《Brattle Group:海上风电传输协同规划过程的优势(英文版)(103页).pdf》由会员分享,可在线阅读,更多相关《Brattle Group:海上风电传输协同规划过程的优势(英文版)(103页).pdf(103页珍藏版)》请在三个皮匠报告上搜索。
1、 The Benefit and Urgency of Planned Offshore Transmission:Reducing the Costs of and Barriers to Achieving U.S.Clean Energy Goals PREPARED BY Johannes P.Pfeifenberger Joe DeLosa III Linquan Bai Cornelis Plet(DNV)Carson Peacock Ryan Nelson PREPARED FOR Natural Resources Defense Council GridLab Clean A
2、ir Task Force American Clean Power Association American Council On Renewable Energy The Benefit and Urgency of Planned Offshore Wind Transmission B|i ADVISORY PANEL STUDY SPONSORS Cullen Howe,NRDC Ric OConnell,GridLab Nicole Pavia,CATF Gabe Tabak,ACP Kevin ORourke,ACORE RTOS Suzanne E.Glatz,PJM Robe
3、rt Ethier,ISO-NE NYISO(invited)CAISO(invited)STATES AND REGULATORY EXPERTS John Bernecker,NYSERDA Robert Snook,CT DEEP Abraham H.Silverman,Esq.,NJ BPU Suedeen Kelly(former FERC Commissioner)ACADEMIC AND INDUSTRY EXPERTS Prof.Eric Hines,Tufts Robert Gramlich,Grid Strategies Beverly Bendix,RMI Christi
4、na Hayes,Americans for a Clean Energy Grid Lopa Parikh,Orsted Shaela Collins,Shell Peter Shattuck,Anbaric Dave Effross,AFL-CIO William Magness,DNV Kevin Knobloch,National Offshore Wind Research and Development Consortium NOTICE AND DISCLAIMER This report was prepared for the named clients in accorda
5、nce with The Brattle Groups engagement terms and is intended to be read and used as a whole and not in parts.It reflects the analyses and opinions of the authors and does not necessarily reflect those of The Brattle Groups clients,Advisory Panel members,or other consultants.Advisory Panel members pr
6、ovided input and guidance related to study design and evaluation,but the contents and conclusions of the report,including any errors and omissions,are the sole responsibility of the authors.Advisory Panel member affiliations in no way imply that those organizations support or endorse this work.There
7、 are no third-party beneficiaries with respect to this report,and The Brattle Group does not accept any liability to any third party with respect to the contents of this report or any actions taken or decisions made as a consequence of the information set forth herein.2023 The Brattle Group,Inc.The
8、Benefit and Urgency of Planned Offshore Wind Transmission B|ii TABLE OF CONTENTS Executive Summary.1 The Urgency of Starting to Plan Offshore Transmission Now.16 A.Offshore Wind Commitments and Needs.17 B.The Urgency of Starting Proactive Planning.24 The Benefits of Proactively Planned Offshore Wind
9、 Transmission.31 A.Cost Savings from Proactive Regional Planning.31 B.Cost Savings and Resilience Value of Expanding Interregional Transmission.36 C.Environmental and Community Benefits of Proactively Planning OSW Transmission.41 D.Employment Benefits of OSW Development.42 The Challenges and Barrier
10、s to Achieving Timely,Cost-Effective OSW Transmission Solutions.43 Recommendations for Planning Cost-Effective Regional and Interregional OSW Transmission that Supports States Ongoing Procurement Efforts.66 Available Federal Support.91 .95 List of Acronyms.98 The Benefit and Urgency of Planned Offsh
11、ore Wind Transmission B|iii LIST OF FIGURES Figure ES-1:regional offshore wind procurement targets and long-term needs.3 Figure ES-2:Unplanned vs.planned Transmission for U.k.offshore wind in 2050.5 Figure ES-3:Unplanned vs.planned Transmission for New England OSW.5 Figure ES-4:Timeline of Recommend
12、ations.12 Figure 1:regional offshore wind procurement targets and long-term needs.20 Figure 2:U.S.offsHore Wind energy areas and call areas(as of 05/31/2022).22 Figure 3:BOEM OFFShore Wind leasing Schedule.23 Figure 4:Transmission Technologies for existing and Proposed OSW Plants.53 Figure 5:HVDC Te
13、chnology Readiness.55 Figure 6:Timeline of Future Technology Development for Offshore Wind.56 Figure 7:Offshore Transmission Design Concepts.58 Figure 8:Timeline of recommendations.68 LIST OF TABLES Table ES-1:Offshore Wind Procurements,Goals,and Long-term Needs.2 Table 1:Offshore Wind Targets and L
14、ongterm Needs.18 Table 2:OSW Development Pipeline as of December 2022.21 Table 3:United States Technical OSW Resource Potential.23 Table A-1:Offshore Wind Commitments and Future Needs.95 The Benefit and Urgency of Planned Offshore Wind Transmission B|1 Executive Summary _ There is an urgent need to
15、plan the transmission grid necessary for achieving Americas increasingly ambitious offshore wind(OSW)and clean energy goals.Proactive and holistic planning for long-term transmission needs offers significant benefits,but unless these planning efforts are started now,more attractive near-term transmi
16、ssion solutions will not be identified and the most effective long-term grid development pathways may be foreclosed.While the most ambitious state and federal clean energy goals will not have to be attained until 2040 or 2050,we project that starting proactive planning for these long-term offshore w
17、ind generation needs now likely will save U.S.consumers at least$20 billion and reduce environmental and community impacts by 50%.Doing so will also support the timely achievement of policy goals,increase reliability,lower development and investment risks,increase energy independence,and improve cli
18、mate resilience.To achieve these benefits,state and federal policymakers,industry regulators,system operators,and market participants must expeditiously address several well-documented challenges.As shown in this analysis,even modest delays in developing and implementing actionable plans for both ne
19、ar-and long-term transmission investments substantially reduces the benefits of such planning efforts.This reportfunded by the Natural Resources Defense Council(NRDC),GridLab,the Clean Air Task Force(CATF),the American Clean Power Association(ACP),and the American Council on Renewable Energy(ACORE)f
20、irst lays out in Section I the urgent case for proactively and holistically planning transmission solutions for the nations increasingly ambitious offshore wind goals.Section II reviews existing studies that document the benefits of proactive planning and quantifies the economic,environmental,and re
21、liability benefits offered by carefully planned offshore wind transmission solutions.Section III summarizes barriers that currently prevent the realization of these benefits.Section IV recommends specific steps that states,grid operators,the federal administration and key federal agencies,and indust
22、ry stakeholders need to take to create a pathway for no-regrets grid solutions that allows achieving near-and long-term offshore wind goals in a more cost-effective and timely manner.Section V summarizes available federal support for these initiativesincluding through the Inflation Reduction Act(IRA
23、),the Infrastructure Investment and Jobs Act(IIJA,which includes the new Transmission Facilitation Program),and U.S Department of Energy(DOE)appropriationsalthough more dedicated The Benefit and Urgency of Planned Offshore Wind Transmission B|2 federal funding would likely be necessary to make inter
24、regional offshore wind transmission a reality.The remainder of this executive summary briefly discusses each of these points.THE AMOUNT OF OSW GENERATION THAT NEEDS TO BE INTEGRATED INTO THE GRID Increasingly ambitious federal and state clean energy goals require comprehensive,coordinated planning f
25、or OSW generation.While the most urgent transmission solutions address OSW goals of the next decade,a least-regrets development of these near-term solutions also requires the consideration of long-term goals.Developing transmission plans that are cost-effective in the near-term while creating attrac
26、tive pathways for addressing long-term goals must start with a clear understanding of both near-term and long-term offshore wind goals.While most current grid planning is still focused only on meeting state procurements and the federal administration OSW goal of 30 gigawatts(GW)by 2030,the OSW procu
27、rements and goals of 11 coastal U.S.states exceed 50 GW through 2035 and reach 77 GW by 2045,as shown in Table ES-1 and illustrated in Figure ES-1.TABLE ES-1:OFFSHORE WIND PROCUREMENTS,GOALS,AND LONG-TERM NEEDS Source:Appendix A.As Table ES-1 and Figure ES-1 further summarize,state-specific studies
28、of clean energy and decarbonization needs show that close to 200 GW of OSW generation may be required by 2050(GW)YearMassachusetts3.25.6202723Connecticut1.2220309-11Rhode Island0.41-1.420355Maine0.015New York4.49203514-25New Jersey3.811204011-26Maryland2220302Virginia2.75.2203420-30North Carolina820
29、40South CarolinaLouisiana520355California25204525Washington4-10Oregon3203020State Total17.677150-197U.S.Goal/Need1102050220-460StateAlready Procured(GW)Current GoalsProjected 2050 Needs(GW)7-10The Benefit and Urgency of Planned Offshore Wind Transmission B|3 to meet the total of state-specific needs
30、 in the U.S.While the federal administrations 2050 OSW target is 110 GW,some nationwide analyses(such as Princetons“Net Zero America”study)project that substantially more OSW will be required to cost-effectively decarbonize the U.S.economy by 2050.The generation output of most of these OSW projects
31、developed in the Atlantic,Pacific,and the Gulf of Mexicoincluding floating turbines in deep-water lease areas in the Gulf of Maine and off the Pacific coastwill have to be delivered to the onshore grid and to electricity customers in population centers,recognizing that some may be used to produce hy
32、drogen.Doing so will require a large number of submarine cables buried in the ocean floor,beach crossings,points of interconnection(POIs)to the existing grid,upgrades to the onshore grid near those POIs,and additional transmission to reach various load centers.To achieve this grid expansion cost eff
33、ectively requires improved and well-coordinated generation interconnection and transmission planning processes by the regional independent transmission system operators(ISOs).On the East Coast,where OSW development is the most advanced,these system operators are ISO New England(ISO-NE),New York ISO(
34、NYISO),and PJM Interconnection(PJM,which covers the coastline from New Jersey to North Carolina).FIGURE ES-1:REGIONAL OFFSHORE WIND PROCUREMENT TARGETS AND LONG-TERM NEEDS The Benefit and Urgency of Planned Offshore Wind Transmission B|4 As shown in Figure ES-1 above,the existing state OSW goals and
35、 projected long-term needs quickly increase beyond near-term grid interconnection requirements.Through 2050,NYISO likely needs transmission to interconnect up to 25 GW of OSW,ISO-NE may need to interconnect up to 40 GW,and PJM and the Carolinas up to 70 GW.System operators along the West Coast may h
36、ave to develop transmission solutions to interconnect 55 GW of floating OSW generation.Given this rapid acceleration of OSW generation,proactive planning of both near-term and long-term transmission needs is essential to create cost-effective options for interconnecting the large amount of OSW gener
37、ationalong with integrating the necessary land-based clean-energy resources and mitigating any environmental and community impacts from the construction of the necessary onshore and offshore transmission facilities.THE BENEFITS OF PROACTIVE OSW TRANSMISSION PLANNING Starting to plan today for the tr
38、ansmission infrastructure development pathway that can integrate this amount of offshore wind generation,and do so cost-effectively over time,will achieve significant economic,environmental,and social benefits.These benefits have been well documented by a wide range of studies and planning efforts.F
39、or example:A nation-wide study conducted for National Grid UK found that proactively planned offshore and onshore grid investments for approximately 60 GW of OSW generation in the United Kingdom added between 2025 and 2050 would:(1)reduce overall transmission costs by 19%(approximately$7.4 billion);
40、(2)reduce the miles of transmission cables installed in the ocean floor by 35%;(3)reduce onshore transmission line miles by 60%;and(4)reduce the number of beach crossings by 70%.Importantly,the study found that delaying the implementation of a planned solution by only five years(by beginning to addr
