The Federal Energy Regulatory Commission recently submitted a staff report to Congress on the North American Reliability Corporation’s Interregional Transfer Capability Study. FERC declined Congress’s invitation to recommend statutory changes in response to the ITC study.
FERC’s staff report reaches several important conclusions about NERC’s ITC Study. APPA said from its point of view, these conclusions are correct:
- The ITC Study is an advancement in existing transfer analysis and modeling that provides a more comprehensive wide-area view of energy deficiencies under extreme conditions; but NERC itself recognizes that the study has limitations.
- While the ITC Study is useful in evaluating the energy adequacy benefits of additions to transfer capability, such additions are only one tool to help mitigate future risks to grid reliability.
- The ITC Study serves only as a first step that could lead to additional, more specific transmission planning studies whose scope includes reliably and economically serving load.
- A one-size-fits-all solution to increase transfer capability, such as requiring a minimum interregional transfer capability requirement as a specified percentage of peak load, may be inefficient and potentially ineffective.
The Fiscal Responsibility Act of 2023 (FRA) directed NERC to study how much electricity transfer capability exists between transmission planning regions and make recommendations on technically prudent additions to that transfer capability.
The FRA also directed FERC to collect public comments on NERC’s study and submit a report to Congress on its conclusions from that study with recommendations, if any, for statutory changes.
The ITC Study, released in November 2024, conducted hourly analysis using consistent assumptions across regions in a single transmission model. The ITC Study found that interregional transfer capability varies widely across the country, that several regions of the country are at risk of energy inadequacy, and that 35 GW of additional interregional transfer capability could help address that risk.
APPA, joined by the Large Public Power Council, urged FERC in February 2025 comments not to recommend any changes to the Federal Power Act nor to recommend any new reliability standards.
The groups explained that the ITC Study provides evidence that any nationally uniform requirements for interregional transmission would be inappropriate. They also explained that regional planners can and must use economic data in addition to the reliability analysis to determine the most cost-effective solutions for maintaining reliability.
