I. Scale Generation and Transmission Projects to Enable Load Growth
The GridWise Alliance does not comment on individual energy projects; however, in response to rising energy demand and the pressing need for grid investments to improve reliability, GridWise members developed a statement, Vision for an Integrated Grid1, that describes how to prioritize investments across the transmission and distribution systems to meet new energy demand by expanding the overall capacity of the nation’s electric grid, including deploying new technologies on existing transmission lines and investing in local distribution systems.
GridWise notes that in addition to building new transmission, the nation must expand the capacity of the existing transmission system, improve integration between the transmission and distribution systems, increase the capacity of distribution systems, and maximize the availability of grid-edge resources for additional power and flexibility. We emphasize that this is not an either-or approach, but rather a coordinated strategy for maximizing the capacity of the current transmission and distribution system while awaiting the benefits of an expanding transmission network and new large-scale generation.
Increasing the Capacity of Existing Transmission Lines
The deployment of new technologies can significantly increase the capacity of the existing transmission system on a faster timeline, and often at considerable cost-savings, than building new transmission. These technologies should be considered not only on existing lines but for all new transmission lines.
- Grid-Enhancing Technologies (GETs): Implementing technologies such as dynamic line rating (DLR), advanced power flow control (APFL), and topology optimization can maximize the efficiency of new and existing transmission lines. Unlike traditional transmission projects that can take five to ten years for planning and construction, many GETs can be implemented in less than a year. GETs can effectively complement new transmission projects by increasing capacity and integrating more resources before new transmission projects can be executed. GETs provide immediate solutions to solve grid issues, while providing more time to plan future transmission projects.
- Reconductoring: Replacing existing conductors with advanced conductors allows the transmission of more electricity without acquiring new rights-of-way. Reconductoring with advanced conductors is estimated to cost less than half the price of building new transmission lines. An estimated 20% of transmission lines across the country could be viable candidates for reconductoring.
- Strategic Storage Deployment: Utilizing energy storage strategically across the system can relieve transmission constraints and provide peak power, further mitigating the need for new transmission lines. Additionally, deploying energy storage technologies can increase the resiliency of the transmission network by providing contingency power support in the event of outages.
- Load Flexibility: Grid operators can coordinate with large energy users—such as industrial facilities, data centers, and water pumping operations—to curtail, shift, or modulate their usage in response to grid conditions. By reducing strain during infrequent peak or emergency events, load flexibility can strategically support grid reliability and help defer or avoid costly future infrastructure investments.
Increasing the Capacity of the Distribution System and Harnessing Local Resources
A reliable, resilient, and modern grid will be essential to enable the connection of increasing volumes of both generation and demand, accelerate the speed of infrastructure development and, in doing so, position the U.S. to win the global AI race. The distribution grids that deliver energy to end consumers, and the customers themselves, will have a particularly critical role.
In the short term, Demand Response (DR) will be the fastest, most cost-competitive option to meet peak demand and grid stress. Aggregated Distributed Energy Resources (DERs), including rooftop solar, storage, and electric vehicles, can now provide additional power and grid flexibility to both the distribution and transmission systems, and in many cases can deliver power to the bulk power system faster than new large-scale generation (but will not replace the need for new large-scale generation). Harnessing DERs and developing more local resources like distribution-level storage and microgrids can alleviate the need for some new transmission and increase resiliency and affordability for consumers. Local resources will help meet skyrocketing electricity demand while new utility-scale generation and transmission are built.
The GridWise Alliance detailed the grid investments necessary to connect aggregated DERs resources in the distribution system to the bulk power system in a report on implementing FERC Order 22222. To support the complex, decentralized, and varying operating characteristics of DERs in an aggregation scheme, hardware and software technologies and procedures (see table 1) are required to ensure reliable and efficient operation. These technologies support advanced communication and analysis of data, enhance grid operations, provide system visibility, and allow for system-wide management of DERs.