41、ess 2050 needs starting in 2030 instead of 2025)would reduce the benefits of a planned 2050 solution by about half.The studys results for 2030 and 2050 are illustrated in Figure ES-2 below.While similar U.S.studies are still ongoing,the insights from the U.K.are directly applicable to the U.S.and co
42、nsistent with initial U.S.OSW experience to date.For example,New Jerseys recently concluded proactive planning effort with PJM for interconnecting an incremental 6.4 GW of OSW generation resulted in cost savings of over$900 million(a 13%reduction of total OSW transmission-related costs)by reducing t
43、he cost of upgrades to the existing onshore grid by approximately two thirds.Doing so also reduced interconnection-related risks,created a more competitive environment for future offshore wind procurements,and mitigated environmental and community impacts by consolidating The Benefit and Urgency of
44、Planned Offshore Wind Transmission B|5 the number of additional onshore transmission corridors needed from three to one.This was the case even though New Jerseys selected solution focused almost entirely on the onshore transmission needs to integrate OSW generation.If the scope of the planning effor
45、t had been broader than just for offshore wind and only for New Jersey,the benefits would have been even larger.FIGURE ES-2:UNPLANNED VS.PLANNED TRANSMISSION FOR U.K.OFFSHORE WIND IN 2050(Assuming planning efforts start to be effective by 2025)Source:National Grid ESO,Offshore Coordination Phase 1 R
46、eport,December 2020.Similarly,two studies by The Brattle Group for Anbaric(an independent transmission developer)found that proactive planning of offshore wind transmission solutions significantly reduces both costs(e.g.,by$0.5 billion for an additional 3.6 GW of OSW in New England)and environmental
47、 impacts(e.g.,reducing the ocean cable miles installed by approximately 50%for an additional 8 GW of OSW,as illustrated in Figure ES-3 below).FIGURE ES-3:UNPLANNED VS.PLANNED TRANSMISSION FOR NEW ENGLAND OSW Source:J.Pfeifenberger,S.Newell,W.Graf,The Brattle Group,Offshore Transmission in New Englan
48、d:The Benefits of a Better-Planned Grid,May 2020.Planned HVDC+POI Approach Plausible AC Gen-Tie ApproachNeeded Onshore Upgrades in Red1620 miles of offshore cables830 miles of offshore cablesThe Benefit and Urgency of Planned Offshore Wind Transmission B|6 A preliminary study by PJM evaluating the g
49、rid upgrades necessary to interconnect 15 GW of OSW generation along with 60 GW of land-based renewable resources also shows the benefits of this type of proactive planning when applied to address the entire regions clean-energy and reliability needs:it would reduce the cost of necessary upgrades to
50、 the existing grid by over 80%compared to PJMs existing generation interconnection process.Recently completed joint interconnection and long-term transmission planning efforts for onshore renewables by system operators in the Midwestern U.S.the Midcontinent ISO(MISO)and Southwest Power Pool(SPP)simi
51、larly show that proactive transmission planning can reduce interconnection-related transmission costs by over 50%and provide significant reliability and other grid-wide benefits that reduce total costs.A timelier,more cost-effective,and risk-mitigated development of OSW generation through improved t
52、ransmission planning facilitates significant state and regional employment and economic benefits.Several studies 123 estimate that approximately 80,000 full-time jobs would be stimulated by the approximately 30,000 MW of OSW construction planned through 2030.Extrapolating from the consistent set of
53、findings from these studies,and conservatively assuming at least 100 GW of offshore wind generation additions by 2050(beyond already-ongoing procurements),the U.S.-wide benefits of starting proactive planning efforts for offshore transmission now are projected to:Lead to at least$20 billion in trans
54、mission-related cost savings;Result in 6070%fewer shore crossings and necessary onshore transmission upgrades;Reduce marine transmission cable installations on the ocean floor by 50%or approximately 2,000 miles;and Significantly accelerate achievement of offshore wind deployment timelines by elimina
55、ting transmission-related delays,reducing project-development and cost-escalation risks,reducing community impacts,achieving more competitive procurement outcomes,and facilitating investments in the local clean energy economy.Planning studies by DNV,PowerGEM,and WSP for NYSERDA further found that ne
56、tworked HVDC offshore transmission grids can deliver significant operational benefits.Going forward,OSW generation should consequently be procured with offshore facilities that are based on a standardized,modular design such that can interconnect with a“meshed”or“networked”offshore grid as part of a
57、 holistic grid planning process.Achieving such a networked offshore transmission system would further:The Benefit and Urgency of Planned Offshore Wind Transmission B|7 Improve the reliability and value of offshore wind generation deliveries;Allow for the utilization of new,higher-capacity transmissi
58、on cables(each able to deliver 22.6 GW of offshore wind generation),which further reduces costs and impacts to communities and the environment;Improve the utilization and flexibility of the offshore transmission infrastructure;Reinforce,avoid upgrades of,and support the existing regional onshore gri
59、ds,which will improve grid-wide resilience and reduce future congestion costs;and Offer unique,cost-effective opportunities to create valuable new transmission links between regions,including addressing system transmission constraints into New York City and New England that reduce system-wide cost a
60、nd increase interregional grid reliability and resilience.As summarized in this report,numerous regional and national studies confirm that expanding regional and interregional transmission capabilities offer substantial benefits that increase grid resilience,reduce system-wide costs,and mitigate inc
61、reases in electricity rates as the U.S.transitions to a more decarbonized electric sector by 2035 andas called for by state policies and the federal administrationaims to achieve a substantially decarbonized economy by 2050.If planned proactively and holistically,multi-purpose transmission links bet
62、ween OSW facilities can offer the lowest-cost,lowest-impact,and most feasible solutions for adding such regional and interregional transfer capabilities to the existing grid.THE URGENCY OF STARTING LONG-TERM TRANSMISSION PLANNING FOR OSW NOW While the nations mid-century offshore wind goals may appe
63、ar quite distant,proactive and coordinated planning efforts must begin immediately to fully realize these planning-related benefits.Actions taken in the next several years will not only impact the cost and environmental footprint of achieving OSW generation goals for the next decade,but will also pr
64、e-determine to a significant extent what is(or is not)possible by 2050.There are several reasons why it is so urgent to initiate regional and interregional planning for both near-term OSW goals and to create a least-regrets pathway for addressing long-term OSW transmission needs:Long developing time
65、lines:Transmission facilities for offshore wind will take at least a decade to plan,permit,and construct.This timeline is worsened by supply chain bottlenecks,which necessitate that equipment(such as submarine transmission cables,transformers,and highly specialize installation vessels)be ordered yea
66、rs in advance of The Benefit and Urgency of Planned Offshore Wind Transmission B|8 installation.As a result,any planning steps taken today are unlikely to yield significant new transmission infrastructure until the early 2030s.Effective use of limited corridors and interconnection points:The type an
67、d location of transmission facilities built to address 2030 or 2035 offshore generation needs will,in turn,directly impact the type and location of transmission facilities that can be built to meet 2040 and 2050 needs.As states continue to procure OSW resources that rely on single-project,radial del
68、ivery facilities,the lowest-cost corridors and interconnection points will be utilized first,making it increasingly costly and challenging to find more attractive long-term solutions and reduce environmental community impacts for the substantial OSW additions needed to achieve long-term goals.Both n
69、ear-and long-term needs have to be considered to specify least-regrets grid expansion pathways that can lead us to more attractive long-term planning outcomes.Technology compatibility:Unless existing regional transmission planning processes are improved and compatible technology standards are develo
70、ped now,a combination of poor planning and continued reliance on incompatible technologies will make it nearly impossible to realize efficiently integrated regional and interregional grid solutions in the future.Federal support:Finally,through the Infrastructure Investment and Jobs Act(IIJA)and the
71、Inflation Reduction Act(IRA),the federal government is currently offering support and tax credits to lower costs,address planning,and facilitate contracting for state and nationwide clean-energy needs,including regional and interregional transmission.Some of this support funds may not be available i
72、f planning efforts are delayed.Importantly,as is well documented,identifying the most attractive long-term solutions requires the development of more proactive planning processes that simultaneously consider the full set of transmission needs(i.e.,reliability,congestion relief,public policy,and gene
73、ration interconnection needs)over a long-term planning horizon(i.e.,through 2040 or 2050 to consider already-known policy needs).Focusing only on near-term transmission needs and addressing them incrementally will not yield cost-effective solutions in the longer-term.BARRIERS TO COST-EFFECTIVE,LEAST
74、-REGRETS OFFSHORE WIND TRANSMISSION The timely development of cost-effective and least-regrets long-term transmission solutions that integrate offshore wind generation holistically in coordination with onshore grid planning faces several distinct challenges.These challenges can be addressed expediti
75、ously and collaboratively as reflected in the recommendations below.The Benefit and Urgency of Planned Offshore Wind Transmission B|9 Inadequate generation interconnection processes:The slow,costly,reactive,and incremental generator interconnection processes currently used by regional grid operators
76、 are not suitable for optimizing grid interconnection points for the timely and cost-effective integration of renewable generation,including the 30 GW of offshore generation that states will soon have procured to meet their clean energy policy goals over this next decade.Uncertain tax credits:There
77、is significant uncertainty over the extent to which the availability of federal investment tax credits for offshore wind generators“wind energy property”applies to the cables and interconnection facilities that deliver the generation to shore and the extent to which these credits are available for s
78、uch facilities if they are shared by multiple OSW generators or owned by third parties.Siloed transmission planning:Many existing transmission planning processes do not yet proactively consider long-term public policy needs,nor do so holistically in combination with other transmission needs.Rather,r
79、egional grid planning is typically siloed into specific project categories that fail to simultaneously optimize the broad range of reliability,economic,and public policy benefits that can be provided by holistically-planned transmission investments that lower system-wide costs and mitigate increases
80、 in customer rates.No effective interregional planning:The grid planning challenge is even more severe for interregional transmission as these needs are not well defined and no effective interregional transmission planning processes currently exist.HVDC technology integration challenges:HVDC transmi
81、ssion technology is becoming critical to achieving cost-effective and less environmentally impactful OSW transmission solutions.Yet,the relatively slow adoption and operational integration of advanced HVDC technology in the U.S.creates its own set of unique challenges:(a)the functional requirements
