SERTP: True Regional Planning, or Siloed Utility Plans in a Trench Coat?

The Southeastern Regional Transmission Planning (SERTP) process encompasses nine utilities across the southeast. SERTP is meant to be a regional process designed to address regional problems “rather than the public utility transmission provider planning only for its own needs or the needs of its native load customers” in line with FERC’s intentions in Order 1000.  At this quarter’s SERTP meeting, stakeholders identified numerous problems in process, methodology, and interpretation of the requirements of a regional transmission planning process. 

First, stakeholders noted that many of the materials provided before the meeting on the SERTP website would appear, then disappear. Some stakeholders were unable to access the hundreds of pages of materials before, and during, the meeting. Without early access to the volumes of information to be presented at a meeting, it’s often difficult, if not impossible to adequately prepare for a meeting.

Next, stakeholders noted that the winter peak load forecasts appeared to be exceptionally low, given the major announcements from the large utilities in the southeast. While utilities agreed that "there's clearly something wrong" with the materials that were presented to the stakeholders, there is no formal process for stakeholders to follow regarding data errors. Utilities mentioned that stakeholders may be able to gain more information about the data presented through the Critical Energy/Electric Infrastructure Information (CEII) portal. CEII designation is reserved only for trade secrets or other information that may be important to shield from otherwise public view. To gain CEII access, SERTP stakeholders are required to pay hundreds of dollars to Southern Company to conduct a “background investigation”. Utility load forecast data are often already publicly available; however, each utility’s individual forecast may be hidden deep within a state docketed proceeding. Designating otherwise publicly available information as trade secret, confidential, or CEII unnecessarily restricts stakeholder involvement, and regional regulatory oversight. SERTP utilities also agreed with this point at the meeting: not all data deserves to be CEII designated. But there’s no clarity on where the line is between materials that are designated CEII, and public in SERTP.

At this point, it is unclear what utility forecasts have been provided to and are being used by the SERTP utilities for modeling purposes. When asked if the recently approved Georgia Power integrated resource plan (IRP), which includes over 6 gigawatts of new load by 2030, was included in the base case data, it sounds like those forecasts may not be included in modeling until next year. Meanwhile, some generation in the Georgia IRP that were approved (and some that were not approved) were included in the SERTP data update. When a utility planning model includes generation that was planned, based on higher load forecasts, but those higher load forecasts were not provided in the same model, the model results will not reflect reality. While some state regulators and utilities have argued that the state IRP process is essentially perfect for transmission planning, IRP incorporation into SERTP is haphazard at best.

In another example, Duke Energy’s Carbon Planning efforts are not reflected in the data provided to SERTP. Duke representatives explained that offshore wind projects are not included in the SERTP generation data because those potential projects don’t include a signed generation interconnection agreement (GIA). Meanwhile, Duke has included multiple “proxy” generators at locations where existing coal units are planned for retirement. Those “proxy” generators are not included in Duke’s IRP, nor do those resources have a signed GIA. Meanwhile, offshore wind is in Duke’s state plans, but the SERTP data tell a wholly different story. The North Carolina Utilities Commission public staff noted that the data appears “extremely stale” for regional planning, to which Duke representatives agreed.

In perhaps the most bizarre case, Louisville Gas & Electric/Kentucky Utilities (LGEKU) are not even including generation projects that have been approved by their state regulator, the Kentucky Public Service Commission (PSC). Utilities will often conduct an IRP to determine generally the technology types for new power plants, but not necessarily specific locations. Specific generators go through the generator interconnection process to “plug in” to the grid, allowing for a specific location to be studied. State PSCs will often review a utility’s request to either construct, contract with, or acquire a power plant through a proceeding called a Certificate of Public Convenience and Necessity (CPCN). That CPCN approval gives a utility permission to move forward with a new power plant. Still, LGEKU is not including recently approved power plants in the SERTP, because according to LGEKU, those generators also need to have a transmission service request (TSR). If an IRP is sort of like a compass to get you where you’re going, the CPCN is a GPS, and a TSR is the name of your Uber driver on the way to your final destination. Effectively, long-range planning is impossible in SERTP because the TSR is completed so late in the generator development process. LGEKU clarified that the utility theoretically could provide SERTP with updated generation retirement and additions data, because it’s up to each individual utility to determine what the official “cut off” qualifier is for stating intentions, or not. There’s no standard practice.

Stakeholders filed requests for evaluation of multiple public policies including the Inflation Reduction Act, resolutions approved by the TVA Board of Director, North Carolina’s carbon law, Georgia’s IRP, and other requests. All of these requests were denied, or otherwise punted to a later date or a separate process. For instance, it was requested that the North Carolina Carbon Plan be included in the SERTP analysis. Duke explained that some transmission projects from its Red Zone Expansion Plan are included in SERTP, but not necessarily the load growth nor the generation, creating a sort of Frankenstein monster of various model inputs that do not all reflect similar forecasts. SERTP has never evaluated a public policy request, and it appears that the utilities involved intend on keeping it that way.
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FERC’s Order 1920 is designed to improve transmission planning practices and will certainly improve the SERTP process; however, it won’t be able to resolve all problems. For instance, the SERTP process is an annual process, whereas the Order 1920 process is guaranteed to occur at least once every five years. The regulators of the SERTP utilities should be more involved in SERTP and push for improvements in the current annual process, while anticipating the reforms associated with Order 1920. 

Simon Mahan is the Executive Director of the Southern Renewable Energy Association.