Table 1. Grid Technologies to Support Aggregation of Customer Resources
Integration of Transmission and Distribution
Many key commercially available, but underutilized, advanced grid solutions are ready for deployment in distribution and transmission networks to increase the capacity, visibility and integration of supply and demand across the entire grid system. Note that many of these solutions are software applications that allow grid operators to manage voltage, reactive power, power-flow control, and other grid capabilities in concert with grid hardware. These grid solutions are differentiated into five categories:
- Advanced Transmission Technologies: Advanced conductors and point-to-point high voltage direct current (HVDC), Flexible AC Transmission Systems (FACTS) such as Static Synchronous Compensators (STATCOM), Fixed Series Capacitors (FSC), and Synchronous Condensers
- Situational Awareness and System Automation Solutions: Advanced sensors, distributed energy resource management systems (DERMS), advanced distribution management systems (ADMS), volt/VAR optimization (VVO), and more
- Grid Enhancing Technologies: Dynamic line rating (DLR), advanced power flow control (APFC), topology optimization
- Technologies to Enhance Flexibility: Virtual power plants (VPP), Distributed Energy Resource Management Systems (DERMS), energy storage, and advanced flexible transformers
- Foundational Systems: Communication technologies, data management systems, system digitization and visualization, and alternate timing and synchronization
If these solutions were deployed today, the transmission and distribution capacity could expand to support 20 to 100 gigawatts of incremental peak demand while also improving energy reliability, resiliency, and affordability. These deployments are essential to effectively address accelerating grid pressures. Furthermore, integrated planning that considers both the distribution and transmission systems will be critical not only to better forecast energy demand but to facilitate the connection of customers to wholesale markets.
Scale of DOE-Supported Grid Projects
The GridWise Alliance supports DOE’s goal of identifying major transmission and generation initiatives that can serve substantial new load. However, the 3-20 GW incremental load requirement outlined in this RFI may inadvertently exclude numerous well-developed projects capable of delivering meaningful results and achieving Speed to Power Initiative goals more quickly. We suggest the Department consider reducing these minimum requirements or adopting tiered screening categories (i.e. 100-500 MW, 500-1,000 MW, and so forth) to expedite identification of projects ready for immediate implementation, including distribution system upgrades. Using tiered categories instead of fixed minimums would provide the Department with greater flexibility to assess how smaller and medium-scale projects collectively compare to larger multi-gigawatt initiatives. This modification would broaden the range of qualifying projects while preserving the Department’s focus on significant infrastructure that enables load growth.
2. High-Priority Geographic Areas for Targeted DOE Investment
The GridWise Alliance does not take positions on individual grid modernization projects or recommend investment in specific geographic areas. However, as part of our “GridWise Alliance Vision for an Integrated Grid,” our members identified the following priorities for transmission investments:
1. Regional Interconnections: The National Transmission Needs Study notes that interregional and cross-interconnection transmission investments will improve system resilience and alleviate resource adequacy concerns by enabling increased access to diverse generation resources across regions. Developing transmission infrastructure between different regions can reduce resource adequacy concerns by unlocking access to resources generated in different climatic zones.
2. Permitting Reform: Streamlining siting and permitting processes across federal, state, and local levels is vital. Congress is currently considering proposals to amend the National Environmental Protection Act (NEPA) and other statutes to improve coordination and alleviate conflicting authorities across overlapping statutes and agencies.
3. Cost Allocation and Benefit Analysis: A comprehensive understanding of the financial benefits from increased transmission capacity to ratepayers is essential. The Liftoff report highlights that many capacity-increasing GETs are low-cost and provide greater value to ratepayers. Currently, the DoE is providing federal funding for advanced grid technology deployment and large scale transmission development to further reduce pressure on rates.
4. Reducing Time for Interconnections: Transmission and distribution projects can take many years, on average, from planning, permitting, construction to operations, and the projects may go through an ISO or State processes, in order to identify the scope and nature of their electrical infrastructure. Over the next years, there is a need to reduce the total interconnection timeframe for both new generation and new load.
5. Integrated Planning: The interconnected nature of the distribution and transmission systems mandates a holistic planning approach. The implementation of FERC Order 2222, aiming to integrate distributed energy resources into bulk power markets, epitomizes this integrated vision.
6. Transmission Investment Optimization: Transmission operators can utilize technology solutions to implement a transmission loading order approach where increased grid capacity in existing rights of way with GETs or reconductoring is initially pursued, followed by new transmission line construction that includes advanced transmission technologies for enhanced grid controls and stability.
If DOE implements a process for prioritizing federal intervention in specific geographic areas, GridWise urges the agency to use well-defined criteria and transparent methodology to identify and communicate high-priority zones. GridWise members emphasize the importance of basing these decisions on objective factors like reliability, security, and impacts on electricity rates for all consumers.