82、of HVDC grids,optimal voltage levels,and transfer capabilities are not yet standardized;(b)equipment from different vendors is not yet compatible or otherwise standardized;(c)critical grid elements(such as DC circuit breakers)are not yet widely commercially available for offshore applications;(d)the
83、 large capacity of new HVDC technologies also exceed what many system operators currently view as an acceptable“most severe single contingency(MSSC)”;and(e)the capabilities of advanced technologiessuch as voltage support,black-start,fast power-flow control,means to address MSCC concerns,and system-s
84、tabilization capability of advanced HVDC convertersare not yet typically accounted for or accepted as solutions in transmission planning.Uncertain offshore network designs:The optimal choices for technology,grid topology,and cost-effective design of“meshed”or“backbone”offshore grids are still uncert
85、ain.While The Benefit and Urgency of Planned Offshore Wind Transmission B|10 some studies are underway,detailed benefit-cost cases are not yet available for specific offshore grid designs in the U.S.,nor for designs that will likely develop over the coming decades.Regulations and contracts:The regul
86、atory and contractual frameworks for the shared and networked operation and use of offshore transmission facilities(including procurement method,structure,evaluation criteria,cost allocation,and the inherent tension between open access provisions and priority interconnection rights)are not yet estab
87、lished.Grid operations:With infrequent exceptions,regional grid operators are not yet equipped to optimize the operations of a regional or interregional offshore grid to take full advantage of networked offshore transmission from a reliability operations and wholesale markets perspective.Transmissio
88、n tariffs under the jurisdiction of the Federal Energy Regulatory Commission(FERC)do not yet satisfactorily address coordinated operation of existing interregional transmission,which would also make it difficult to capture the full value of new interregional facilities.BOEM transmission permitting:T
89、he Bureau of Ocean Energy Management(BOEM)does not currently have a well-defined or broadly understood maritime spatial planning and permitting process for offshore transmission that is distinct from offshore wind generators individual interconnection cables.The project-by-project approach to OSW tr
90、ansmission is driven in part by BOEMs regulations,which bundle permitting for radial transmission lines as an easement right associated with the permitting of offshore wind generation in individual wind lease areas.Additionally,BOEM has not clarified how the presence of third-party offshore transmis
91、sion would affect the right of adjacent leaseholders to utilize their own radial lines if at all.Disjointed lease,procurement,and planning processes:The processes of lease area auctions,state procurement of OSW generation,and regional transmission planning are siloed and lack coordination.When OSW d
92、evelopers purchase offshore leases that can serve more than one RTO/ISO,it is often uncertain which region they will be connecting into and where the specific points of interconnection might be.When states issue solicitations for OSW generation,they do not know which lease area will serve them(altho
93、ugh,realistically,only a few generators with nearby lease areas can effectively compete in those solicitations).And transmission planners attempting to pre-build an offshore grid to address some states clean energy needs do not know which lease or call areas to target.This separation of leasing,proc
94、urement,and planning is inefficient and time consuming because it:(1)creates delays since neither OSW generators nor transmission developers can start planning and permitting the offshore transmission until they know which region they will be The Benefit and Urgency of Planned Offshore Wind Transmis
95、sion B|11 serving as determined by the outcomes of state procurements;(2)challenges the planning and development of efficient transmission solutions,adding costs to any prebuilt transmission since any chosen location of offshore collector stations may turn out to be suboptimal and lead to duplicativ
96、e offshore substations;(3)can reduce competition in OSW generation procurements since only a limited number of entities with nearby leases can compete;and(4)creates additional barriers for shared offshore transmission.RECOMMENDATIONS FOR ACHIEVING COST-EFFECTIVE REGIONAL AND INTERREGIONAL TRANSMISSI
97、ON SOLUTIONS WHILE INTEGRATING STATES ONGOING OFFSHORE WIND PROCUREMENT EFFORTS We recommend that state and federal policymakers and regulators,federal agencies,regional grid operators,and market participants expeditiously collaborate on the following initiatives to address the challenges discussed
98、above.As summarized in Figure ES-4 below,these recommendations have been grouped into the following four categories:Immediate(this year):actions to ensure some of the identified challenges can be addressed expeditiously in states OSW generation procurements;Near-term(over the next 12 years):actions
99、to ensure that holistic planning of offshore transmission networks can start at the regional grid operator level;Mid-term(over the next 23 years):actions to enable effective interregional transmission planning processes between existing grid operators;and Longer-term(over the next 35 years):actions
100、to develop the necessary grid operations,wholesale market,regulatory,and contractual frameworks,which need to be in place before networked offshore facilities are placed into service.Brief summaries of each of these recommendations are provided below,including an identification of the relevant entit
101、ies that should be involved in implementing the recommended actionsmany of which can be supported with available federal support and funding.The Benefit and Urgency of Planned Offshore Wind Transmission B|12 FIGURE ES-4:TIMELINE OF RECOMMENDATIONS IMMEDIATE ACTIONS(this year)1.Increase staffing at s
102、tate and federal regulatory agencies involved in OSW planning:Increased staffing and budgets will be necessary for state and federal regulatory agencies involved in planning for evolving OSW and other clean energy needs to enhance their capabilities to develop,evaluate,and utilize the updated regula
103、tory frameworks necessary to reliably integrate these new facilities in a timely,cost-effective manner while mitigating environmental and community impacts.Relevant entities:state governors or senior policymakers,federal policymakers 2.Create and empower multi-state decision-making entities:Multi-st
104、ate entities should be created that are authorized to facilitate planning and procuring of effective regional and interregional transmission solutions to integrate the clean energy resources,including offshore wind,needed over the 20302050 timeframe.A multi-state“transmission authority”modeled after
105、 the Regional Greenhouse Gas Initiative(RGGI)is one potential option.Governors of adjacent states should immediately begin collaborating to develop a declaration of shared goals for offshore wind transmission and interconnection,create a task force of state agencies to address those goals,and provid
106、e dedicated funding.The multi-state task force should then develop a Memorandum of Understanding(MOU)signed by state agencies with specific state goals and a framework for making decisions.This task force would start the work of implementation the recommendations below and identify The Benefit and U
107、rgency of Planned Offshore Wind Transmission B|13 what states will need from the regional grid operators,DOE,BOEM,and FERC to accomplish those goals.Relevant entities:state governors or senior policymakers and state regulatory agencies with support of grid operators,DOE,FERC,BOEM,industry stakeholde
108、rs,possibly with PMAs 3.Provide IRS guidance regarding applicability of ITC:Within the next 90 days,the Internal Revenue Service(IRS)should provide guidance to confirm the applicability of the investment tax credit(ITC)to offshore wind-related interconnection facilities owned by either generators or
109、 third parties.Relevant entities:IRS 4.Identify feasible,cost-effective POIs:In collaboration with grid operators and transmission owners,states should immediately begin efforts to proactively identify feasible,cost-effective,and future-proof points of interconnections to the existing grid.POIs shou
110、ld be planned with the necessary transmission corridors and onshore upgrades for all generation interconnection needs associated with existing state OSW and other clean energy goals within each planning region(e.g.,initiate efforts similar to New Jerseys recent offshore wind transmission procurement
111、 with PJM at full regional scale).These POIs will be needed for both the interconnection of OSW generation with radial export cables and any unbundled networked offshore transmission facilities.POIs for near-term OSW interconnection needs should be selected within a least-regrets pathway to meet lik
112、ely future OSW transmission needs.Interconnection rights to the specific POIs should be made available to state-procured OSW generation and/or unbundled offshore transmission through a fast-track(i.e.,first-ready/first-served)interconnection process.Relevant entities:states,multi-state entities,DOE,
113、grid operators,FERC 5.Develop network-ready offshore facility standards:States and grid operators should immediately develop and implement“network-ready”standards for modular offshore substations and export cables that ensure physical and functional compatibility and expandability of offshore transm
114、ission infrastructure.This will enable states to require such network-ready capabilities in all of their upcoming OSW transmission and generation procurements,so that any export links built today can to be integrated into a planned offshore network in the future.Relevant entities:DOE,states,grid ope
115、rators with input from OSW generation and transmission developers 6.Clarify and modify BOEM transmission permitting and lease-process coordination:BOEM should clarify and modify transmission permitting to add specificity to the permitting process for third-party offshore cable routes between lease a
116、reas and to the pre-specified The Benefit and Urgency of Planned Offshore Wind Transmission B|14 interconnection points on the existing grid.In addition,DOE,with BOEM,should exploreand evaluate for possible federal legislative actionmore effective alternatives to the existing auction,lease,and permi
117、tting processes to align them better with state OSW generation procurements.Relevant entities:BOEM,DOE,OSW transmission developers NEAR-TERM ACTIONS(12 years)7.Develop cost-allocation framework:States should develop an actionable cost allocation framework that covers their OSW commitments within eac
118、h region.The framework should clearly identify which costs and benefits should be considered,how they should be quantified and monetized to inform cost allocation.Without being formulaically based on quantified benefits,the costs of OSW-related transmission facilities should be allocated in a fair a
119、nd transparent way that is roughly commensurate with their benefits(e.g.,in proportion to their OSW and/or other clean-energy needs).Relevant entities:state regulatory agencies,grid operators,FERC 8.Develop HVDC-technology and operational standards:A full set of HVDC-technology and operational stand
120、ards should be developedbeyond network-ready requirements,and in coordination with similar efforts in Europe and elsewhereto ensure vendor compatibility in offshore transmission procurements and allow for a“future proof”evolution of an offshore transmission network capable of meeting long-term state
121、,regional,and interregional needs.Relevant entities:DOE,grid operators,states 9.Improve regional transmission planning and interconnection processes:Ongoing efforts to improve transmission planning processes should be continued in coordination with improving generation interconnection processes to a
122、ddress onshore and offshore renewable generation grid integration needs more proactively and from a long-term,multi-value planning perspective that considers the broad range of benefits offered by well-designed transmission networks.Relevant entities:FERC,grid operators MID-TERM ACTIONS(23 years)10.
