A New, Collaborative Approach to Siting and Permitting Electricity Transmission Infrastructure

Summary: The Biden administration has committed the US to a 50–52% reduction of greenhouse gas emissions from 2005 levels by 2030 and to net-zero emissions by 2050. To achieve these goals, the US must rapidly increase renewable energy production while simultaneously building the transmission needed to carry power from new renewable sources to consumers. Such an investment requires transforming the grid at a never-before-seen speed and scale. For example, a recent study estimates that a 60% increase in transmission capacity will be required. One way to achieve this ambitious target is to create a national High Voltage Direct Current (HVDC) transmission network overlaid atop the existing alternating current (AC) grid. In addition to advancing America’s climate goals, such an effort would spur economic development in rural areas, improve the grid’s energy efficiency, and bolster grid stability.

Challenge and Opportunity: The US grid resembles the US highway system before the interstate system. Just as roads connected most American towns and cities by the early 1950s, few areas are not electrified today. However, many of these roads were circuitous, prone to congestion, and ill-suited to quickly move large numbers of vehicles across the country. The current AC lines that crisscross the country are similarly inefficient due to tangled, congested routes. As a result, they are ill-suited to quickly move renewable energy from energy-producing, low-demand regions to large population centers with high demand. Since HVDC transmission loses less power than AC lines at distances over 300 miles, HVDC technology is the best candidate to connect the renewable generation required to achieve net-zero emissions by 2050 with power consumers.

There is a dearth of HVDC lines in the US today, and the scattered few that do exist were not designed to ease renewable development. Recent attempts by the private sector to begin building the long-distance HVDC network necessary for net-zero emissions — such as Clean Line Energy’s proposals for lines that would have linked much of the Great Plains and Southeast — have not been successful due to siting and permitting challenges. However, a new generation of private developers has proposed an innovative solution: constructing an underground nationwide HVDC network alongside existing railroads. This solution takes advantage of the proximity between areas with wind and solar energy potential and existing rail infrastructure (Figures 1–3). In addition, it bypasses issues with eminent domain, landowner opposition, visual pollution, and permitting that have plagued previous projects. Despite these advantages, collaboration among various stakeholders remains essential to developing rail co-located transmission at the scale needed to achieve the Biden administration’s climate goals. This memo proposes a pathway for how the US Department of Energy (DOE) and Federal Energy Regulatory Commission (FERC) can accelerate and facilitate these essential collaborations.

Figure 1: Routes of all seven class I commercial US railways (Source: Federal Railway Administration).

Figure 2: Heat map of average annual wind speed 80 meters above ground (an indicator of the potential for wind energy generation; Source: National Renewable Energy Laboratory (NREL)). Areas with high wind potential co-occur with already existing railways.

Figure 3: Heat map of direct normal solar irradiance (an indicator of solar-energy potential; Source: NREL). Areas with high solar potential co-occur with already existing railways.

Plan of Action: DOE and FERC should adopt a collaborative strategy to identify, with relevant stakeholders, mutually agreeable routes for rail co-located HVDC transmission. This collaborative approach would harness the political momentum surrounding the newly created DOE Undersecretary of Infrastructure office as well as DOE’s recent Building a Better Grid Initiative. The new undersecretary, in partnership with FERC’s Office of Energy Policy and Innovation (OEPI), should together begin efforts to bring representatives from each state, utilities, the seven major US railways, and transmission developers to a series of “transmission summits” as soon as possible. These regular summits can serve as venues to build consensus on transmission routes that meet the concerns of all parties.

This approach sharply differs from previous attempts by Congress in Section 216 of the Federal Power Act and in 2021’s Infrastructure Investment and Jobs Act to establish greater federal power over transmission siting and permitting. Congress’ previous efforts have revolved around (1) the DOE’s authority to designate some counties prone to grid congestion as National Interest Electric Transmission Corridors (NIETCs) and (2) FERC’s authority to supersede states’ permitting and siting decisions if a rejected project is in a NIETC and meets certain conditions, including benefits to consumers, enhancement of energy independence, or if the project is “consistent with the public interest”.

Congress’ aggressive approach is unlikely to lead to the sudden acceleration of transmission development necessary to achieve the Biden administration’s climate goals. This is because NIETC designation, as well as any FERC action under Section 216 of the Federal Power Act, would (1) trigger the development of multi-year environmental impact reviews under the National Environmental Policy Act (NEPA), and (2) would likely engender strong political opposition by states and landowners whose properties would be part of proposed routes but would not receive any benefits from transmission investments. A collaborative approach to rail co-located transmission development would forestall lengthy NEPA reviews and would decrease the possibility of political opposition due to the relatively small number of stakeholders and location of rail co-located HVDC in already disturbed corridors.

Conclusion: A significant increase in transmission capacity is needed to meet the Biden administration’s efforts to achieve net-zero emissions by 2050. Creating a nationwide HVDC transmission network would not only greatly aid the US’ efforts to meet this goal; it would also improve grid efficiency, stability, and security and would provide sustained economic development in rural areas. Recent proposals to construct HVDC transmission alongside existing rail corridors are examples of innovative solutions to legitimate stakeholder concerns over environmental impacts and the use of eminent domain — concerns that have plagued previous failed efforts to construct long-distance HVDC transmission. To address these concerns while accelerating transmission development to meet the Biden administration’s climate goals, DOE and FERC should embrace a collaborative strategy where all relevant stakeholders for rail co-located HVDC are engaged to plan essential new transmission infrastructure.