Most importantly, GridWise Alliance urges DOE to align federal efforts to accelerate grid modernization with the need to balance investments between transmission capacity expansion, new generation, and distribution system upgrades. While this RFI focuses primarily on large-scale generation and transmission, the distribution system can provide significant power and flexibility to the overall grid in a faster timeframe at potentially lower overall cost than investments in new infrastructure.
3. Use of DOE Funding, Financing, and Technical Assistance
The GridWise Alliance offers the following observations and recommendations for DOE funding, financing, and technical assistance:
1. GridWise emphasizes that there is no lack of capital for grid investments, but that uncertainty in federal and state policy and regulation can create disincentives for investment or increase the cost of capital.
2. Federal loan guarantees are less attractive to entities that can obtain funding from the private equity/capital markets unless there are significant savings.
3. The application, contracting, and reporting requirements traditionally associated with federal funding can be onerous for applicants and can deter companies from pursuing these federal programs. DOE should streamline these processes to make programs more accessible and attractive to potential applicants.
4. DOE should explore ways to reduce the administrative overhead associated with grant programs, which can significantly erode the value of federal funding.
5. GridWise recommends that DOE explore ways to more effectively leverage public-private partnerships to accelerate project development, including cost-sharing mechanisms.
6. Federal funding is highly impactful in addressing the significant challenges for private sector investment in foundational research.
7. Providing resources (both funding and technical assistance) to publicly owned utilities, particularly small- and medium-sized entities, will facilitate grid modernization and reduce rate pressure on consumers.
8. DOE should coordinate grid funding across silo-ed programs through staff committees managed at the Deputy Secretary level to ensure that federal programs leverage investments from basic R&D to technology deployment to achieve the President’s goals.
9. Some of the most critical data gaps related to meeting increased energy load relate to load forecasting, infrastructure capability, and supply chain constraints. DOE could play an important role in providing national insights into these challenges. DOE’s national labs can provide support for planning and modeling for the integration of large loads, and new super-computers can provide increased capacity for scenario planning.
10. DOE should consider the importance of upgrading existing grid infrastructure as well as supporting new infrastructure. Core assets such as transformers, circuit breakers, reclosers and switchgear are critical to ensuring the reliability and resilience of our grids and are foundational for expanding grid capacity and enabling demand growth.
11. DOE should consider the essential linkage between hardware and software in a digital, modern grid when designing programs to meet energy demand. Modern software platforms are proven, near-term pathways to expand grid capacity, improve reliability, enhance cybersecurity, and integrate new loads at lower cost.
Critical Caveat: Certainty in Federal Support
While federal programs can accelerate grid modernization, their effectiveness depends long-term regulatory and contractual certainty. The electric grid industry operates on fundamentally different timelines than other sectors; transmission projects require 7-15 years from conception to energization, and grid infrastructure investments are amortized over 30-50 year periods.
Recent contract cancellations and permit reversals have added a risk premium to decisions about pursuing DOE financing and funding opportunities. Private developers and utilities now must price in the possibility that federal loan guarantees or grants will be revoked mid-construction, that siting approvals will be overturned after years of environmental review, or that tax credit structures will be retroactively modified.
Regulatory and program uncertainty and lengthy federal approval processes complicate project financing and development. Utilities and developers have expressed new hesitation to pursue federal cost-share programs and may in the future prefer opportunities where the federal share is greater than the traditional 30-50% model, reducing the number of projects DOE can support with available funds. Grid developers are also increasingly pursuing projects entirely within state and regional frameworks, even when interstate transmission would better serve reliability and affordability goals.
Without assurance of long-term certainly in federal agreements, grid developers will continue to pursue the lowest-risk path, which may increasingly mean avoiding federal partnerships entirely, even when those partnerships could deliver projects faster, cheaper, and more aligned with national energy security interests.
5. Grid Infrastructure Constraints
The GridWise Alliance concurs that DOE has identified all significant constraints that impact the acceleration of investments in grid investments to address the historic increase in energy demand across the country.
Note on supply chain constraints (5.iv): GridWise recently launched a Supply Chain Initiative that can provide critical insights to DOE on critical macro-economic and sector-specific trends affecting the availability, sourcing, price, delivery timelines and other factors related to electric grid components. These components are no longer acquired exclusively by the utility sector but increasingly by data centers, manufacturers, and other new actors acquiring and generating power across the grid, increasing supply chain constraints that will slow the development of infrastructure necessary to support rapid electricity demand growth.