123、Improve interregional transmission planning:It is critical to create effective interregional transmission planning processes with the requisite cost allocation agreements able to identify the needs and approve the investment necessary to capture well-documented benefits of expanded interregional tra
124、nsmissionincreased grid resilience,lower system-wide costs,taking advantage of load and resource diversity.The planning processes should The Benefit and Urgency of Planned Offshore Wind Transmission B|15 be able to identify where offshore transmission links between regions may be the most feasible a
125、nd cost-effective way to address the identified(multi-driver/multi-value)interregional needs.Relevant entities:FERC,grid operators,multi-state entities with input from market participants LONGER TERM ACTIONS(35 years)11.Develop offshore grid contracts and regulations:Before networked offshore facili
126、ties are placed in service,offshore grid contracts and regulationssuch as shared use/ownership agreements,transmission rights,open access agreements and regulations,liability and decommissioning provisions,cost allocations for shared and networked offshore facilities across multiple POIswill have to
127、 be developed to support the evolving OSW industry and enable a transition from using radial lines to meshed radial lines and(ultimately)fully networked regional and interregional grid solutions.Relevant entities:DOE,FERC,states,multi-state entities,grid operators,with input from OSW generation and
128、transmission developers 12.Develop grid operations and wholesale market design modifications:Develop recommendations for grid operations and wholesale market design modifications that allow for the regional and interregional optimization of offshore-wind-related transmission including the unique cap
129、abilities of HVDC links within and across regions.Relevant entities:DOE,FERC,grid operators,transmission owners AVAILABLE FEDERAL SUPPORT As discussed in Section V of this report,substantial technical,regulatory,and financial federal support for these initiatives is available now through collaborati
130、on with BOEM and the U.S.Department of the Interior(DOI),grid operators,DOE,FERC,and the North American Electric Reliability Corporation(NERC).Federal funding to support implementing these recommendations is available through several avenues,facilitated through DOEs Building a Better Grid Initiative
131、,which coordinates many new programs including the Transmission Facilitation Program,the Grid Resilience Utility and Industry Grants,Smart Grid Grants,and the Grid Innovation Program.Other funding sources include siting facilitation grants,energy infrastructure reinvestment program,and tax credits f
132、or certain eligible offshore wind generation property.In addition,the DOEs Wind Energy Technology Office also provides additional funding opportunities,including a recent$28 million opportunity related to addressing key wind energy deployment challenges,along with managing the federal administration
133、s Earthshot for floating offshore wind.The Benefit and Urgency of Planned Offshore Wind Transmission B|16 The remainder of this report is structured as follows:Section I outlines the urgent case for proactively and holistically planning transmission solutions.For this purpose,we identify the substan
134、tial and growing OSW goals that will need to be considered and enabled by such planning efforts,driving the urgency to begin planning efforts.Section II documents identified benefits of proactive planning and quantifies the economic,environmental,community,and reliability benefits only offered by ca
135、refully planned offshore wind transmission solutions.Section III summarizes the challenges that currently prevent effective planning,which limit the realization of these identified benefits.Section IV provides a roadmap for overcoming these barriers,and recommends specific steps that states,grid ope
136、rators,the federal administration and key federal agencies,and industry stakeholders need to take immediately and in the near term to create a pathway for no-regrets grid solutions that can achieve OSW goals in the most cost-effective and timely manner.Finally,Section V summarizes available federal
137、support for these initiatives,including through the Inflation Reduction Act(IRA),the Infrastructure Investment and Jobs Act(IIJA,which includes the new Transmission Facilitation Program),and U.S Department of Energy(DOE)appropriations.The Urgency of Starting to Plan Offshore Transmission Now _ Coord
138、inated planning for transmission to enable OSW is a key element of efficiently achieving state and national clean energy and climate policies.Without a plan and swift action toward identifying and upgrading the limited near-shore grid locations that can accept substantial volumes of OSW generation,a
139、chieving state and federal clean energy goals will be more costly,time consuming,and more disruptive to local communities and the environment.Compared to the current process of developing and interconnecting one OSW generation project at time,each with its own cables to shore,a coordinated comprehen
140、sive transmission plan could unlock numerous efficiencies and benefits unavailable under current processes.Because state and The Benefit and Urgency of Planned Offshore Wind Transmission B|17 national goals will require substantial decarbonization efforts over the next decade and beyond,it is of upm
141、ost importance to start proactive transmission planning now.Given both accelerating near-term and challenging long-term infrastructure needs,this planning effort should have been started years ago.At this point,as existing studies show,even modest further delays in starting coordinated planning effo
142、rts will lead to higher costs and greater environmental impacts.Currently available federal support and funding options make starting these planning efforts even more urgent and beneficial.A.Offshore Wind Commitments and Needs Developing transmission plans that are cost-effective in the near-term wh
143、ile creating pathways for efficiently addressing long-term goals must start with a clear understanding of both near-term OSW commitments and long-term needs.Many states and the federal government have set ambitious clean energy and decarbonization goals that will require large-scale renewable resour
144、ce additions,including substantial amounts of OSW generation.This is evidenced by the significant quantities of OSW in resource interconnection queues,the accelerating pace of OSW procurement activities,and the significant OSW development efforts internationally.1 In addition to individual state goa
145、ls,OSW generation targets include the Biden Administrations announcement of a 30 GW by 2030 goal,which includes a goal of 15 GW floating OSW by 2035,unlocking a pathway to develop 110 GW in the United States by 2050.2 The significant OSW resource pipeline demonstrates the urgency of beginning coordi
146、nated transmission planning efforts now to identify more cost-effective and lower-impact solutions for integrating these resources into the existing electricity grid.Table 1 summarizes the current procurements,state and federal policy and planning goals,and projected long-term needs to achieve decar
147、bonization goals.1 W.Musial,P.Spitsen,P.Duffy,et al.,DOE,Offshore Wind Market Report 2022,August 2022.2 The White House,FACT SHEET:Biden Administration Jumpstarts Offshore Wind Energy Projects to Create Jobs,March 29,2021;The White House,FACT SHEET:Biden-Harris Administration Announces New Actions t
148、o Expand U.S.Offshore Wind Energy,September 15,2022.The Benefit and Urgency of Planned Offshore Wind Transmission B|18 TABLE 1:OFFSHORE WIND TARGETS AND LONGTERM NEEDS Sources:See Appendix A.As this table shows,collective procurement goals of the top 11 states now exceed 75 GW by 2045.States have al
149、ready procured the first 18 GW of this OSW generation,which is projected to be in service by 2035 along the U.S.Atlantic coast from Massachusetts to Virginia.In addition to the offshore wind goals set recently by East Coast states,offshore wind goals now exist along the Pacific Coast with California
150、s recently announced planning goal of 25 GW OSW by 2045.In the Gulf of Mexico,Louisiana set the target of 5 GW OSW by 2035 in its Climate Plan.Many states with ambitious clean energy and decarbonization goals recognize that OSW will be a substantial part of achieving their long-term goals.Most state
151、s have already conducted decarbonization pathways studies that identify likely long-term OSW generation needs that substantially exceed their current OSW goals and targets.As Table 1 above shows,the total projected OSW generation needs based on studies for individual states now range from 150(GW)Yea
152、rISO-NE5842-44Massachusetts3.25.6202723Connecticut1.2220309-11Rhode Island0.41-1.420355Maine0.015NYISO4.4914-25New York4.49203514-25PJM8.418.233-58New Jersey3.811204011-26Maryland2220302Virginia2.75.2203420-30SERC87-10North Carolina82040South CarolinaMISO55Louisiana520355CAISO2525California25204525N
153、WPP24-30Washington4-10Oregon3203020State Total17.677150-197U.S.Goal/Need1102050220-460Current GoalsStateAlready Procured(GW)Projected 2050 Needs(GW)7-10The Benefit and Urgency of Planned Offshore Wind Transmission B|19 200 GW by 2050.3 Looking beyond state-specific needs,national decarbonization stu
154、dies have already projected OSW generation developments as high as 460 GW.4 As illustrated in Figure 1 below,the individual state and regional decarbonization pathways studies document substantial future generation interconnection needs for the regional grid operators along the U.S.Atlantic Coast.By
155、 2050,ISO-NE will need to interconnect over 40 GW of OSW,NYISO will need to interconnect up to 25 GW,PJM will need to interconnect up to 58 GW,and the Carolinas will need to interconnect up to 10 GW.Full decarbonization roadmap studies often indicate substantial future OSW needs for even individual
156、states,with Massachusetts most recently identifying a goal of 23 GW of OSW generation by 2050,5 New York identifying 1619 GW(possibly up to 25 GW)of OSW,6 New Jerseys 2019 Energy Master Plan envisioning up to 26 GW,7 studies for Virginia projecting up to 30 GW,8 and studies for Oregon projecting 20
157、GW of offshore wind in some 2050 scenarios.9 Similarly,state decarbonization goals likely mean that system operators on the West Coast will have to interconnect up to 55 GW of floating OSW generation by 2050.On a nationwide basis,these state-specific needs would require 150200 GW of OSW generation b
158、y 2050with a total possible nationwide need of over 400 GW based on a nationwide study scope.Most of this offshore wind energy will have to be delivered to shore and integrated with the existing gridrecognizing that some of it may be used to produce hydrogen at the offshore plants locations.3 See Ap
159、pendix A for a complete list of state clean energy transition and decarbonization pathway studies considered in Table 1.4 E.Larson,et al.,Princeton University,Net-Zero AmericaNational data,January 9,2022,at 41,Table 42.5 Massachusetts Clean Energy and Climate Plan for 2050,December 2022,at 24.See al
160、so Massachusetts 2050 Decarbonization Roadmap Study,Energy Pathways to Deep Decarbonization,December 2020,showing a projected range of 1119 GW for 2050 OSW generation.6 New York State Climate Action Council,Final Scoping Plan,Full Report,December 2022,Table 13.Note that some studies of New Yorks cle
161、an energy needs identify up to 25 GW of OSW generation requirements(see Brattle New York Electric Grid Evolution Study(),pp.32,44)7 New Jersey 2019 Energy Master Plan,Integrated Energy Plan Technical Appendix,January 2019,at 25.8 W.Shobe,et al.,Decarbonizing Virginias Economy:Pathways to 2050,Univer
