators and a powerful local consumer group, The Utility Reform Network. TURN says burying power lines is a “very expensive way to prevent wildfires.” TURN notes that PG&E is “inherently incentivized to undertake more expensive infrastructure projects such as undergrounding. This is how the utility makes money, not by selling electricity or gas.”

The CPUC has proposed two alternatives to the PG&E plan. One, proposed by the commissions administrative law judges, would scale back the undergrounding schedule to 200 miles over four years. A second, by Commissioner John Reynolds, would allow undergrounding 973 miles by 2026. Both recommend using covered conductors instead of conventional bare wire on overhead wires. According to T&D World, Southern California Edison is deploying covered conductors on its transmission system, as a much less expensive approach to wildfire mitigation.

The CPUC is scheduled to take up PG&E’s general rate case, including funding for undergrounding transmission, on Thursday (Nov. 2).

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Texas is at the U.S. Supreme Court defending its policy of keeping out of state companies from building new electric transmission in the Lone Star State. In August 2022, the Fifth Circuit Court of Appeals ruled that a state law that prevents new entrants from building transmission in those areas of the state that are in interstate commerce (not the Electric Reliability Council of Texas, which is deliberately not connected to the rest of the U.S.) violates the Constitution’s Commerce Clause.

Most of the Texas panhandle and smaller portions of eastern and western Texas are not part of ERCOT and are connected to interstate wholesale markets through the Southwest Power Pool, the Midcontinent Independent System Operator, and the Western Electric Coordinating Council. In 2018, MISO proposed a 500 kV line to connect with Entergy Texas, which participates in the MISO wholesale market. In 2019, the state legislature passed a law (S.B. 1938) saying that new lines “that directly [connect] with an existing utility facility . . . may be granted only to the owner of that existing facility.” The law is implemented by the Public Utility Commission of Texas (PUCT).

NextEra Energy, which would build and operate the new line, appealed to a federal district court, which upheld the PUCT. NextEra then took the case to the appeals court. The three-judge appeals court ruling was scathing. “Imagine if Texas—a state that prides itself on promoting free enterprise—passed a law saying that only those with existing oil wells in the state could drill new wells. It would be hard to believe. It would also raise significant questions under the dormant Commerce Clause….Texas recently enacted such a ban on new entrants in a market with a more direct connection to interstate commerce than the drilling of oil wells: the building of transmission lines that are part of multistate electricity grids.”

Texas asked the Supreme Court to review the appeals court ruling. On Monday, the Justice Department argued that the court should not review the decision. Solicitor General Elizabeth Prelogar noted that the Federal Energy Regulatory Commission is considering “right of first refusal” provisions in its ongoing review of transmission planning. “If FERC were to adopt the proposed rule (or some alternative) while this case was pending before the court, that development might require supplemental briefing or otherwise complicate this court’s consideration,” she suggested.

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State interconnection rules “are some of the most important, but least talked about, policies for enabling the adoption of clean energy resources,” says the American Solar Energy Society. The Colorado-based solar advocacy groups says, “Out-of-date or poorly designed state interconnection rules can cause prospective clean energy customers to face long wait times (sometimes multiple years!) or high costs that hinder their ability to adopt clean energy. They can also undermine clean energy policy objectives and slow the transition to a cleaner grid.”

The Interstate Renewable Energy Council scores the 50 states, the District of Columbia, and Puerto Rico on their interconnection rules on an A-F scale and provides an interactive map at its web site. The rankings are based on “56 criteria worth 63 possible points that are separated into 10 categories.”

Only one state – New Mexico – got an A grade, with a check mark in eight of the 10 categories. Ratings of F (13) and D (18) vastly exceeded ratings of C (15) and B (5). Among the key takeaways: “Though some states may have the same letter grade and/or numerical score, no two states have exactly the same rules, meaning that there is a lack of standardization and consistency across state lines and even across electric utility territories that may be spread out over different states and regions.”

 

–Kennedy Maize

kenmaize@gmail.com

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