On June 17, 2010, the Federal Energy Regulatory Commission (FERC) initiated a Notice of Proposed Rulemaking (NOPR) to correct deficiencies in current transmission planning and cost allocation processes. On November 12, 2010, the Solar Energy Industries Association (SEIA) submitted reply comments to the FERC NOPR. In their comments, SEIA emphasized that "the current disaggregated planning process in the West creates uncertainty and stymies development of transmission" and provides an analysis of the issues in the whitepaper attached to their comments entitled, "Removing Transmission Barriers to Solar Energy Development in the Southwest." SEIA Reply Comments, Docket No. RM10-23-000, pg. 4.
The existing grid was designed around baseload generation facilities that were built close to load centers. Long distance transmission was generally designed to carry power generated from coal, nuclear and hydro power generation facilities and there was little extra capacity designed into the system. More capacity is needed to support integration of renewable generation and transmission needs to be designed to coordinate remote resources with the energy load centers that need the power. In addition, the intermittency of renewable resources can be minimized across a geographic region. Thus, transmission planning is regional.
SEIA provides that the following steps are necessary to enable utility-scale solar development:
1. "Transmission planning must be done on a regional level." Energy development across a multi-state region should be coordinated.
2. The disconnect between transmission planning processes and commercial-scale energy development must be addressed in order to facilitate energy development in the short term. "Planning, permitting and construction of foundational transmission lines must be achieved by 2014."
3. A multi-jurisdictional and multi-stakeholder approach should be used to address seams issues.
4. "Planning cannot be done in geographic or jurisdictional isolation. Each of these entities has a role to play (in siting, transmission study, grid management, and cost recovery) and must do their part to ensure timely development of renewable generation."
5. "A regional planning process must prioritize the planning, permitting, cost allocation and construction of key foundational lines."
SEIA concludes that the renewable energy industry is being hurt by the lack of coordinated planning, siting and cost allocation for regional transmission projects in the southwest. The SEIA whitepaper can be found under FERC Docket No. RM10-23-000.