162、sity of Virginia and Evolved Energy Research,January 2021,Fig.34.9 Evolved Energy Research,Renewable Northwest,GridLab,and the Energy Transition Institute,Oregon Clean Energy Pathways Final Report,June 15 and July 2,2021.The Benefit and Urgency of Planned Offshore Wind Transmission B|20 FIGURE 1:REG
163、IONAL OFFSHORE WIND PROCUREMENT TARGETS AND LONG-TERM NEEDS Available data shows that an OSW development pipeline of 52 GW exists as of December 2022.As shown in Table 2,of the 52 GW of OSW generation under various stages of development,nearly 20 GW have submitted Construction and Operation Plans(CO
164、Ps)to BOEM,and an additional 24 GW has been made available to developers by BOEM.Table 2 also reflects the updated draft Call Area of 9.9 million acres in the Gulf of Maine that BOEM published in January 2023,10 the two Wind Energy Areas(WEAs)that BOEM finalized in October 2022 in Texas and Louisian
165、a,enabling at least 8 GW of OSW development11 and the 373,000 acres BOEM sold in its December 2022 California Lease auction,which is estimated to enable over 8 GW of OSW generation.12 10 BOEM,Gulf of Maine activities.11 BOEM,BOEM Designates Two Wind Energy Areas in Gulf of Mexico,October 31,2022.(ba
166、sed on BOEMs assumption of 3 MW/km2).12 A.Buljan,offshoreWIND.biz,California Lease Sale Winners Are:RWE,Equinor,CIP,Ocean Winds,and Invenergy.Floating Wind Farm Capacities Higher than Initially Estimated,December 7,2022.(BOEM estimated a lower 4.5 GW based on 3 MW/km2).The Benefit and Urgency of Pla
167、nned Offshore Wind Transmission B|21 TABLE 2:OSW DEVELOPMENT PIPELINE AS OF DECEMBER 2022 Source:W.Musial,P.Spitsen,P.Duffy,et al.,DOE,Offshore Wind Market Report 2022,August 2022,at 8.Updated with the latest activities of BOEM in the Gulf of Mexico and California.Existing lease areas,identified win
168、d energy areas,and call areas in different regions are shown in Figure 2.BOEM is planning to continue to make available WEAs and award leases through its auction process as shown in Figure 3with additional lease auctions planned for the Gulf of Mexico,the Central Atlantic,Oregon,and the Gulf of Main
169、e before the end of 2024.13 13 The process to identify and release a new lease area to developers takes several years.For example,BOEM first initiated action in support of the California leases in August of 2016,with a published Request for Interest.BOEM then published a call for information and com
170、ment in 2018,another call in 2021,before identifying the wind energy areas in July of 2021,announcing a lease sale in May of 2022,and conducting the lease sale in December of 2022.See BOEM,Request for Interest in California OSW,August 18,2016;California Activities,History.StatusDescriptionTotal(MW)O
171、peratingThe project is fully operational with all wind turbines generating power to the grid.42Under ConstructionAll permitting processes completed.Wind turbines,substructures,and cables are in the process of being installed.Onshore upgrades are underway.932Financial CloseAll permitting processes co
172、mpleted.Begins when sponsor announces final investment decision and has signed contracts.0ApprovedBOEM and other federal agencies reviewed and approved a projects COP.The project has received all necessary state and local permits as well as acquiring an interconnection agreement to inject power to t
173、he grid.0PermittingThe developer has site control of a lease area,has submitted a COP to BOEM,and BOEM has published a Notice of Intent to prepare an Environmental Impact Statement on the projects COP.If project development occurs in state waters,permitting is initiated with relevant state agencies.
174、18,581Site ControlThe developer has acquired the right to develop a lease area and has begun surveying the lease area.24,096Unleased Wind Energy AreaThe rights to a lease area have yet to be auctioned to offshore wind energy developers.Capacity is estimated using a 3 MW/km2 wind turbine density assu
175、mption.8,290Total U.S.OSW Pipeline:51,941 The Benefit and Urgency of Planned Offshore Wind Transmission B|22 FIGURE 2:U.S.OFFSHORE WIND ENERGY AREAS AND CALL AREAS(AS OF 05/31/2022)Source:W.Musial,P.Spitsen,P.Duffy,et al.,DOE offshore wind market report 2022,August 2022,at 12,14,18(BOEM activities a
176、s of 05/31/2022).Since May 31,2022,BOEM updated the draft Call Area of 9.9 million acres in the Gulf of Maine in January 2023;finalized two WEAs in the Gulf of Mexico on October 31,2022 within the Call Area 49 in the figure above;and sold two lease areas off central and northern California on Decemb
177、er 7,2022(WEA 51 and 52).The Benefit and Urgency of Planned Offshore Wind Transmission B|23 FIGURE 3:BOEM OFFSHORE WIND LEASING SCHEDULE Source:BOEM,Offshore Wind Leasing Path Forward 20212025,October 2021.Importantly,the ability to develop OSW generation off U.S.coasts through 2050 substantially ex
178、ceeds the capability of the leases and WEAs BOEM has made available to date or is planning to make available in the near future.For example,NRELs 2022 study of Offshore Wind Energy Technical Potential found that,after excluding areas unavailable or unsuitable to OSW development,more than 4,000 GW of
179、 technical offshore wind resource potential exists off the coasts of the continental United States,as summarized in Table 3 below.TABLE 3:UNITED STATES TECHNICAL OSW RESOURCE POTENTIAL Source:NREL,Offshore Wind Energy Technical Potential for the Contiguous United States,August 15,2022,at 16.Without
180、a doubt,sufficient OSW development potential technically exists to meet currently projected state OSW generation needs of over 100 GW by 2040 and state and broader national needs of 200460 GW by 2050 as summarized in Figure 1 above.The generation output of these OSW plants developed in the Atlantic,
181、Pacific,and the Gulf of Mexicoincluding floating plants in deep-water lease areas in the Gulf of Maine and off the Pacific coastwill need to be delivered to the onshore grid and to electricity customers in the various population centers.Doing so will require many offshore cables buried in the ocean
182、floor and numerous landfall RegionTotal(GW)Fixed-Bottom(GW)Floating(GW)Share of Fixed(%)California924884%Great Lakes57516041528%Gulf1,56369686745%Mid-Atlantic32315716649%North Atlantic70626444237%Washington/Oregon21672093%South Atlantic77418858624%Continental U.S.Total4,2491,4762,77335%The Benefit a
183、nd Urgency of Planned Offshore Wind Transmission B|24 locations.It will also require points of interconnection(POIs)to the existing grid,and upgrades to the onshore grid to allow for the injection of OSW generation at these POIs and to deliver the energy from there to the various load centers.The de
184、velopment of these OSW-related transmission solutions will have to be coordinated with the existing generation interconnection and transmission planning processes of the regional transmission system operators.On the East Coast,where U.S.OSW development is most active,these system operators are ISO-N
185、E,NYISO,and PJM(which covers the coastline from New Jersey to North Carolina).B.The Urgency of Starting Proactive Planning Addressing the interconnection and transmission needs for the substantial amount of U.S.OSW generation development will be challenging.This is particularly the case for meeting
186、the large 2040 and 2050 OSW generation needs,because the transmission grid currently lacks the capability to connect these amounts of new OSW generation and deliver the generation to loads.For example,ISO-NEs 2050 transmission study shows that upgrades will be needed to address 4,500 miles of overlo
187、aded onshore transmission lines14 and several national studies,such as the“Net Zero America”study by Princeton University,project that the capability of todays transmission grid would need to be at least doubled(if not increased five-fold)of this timeframe.15 It is clear that neither the physical in
188、frastructure nor the current processes of planning and developing the necessary transmission are adequate to meet the challenges presented by the deployment of OSW resources at the already-known scale.If offshore wind and broader clean energy goals are to be achieved in a timely and cost-effective m
189、anner,it is clear that policymakers and the industry must start to reform the transmission planning process and other associated reforms now.To cost-effectively and reliably integrate the anticipated new generation and achieve OSW and decarbonization goals,it is essential and urgent to start plannin
190、g processes that can identify cost-effective and least-regrets transmission development pathways for interconnecting the significant amounts of OSW generation projected to be necessary to meet clean energy goals over the next decades.The immediate challenge is to find solutions that can cost effecti
191、vely integrate the 30 GW of OSW generation already procured or scheduled to come online over the next decade without 14 A.Kniska and R.Collins,ISO-NE,2050 Transmission Study:Preliminary N-1 and N-1-1 Thermal Results,March 15,2022,at 18.15 E.Larson,et al.,Princeton University,Net-Zero America:Potenti
192、al Pathways,Infrastructure,and ImpactsFinal Report Summary,October 29,2021,at 17.The Benefit and Urgency of Planned Offshore Wind Transmission B|25 foreclosing cost-effective pathways towards integrating at least 110 GW(and possibly more than 400 GW)by 2050.Transmission facilities for offshore wind
193、may take a decade to plan and develop.16 As a result,any planning efforts started today will not yield significant transmission infrastructure until into the 2030s.Further,because a transmission solution often must be identified significantly in advance of an offshore wind generation solicitation be
194、ing issued,the lack of a federal or multi-state transmission planning effort risks locking in the current radial tie-line approach.Integrating a large amount of additional offshore wind energy between 2030 and 2050 will need significant offshore and onshore transmission infrastructure to connect the
195、 projects to the existing grid.The ongoing delays in generation interconnection and transmission planning pose a challenge to even the OSW generators procured to meet near-term OSW goals.Any delay in acting to reform transmission and interconnection planning for OSW generation and other clean energy
196、 policy needs would only increase the challenge of timely and efficiently realizing long-term state,regional,and national clean energy and decarbonization goals.This is because todays transmission planning and interconnection processes rely on piecemeal and reactive approaches that fail to identify
197、the most cost-effective and lowest-impact transmission solutions to allow for the integration of OSW generation in both the near term but particularly the even larger amounts of OSW generation required by 2040 and 2050.This planning challenge was analyzed in the United Kingdom,where a study found th
198、at the use of proactive national transmission planning could reduce by 19%the costs to integrate an incremental 60 GW of OSW generation needed by 2050(5.5 billion or$7.4 billion in capital cost plus 1 billion saving in operational costs),reduce the miles of transmission cables installed in the ocean
199、 floor by 35%;reduce onshore transmission upgrades by 62%;and reduce the number of beach crossings by 70%.17 The study also found that an only 5-year delay of implementing such planning would reduce the benefits of doing so by half.Similarly,NYISO system planning and interconnection studies found th
200、at continued reliance on current processes will result in significant OSW curtailments and increase future upgrade costs by hundreds of millions of dollars.18 16 For example,see J.Saul,N.Malik and D.Merrill,The Clean-Power Megaproject Held Hostage by a Ranch and a Bird,Bloomberg Green,April 12,2022.
