Zap the Sleeping Giant: Revamping Order 1000 to Facilitate Decarbonization Across the Western United States

Feb. 3, 2022   /   Benjamin Criswell



Across the United States, public policies with ambitious decarbonization requirements affect electricity systems spanning various jurisdictions and geographies. In 2011, the Federal Energy Regulatory Commission issued Order 1000, recognizing the importance of incorporating federal, state, and local public policy requirements into regional and interregional transmission planning and coordination. Alas, Order 1000 has failed to reconcile electricity grid balkanization across the western United States. This failure threatens to thwart decarbonization efforts, expose electricity customers to unfair rates, and undercut grid reliability. But even without new federal legislation, the Commission could revamp Order 1000 and leverage existing statutory mechanisms to facilitate the creation of transmission systems sufficient to comport with decarbonization goals and other public policy requirements.

You can read the full Comment here.


Additional Thoughts

This was a difficult paper to write because the world of electricity is rapidly evolving. As I note in the Forward, during the editing and publishing of this Comment, the United States enacted legislation and initiated a rulemaking process set to transform the development and management of the electricity grid. Further, CAISO (the grid administrator in California) released its first-ever “20-year Transmission Outlook.”  NorthernGrid, a recently-formed transmission planning region combining former members of ColumbiaGrid and NTTG (including Bonneville Power Administration), published its most recent Regional Transmission Plan. The Northwest Power and Conservation Council is nearing completion of its Eighth Power Plan. And the Northwest Power Pool continues developing its Western Resource Adequacy Program.

The Western Interconnection is at a critical and exciting moment. Policymakers continue to recognize the decarbonization imperative and accordingly plan for a grid that will feature greater contributions from wind, solar, batteries, and other technologies that reduce carbon emissions associated with our electricity systems. As regional and interregional plans take shape, stakeholders, regulators, and lawmakers must ensure the resulting monumental investments are prudent and compatible with a clean energy future.

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