201、17 NationalGrid ESO,Offshore Coordination Phase 1 Final Report,2020,at 4,31,and 34.18 Shell,Comments of Shell Energy North America(US),L.P.and Shell New Energies,LLC Addressing Participating New England States Regional Transmission InitiativeRequest for Information,2022,at 67.The Benefit and Urgency
202、 of Planned Offshore Wind Transmission B|26 As described more fully below,many of these long-term planning benefits are reliant on beginning the process for identifying and constructing transmission far enough in advance of OSW project development to enable the necessary level of near-and long-term
203、coordination and planning of transmission solutions.Without such proactive planning,the type and locations of transmission facilities chosen built to address the interconnection of individual OSW generation projects over the next decade will necessarily impact the type and locations of transmission
204、facilities that can be built to meet 2040 and 2050 needs.If transmission technologies,corridors,and grid interconnection points used to address OSW generation interconnection over the next decade do not consider longer-term needs,achieving 2040 and 2050 goals will be more expensive and result in inc
205、reased environmental and community impacts.Any delay in starting proactive planning efforts for integrating the large amounts of OSW generation needed over the next decade and beyond will,accordingly,result in suboptimal transmission solutions with higher costs,greater risks and possible delays,and
206、higher environmental and community impacts.If states proceed with OSW procurements that rely on conventional radial interconnection facilities,opportunities to coordinate elements of needed transmission will rapidly shrink;each selected OSW project will utilize a landing point and grid interconnecti
207、on point in a way that will almost invariably be inefficient in the long term.If the development of offshore wind transmission solutions continues to be focused solely on near-term needs,it will inevitably lead to technology choices thatwhile suitable for individual projectsprevent the development o
208、f modular transmission solutions that can serve near-term needs while simultaneously creating the flexibility to expand and integrate the facilities into a more beneficial,regionally and interregionally networked offshore transmission solution over time.Thus,even as states proceed with their already
209、-scheduled procurements of OSW generation,there is an opportunity to specify modular transmission designssuch as network-ready offshore substations or higher-capacity high voltage,direct current(HVDC)designsthat create flexibility and preserve the ability to maximize the long-term value of the facil
210、ities by being able to integrate them into a networked grid over time.Unless future-proof technology standards are developed now,the continued use of incompatible technologies will make it nearly impossible to realize efficient regional and interregional grid solutions in the future.Reflecting this
211、urgency of more proactive transmission planning for OSW generation,some states have started to procure more comprehensive transmission solutions for meeting their OSW goals.For example,New Jersey has just completed a transmission-only procurement with PJM to address its entire 2035 OSW generation ne
212、eds,which yielded transmission solutions for The Benefit and Urgency of Planned Offshore Wind Transmission B|27 6,400 MW of OSW generation that reduced costs by approximately$900 million and offered significantly lower environmental and community impacts.19 New Jerseys experience demonstrates vividl
213、y that currently used generation interconnection processes are not designed to optimally utilize available POIs and existing transmission capability and yield transmission solutions that could cost-effectively meet the much broader set of future transmission needs.New England states have similarly i
214、ssued a Request for Information(RFI)to address the regions current OSW transmission needs.20 However,while a step in the right direction,the limited geographic scopes and time horizon of these OSW transmission planning efforts will not yield regional and interregional transmission solutions that can
215、 most cost-effectively address the full suite of state,regional,and national long-term OSW transmission needs.In contrast,the more holistic planning efforts now underway in the UK have already identified specific transmission projects that will enable the interconnection of 23 GW of OSW resources,wh
216、ile satisfying reliability needs,enhancing OSW availability,reducing environmental impacts by up to 30%,and resulting over 5 billion in customer benefits.21 Identifying the most attractive long-term solutions will require the development of more proactive planning processes that simultaneously consi
217、der the full set of transmission needs(i.e.,reliability,congestion relief,public policy,and generation interconnection needs)over a long-term planning horizon(i.e.,through 2040 or 2050 to consider already-known policy needs).22 Such a long-term,multi-value planning processwhich will have to be scena
218、rio based to consider long-term uncertaintieswill be able to identify least-regrets transmission solutions that(if flexibly developed)can more cost-effectively integrate OSW and other clean-energy resources over time and reduce environmental impacts compared to the currently used incremental generat
219、ion interconnection and narrowly focused transmission planning efforts.As discussed further in Section II below,where such proactive,long-term,multi-driver,scenario-based transmission planning processes are already used,they have led to planning outcomes that substantially reduce system-wide costs.I
220、n the context of OSW integration,existing proactive studies and planning efforts have shown that proactive planning will reduce the environmental and community impacts through fewer landing points,fewer cable line 19 J.P.Pfeifenberger,J.M.Hagerty,J.DeLosa III,The Brattle Group,New Jersey State Agree
221、ment Approach for Offshore Wind Transmission:Evaluation Report,October 26,2022.(BPU SAA Evaluation Report)20 See New England States Transmission Initiative.21 NationalGrid ESO,Pathway to 2030,July 2022,at 9.22 See J.Pfeifenberger,R.Gramlich,et al.,Transmission Planning for the 21st Century:Proven Pr
222、actices that Increase Value and Reduce Costs,the Brattle Group and Grid Strategies,October 13,2021;J.Pfeifenberger and J.DeLosa,Transmission Planning for a Changing Generation Mix,OPSI 2022 Annual Meeting,October 18,2022.The Benefit and Urgency of Planned Offshore Wind Transmission B|28 miles,and le
223、ss onshore land use.With fewer facilities built at a larger,more efficient scale,proactive planning will significantly reduce permitting challenges and increase the likelihood of meeting the clean energy and decarbonization goals in a timely fashion.Many OSW experts and market participants have high
224、lighted the urgency to start proactive planning for offshore wind transmission in their responses to the recent RFI of New England States on regional offshore transmission needs.23 For example:Shell explained that“the need to coordinate the interconnection of individual offshore transmission facilit
225、ies is paramount first on a regional basis and,subsequently,as a critical building block for the development of an integrated interregional transmission network.”24 Tufts University noted that“there are many benefits to thinking holistically about transmission landfalls in coordination with port inf
226、rastructure,storage,and hydrogen production.A 300 GW OSW build-out represents an approximately$1 trillion investment to be made on a very short timeframe(27 years).The U.S.has only one chance to get this right,and it is essential that we view this massive challenge with the respect it deserves.Inter
227、regional collaboration and planning with input from state,federal and RTO personnel is essential to working these issues out on a holistic level.”25 Anbaric explained that the radial only approach that was used to interconnect OSW projects at the inception of these programs is no longer viable.“Movi
228、ng to a planned approach is a prerequisite to achieving the 30,000 MW of offshore wind needed to achieve 2050 decarbonization goals in New England.”26 The American Clean Power Association(ACP)and RENEW Northeast(RENEW)highlighted the urgency of initiating planning efforts based on robust long-term g
229、oals:“Major transmission projects typically take longer to complete than generation projects,and 23 See Regional Transmission Initiative(including Connecticut,Maine,Massachusetts,New Hampshire,and Rhode Island),Notice of Request for Information and Scoping Meeting,September 1,2022;For further inform
230、ation,see the New England States Transmission InitiativeNew England Energy Vision webpage.24 Shell,Comments of Shell Energy North America(US),L.P.and Shell New Energies,LLC Addressing Participating New England States Regional Transmission InitiativeRequest for Information,2022,p.at 2(“the need to co
231、ordinate the interconnection of these facilities is paramount first on a regional basis and,subsequently,as a critical building block for the development of an integrated interregional transmission network.”)25 Tufts University,Request for Information:Regional Transmission Initiative Connecticut,Mai
232、ne,Massachusetts,New Hampshire,and Rhode Island,2022,at 9.26 Anbaric,Scaling Renewable Energy(RFI Comments),2022,at 1.The Benefit and Urgency of Planned Offshore Wind Transmission B|29 proactive development of the near-term transmission projects must start now if growth of renewable energy is to con
233、tinue.”27 Eversource stressed that:“the evolution of policy objectives dictates that the New England region could benefit from a more comprehensive,holistic and forward-looking planning process to identify,with direction from the states,transmission investments that will be needed to integrate the c
234、oming influx of renewable resources to achieve state policy goals.We need to act now on a set of targeted solutions that address existing interconnection queue backlogs,facilitate near-term clean energy procurements,improve winter reliability,position the region for electrification,and provide finan
235、cial benefit to customers via DOE funding.Eversource is concerned that transmission procurements modeled directly on prior RFPs for clean energy generation could result in siloed and chaotic transmission development that results in higher costs to customers,does not comprehensively address the regio
236、ns reliability and clean energy needs,and indeed puts meeting clean energy goals at risk.”28 The need to expeditiously address OSW transmission through more proactive planning is particularly pressing because todays generation interconnection processes,which evaluate needs only incrementally(such as
237、 one project or one group of projects at a time),have already been stretched well beyond what they have been designed for,resulting in significant delays and unnecessarily high costs of OSW interconnections.As Ocean Winds(OW)has noted in its New England RFI response:OWs collective US interconnection
238、 experience has been that the ambiguity and the long duration of existing interconnection practices have been a challenge for advancing large offshore wind projects.Given the cost,capacity,and temporal uncertainty of the interconnection process,offshore wind developers are effectively and implicitly
239、 encouraged to file multiple duplicative interconnection requests in order to de-risk their projects potentially delaying interconnection studies of later interconnection applicants.As more and more interconnection requests are filed,the self-interest of each developer will further incentivize each
240、developer to file even a higher number of interconnection requests in advance,further hindering 27 American Clean Power Association and RENEW Northeast,Comments of the American Clean Power Association and RENEW-Northeast on Changes and Upgrades to the Regional Electric Transmission System Needed to
241、Integrate Renewable Energy Resources,2022,at 6.28 Eversource,Comments of Eversource Energy Service Company on behalf of The Connecticut Light and Power Company,NSTAR Electric Company and Public Service Company of New Hampshire,at 2 emphasis original.The Benefit and Urgency of Planned Offshore Wind T
242、ransmission B|30 the speed of interconnection process for all market participants in a vicious cycle of self-interest of first movers in the interconnection queue.This unintended consequence of the existing interconnection process perpetually increases the number of grid upgrades being cost-allocate
243、d,putting an unreasonable price tag and a level of cost-uncertainty in each interconnection application.Simply limiting speculative,hence risk-mitigating,duplicative interconnection requests and“purging queues”is not the answer.Instead,there is an urgent need for proactive action:a clear policy sign
244、al to offshore wind developers that if a state-facilitated offshore wind project is awarded,the State will enable the grid upgrades needed to“beef up”the key coastal POIs that offshore wind projects will need to utilize.29 Finally,initiating planning and technology standardization efforts now is par
245、ticularly compelling since,as discussed further in Section III below,the federal government is offering technical and financial support,including tax credits for generation interconnection facilities,that can be used to address planning challenges,lower costs,and facilitate contracting for the state
246、 and nation-wide clean-energy needs,and proactively develop both regional and interregional transmission solutions.Some of this support and funding may not be available if planning efforts are delayed.States need to act quickly to secure available federal funding.For example,DOE issued a Funding Opp
247、ortunity Announcement(FOA)30 in November 2022 for the Grid Innovation Program(GIP)as part of the Bipartisan Infrastructure Law(Section 40103(b)to fund projects that aim to improve grid reliability and resilience and states are eligible to apply.Some states including Massachusetts,Connecticut,Rhode I
248、sland,and Maine have started to act and requested notices of interest and draft concept papers from developers for states to consider as part of a GIP funding application.31 29 Ocean Winds,Comments of OW North America LLC on Regional Transmission Initiative Notice of Request for Information and Scop
249、ing Meeting,October 28,2022.30 Opportunity:BIL Grid Resilience and Innovation Partnerships(GRIP)31 See the individual states notices:Massachusetts(responses due December 22,2022),Connecticut(responses due December 23,2022),Rhode Island(responses due December 28,2022),and Maine(responses due December
250、 30,2022).The Benefit and Urgency of Planned Offshore Wind Transmission B|31 The Benefits of Proactively Planned Offshore Wind Transmission The advantages of proactive regional and interregional planning are increasingly well-understood and show that proactive planning offers a wide range of benefit
251、s.These benefits include:(1)cost savings;(2)improved grid reliability and resilience;(3)environmental benefits and reduced community impacts;and(4)the employment and economic benefits of developing OSW resources in an efficient and timely fashion.Studies that document these benefits of proactive pla
252、nning are summarized below.Based on these studies,assuming at least 100 GW of additional U.S.OSW generation procurements between 2030 and 2050,the benefits of proactive planning efforts translate to around$20 billion in reduced transmission costs,6070%fewer shore crossings and onshore transmission u
253、pgrades,and up to 2,000 fewer miles of marine transmission cable trenches on the ocean floor by 2050.Many of these benefits are reduced considerably if proactive planning efforts are delayed.A.Cost Savings from Proactive Regional Planning Proactive long-term planning can reduce the total cost of a c
254、lean-energy grid by developing solutions that can more efficiently address multiple transmission needs simultaneously,instead of relying on incremental solutions to many individual needs over time.These proactive planning benefits have been demonstrated through targeted interconnection studies as we
255、ll as regional multi-value planning efforts.Benefits associated with proactive planning that includes offshore transmission are likely to increase as technology continues to develop,allowing for the integration of multiple and larger OSW generation projects into networked transmission solutions that
256、 add to regional and interregional transfer capability of the existing grid.To enable the benefits,the planning efforts must consider the transition from todays interconnection processes based on radial interconnection facilities to more cost-effective regional and interregional transmission solutio
257、ns.Several recent transmission studies document the significant cost savings that proactive planning efforts can achieve:PJMs Offshore Wind Transmission Study highlights the stark difference in generation interconnection costs if long-term interconnection needs are planned proactively.A previous OSW
258、 study showed that under the then-current interconnection process,which The Benefit and Urgency of Planned Offshore Wind Transmission B|32 relied on individual interconnection studies for each queue request,PJM identified$6.4 billion in required upgrades to the onshore grid for 15.6 GW of individual
259、 OSW plants,32 or$413 per kW of renewable generation.33 In contrast,PJMs 2021 Offshore Wind Transmission Study showed that proactively planning interconnection needs for an estimated 74.5 GW of combined onshore wind,offshore wind,and solar capacity needed to meet the current public policy goals of P
260、JM states would require only$3.2 billion of onshore system upgrades to facilities above 100kV,34 resulting in interconnection costs of only$43 per kW of renewable generation.If these study results were actually implemented by PJM,it would yield a nearly 90%reduction in the cost of major onshore upgr
261、ades(before adding the cost of lower-voltage transmission upgrades)to accommodate interconnection of the resources necessary to meet existing clean energy goals of PJM states.The recent PJM-New Jersey State Agreement Approach(SAA)experience with more proactively addressing the 6,400 MW of additional
262、 OSW generation interconnections needed to reach the states 7,500 MW OSW goal for 2035 similarly showed substantial savings compared to pursuing generation interconnection incrementally through PJMs conventional process.This proactive planning effort,conducted under PJMs never-previously used SAA,wa
263、s focused only on New Jerseys OSW interconnection needs through 2035,yet yielded substantially lower-cost solutions for the identified upgrades to the onshore grid.In response to the SAA solicitation that received 80 proposals from 13 bidders,PJM and the New Jersey Board of Public Utilities have now
264、 approved onshore transmission upgrades to nine companies that will:(1)reduce the total cost of transmission needed to add an additional 6,400 MW of OSW generation by 2035 by over$900 million;(2)significantly reduce schedule and cost uncertainties;(3)utilize the existing grid more efficiently;(4)dev
265、elop a shared collector substation with sufficient space for the HVDC converter stations of up to four OSW generators that allows for a significant reduction of transmission-related environmental and community impacts;(5)maximize the availability of approximately$2.2 billion in federal tax credits;a
266、nd(6)allow the state to more cost-effectively reach its new 11,000 MW by 2040 offshore wind goal through future 32 Business Network for Offshore Wind and Grid Strategies LLC,Offshore Wind Transmission Whitepaper,2020,at 11.33 See also J.Seel,et al.,Interconnection Cost Analysis in the PJM Territory,
267、Berkeley Lab,January 2023.Figure 5 of this study similarly shows approximately$400/kW in average cost for OSW generation in PJMs interconnection queue currentlyhigher than the interconnection costs of any other resource type and with an uncertainty range of$200/kW to over$500/kW.34 PJM,Offshore Wind
268、 Transmission Study:Phase 1 Results,2021,at 14,18.The Benefit and Urgency of Planned Offshore Wind Transmission B|33 procurements.35 While New Jersey did not select any offshore transmission through this SAA,the state issued its new draft solicitation framework for the next OSW generation procuremen
269、t with provisions that require both(a)the use of“network-ready”HVDC cables and offshore substation designs and(b)the construction of a shared onshore transmission corridor with the space for HVDC converter stations pre-built conducts and vaults that can accommodate the HVDC cables of up to four OSW
270、generators.36 The benefits of proactive planningeven if focused solely on generation interconnection needsare similarly documented in MISOs and SPPs Joint Targeted Interconnection Queue Study(JTIQ).By pooling 5-years worth of generation interconnection requests on both sides of the MISO-SPP seam,the
271、 two RTOs identified$1.6 billion in interregional transmission solutions that facilitate the integration of over 28 GW of generation interconnection at a cost of only$58 per kW of renewable resources,reducing interconnection costs by over 50%(from$117/kW under the system operators individual interco
272、nnection processes),while additionally reducing the congestion and fuel costs of MISO and SPP customers by approximately$1 billion.37 MISOs Long Range Transmission Planning(LRTP)effort is perhaps the best available example of how scenario-based long-term planning for multiple transmission needssimul
273、taneously for generation interconnection,regional reliability,congestion relief,and public policy needsoffers substantial overall cost savings to electricity customers.MISOs LRTP effort resulted in the approval of a$10 billion“least regrets”portfolio consisting of 18 multi-value transmission project
274、s in MISOs Midwestern Subregion.In addition to addressing long-term reliability needs throughout the region,the multi-value portfolio of transmission investment will reduce congestion and fuel costs,avoid capital costs of local resource and other transmission facilities,reduce resource adequacy cost
275、s and customer load shedding,while also supporting member states decarbonization policies by helping integrate low-cost wind resources in its footprint.MISO estimated that the transmission investments,which are associated with$14 billion of expenses(including operating costs)over the initial 20 year
276、s,will reduce other MISO costs by between$37 billion and$54 billion over the same timeframeproducing significant net benefits that reduce the total costs 35 See BPU SAA Evaluation Report.The SAA process identified$575 million in upgrades to the existing grid for 6,400 MW,or$90 per kW of OSW generati
277、on.This is approximately 60%less than the$1.5 billion($234/kW)cost of grid upgrades estimated based on PJMs most recent individual OSW interconnection studies.36 New Jersey Board of Public Utilities,Solicitation DocumentsNJ Offshore Wind,Attachment 10(Prebuild Infrastructure Requirements)and Attachm
278、ent 11(Offshore Transmission Network Preparation Requirements).37 Tsuchida,Proactive Planning for Generation Interconnection A Case Study of SPP and MISO,The Brattle Group,August 17,2022,at 9.The Benefit and Urgency of Planned Offshore Wind Transmission B|34 faced by MISOs customers.38 Importantly,t
279、his portfolio of transmission projects is designed to facilitate a significant shift in MISOs generation mix over the next two decades,including the retirement of about 58 GW of mainly coal-fired power plants,and the addition of about 90 GW of solar,gas,and wind generation by 2039.39 National Grids
280、U.K.OSW study analyzed the impact planning would have on the integration of 60 GW of wind generation between 2025 and 2050.The study estimated that,if planning results are implemented starting in 2025,the U.K.could reduce total transmission-related capital costs by 19%,saving approximately$7.4 billi
281、on.The estimated savings drop to half that amount if implementation of planning results is delayed by only 5 years,from 2025 until 2030.40 Anabarics New England OSW transmission study found that a planned approach based on more expensive high-capacity offshore transmission links to more distant load
282、 centers on the existing grid decreases the total combined onshore and offshore transmission costs by$0.5 billion for 3,600 MW of planned additional New England OSW procurementsan 11%reduction of total transmission-related costs.41 A study by the Lawrence Berkley National Laboratory(LBNL Study)has a
283、nalyzed differences in wholesale electricity prices over the last decade to estimate the extent to which expanding transmission capabilities within and between regions could offer significant benefits.The analysis shows that the median price differences across locations within individual regions was
284、$11/MWh in 2021.The analysis also shows that 1,000 MW of expanded transfer capabilities between coastal locations within PJM or CAISOwhich may be achievable cost-effectively through proactively planned offshore networkswould have offered benefits of$100150 million annually in each of 2021 and 2022.4
285、2 38 MISO,LRTP Tranche 1 Portfolio Detailed Business Case,June 25,2022,at 5758.39 Id.at 4.See also Utility Dive,MISO board approves$10.3B transmission plan to support 53 GW of renewables,July 26,2022.40 National Grid ESO,Offshore Coordination Phase 1 Final Report,2020,at 31.National Grids UK OSW stu
286、dy found that without proactive planning,the best POIs for connecting offshore wind to the UK electric transmission network quickly became saturated,and that additional POIs developed to supplement them were not as ideal,requiring extensive upgrades to the onshore transmission network.41 J.Pfeifenbe
287、rger,Offshore Transmission in New England:The Benefits of a Better-Planned Grid,The Brattle Group,prepared for Anbaric,May 2020,at 17.See also J.Pfeifenberger,et al.,Offshore Wind Transmission:An Analysis of Options for New York,The Brattle Group,prepared for Anbaric,August 2020,documenting a simila
288、r magnitude of savings for New York.42 LBNL,Empirical Estimates of Transmission Value Using Locational Marginal Prices,2022,at 3 and 1819.The Benefit and Urgency of Planned Offshore Wind Transmission B|35 The Massachusetts Decarbonization Pathways report found that to achieve a cost-effective region
289、al electricity system,significant transmission expansions would be necessary within New England and to neighboring regions.For example,between 1.8 GW and 2 GW of additional transfer capability would be cost effective between Maine,New Hampshire,and Massachusetts and approximately 1 GW of additional
290、transfer capability would be cost effective between Connecticut,Rhode Island,and Massachusetts in the studys regional coordination scenario.43 The study identified even larger interregional transmission needs as discussed below.As noted in RENEWs“Blueprint for New England”study,interconnection costs
291、 are currently rising rapidly for new OSW generation projects.In New England,early OSW projects interconnected at a cost of$10/kW,which has now increased to$275/kW for the most recent projects.44 Additional attempts to interconnect OSW generation through current interconnection processes will lead t
292、o further increases in OSW interconnection costs unless addressed proactively.However,when interconnection requests are addressed proactively and at sufficiently large scale,the average costs of interconnection tend to be lower.45 The studies summarized above consistently document that these signifi
293、cant increases in interconnection costs that OSW generation faces under the current interconnection processes can be mitigated through more proactive planning of generation interconnection needs,particularly when planned in conjunction with other regional and interregional transmission needs.Extrapo
294、lating from these studies,proactive planning for the interconnection of at least 100 GW of additional offshore wind generation beyond already ongoing procurements would yield at least$20 billion in transmission-related cost savingseven before considering risk mitigation,reduced environmental and com
295、munity impacts,and the broader regional and interregional benefits of a networked offshore transmission grid.46 Given that incremental offshore wind 43 R.Jones,et al.,Energy Pathways to Deep Decarbonization:A Technical Report of the Massachusetts 2050 Decarbonization Roadmap Study,Evolved Energy Res
296、earch,December,2020,Table 8,p.64.44 RENEW Northeast,Comments of the American Clean Power Association and RENEW-Northeast on Changes and Upgrades to the Regional Electric Transmission System Needed to Integrate Renewable Energy Resources,2022,at 2.45 Compare incremental interconnection costs of$413/k
297、W from previous PJM generation interconnection studies for individual OSW generators,and$275/kW anticipated in the short-term in New England,against costs of proactive planning efforts at$89/kW for Option 1a(interconnection)facilities in New Jerseys SAA(for 6.4 GW of OSW generation),MISO-SPP JTIQ at
298、$58/kW(for 28 GW of renewables),and the PJM Offshore Wind Transmission Study at$40/kW(for 75 GW of renewables,including OSW).46 For example,the New Jersey BPU evaluation of transmission alternatives estimated that in the absence of coordinated transmission procurements through the State Agreement Ap
299、proach,the total cost of onshore and offshore transmission facilities to interconnect 6,400 MW of OSW generation would be$8.9 billion(before The Benefit and Urgency of Planned Offshore Wind Transmission B|36 generation needs will likely exceed 100 GW through 2050,and could possibly reach more than 4
300、00 GW,the total savings associated with proactively planned transmission solutions will be substantial.Importantly,the planning activities conducted over the next few years will determine if the OSW generation procured for the next decade can be integrated in a timely and cost-effective manner.Becau
301、se decisions made today will have long-term consequences,they determine the extent to which 2050 OSW generation needs can be integrated cost effectively.B.Cost Savings and Resilience Value of Expanding Interregional Transmission Well-planned offshore transmission can integrate OSW generation more co
302、st effectively while also reinforcing the onshore grid,with cost and resilience benefits spread across regions.Interregional benefits include more efficient wholesale market outcomes,reduced congestion,fewer curtailments of renewable generation,reduced costs,improved reliability during challenging m
303、arket conditions,and resilience benefits during extreme conditions.These benefits are enabled through increased interregional transfer capabilitiessome of which may be made feasible and most cost-effectively provided through a well-designed offshore transmission network.In other words,since OSW gene
304、ration is expected to account for a large share of additional clean energy resources in coastal areas,expanding interregional transfer capability through networked offshore transmission facilities may be a cost-effective way to achieve these benefits.Several studies document the significant potentia
305、l cost savings and resilience value associated with expanding interregional transmission:The LBNL Study analyzed regional and interregional price differences in wholesale electricity markets.The study showed interregional price differences offered significantly more applying federal tax credits)or$6
306、.7 billion(assuming federal tax credits for generation interconnection facilities).Applying these estimates of OSW transmission costs to 100 GW of nation-wide OSW additions,this translates to$139 billion(before tax credits)and$105 billion(after tax credits)in total OSW transmission costs.A 19%reduct
307、ion of these transmission costs(as documented in the UK study summarized above)will translate to$2026 billion per 100 GW of OSW.The estimated$20+billion(or$200/kW)cost savings estimates exceed the savings realized by the smaller-scale OSW integration studies(such as the Anbaric and PJM SAA studies)b
308、ut is consistent with savings identified in larger-scale studiessuch as MISO LRTP results,which show that$10 billion in proactively planned transmission investments facilitates the integration of 90 GW of new resources,while reducing other costs between$37 billion and$54 billion over the first 20 ye
309、ars.The estimated$200/kW savings in OSW-related transmission cost is consistent with the results of PJMs 2021 study of the grid upgrade costs associated with integrating 75 GW of renewable generation(as discussed above).The Benefit and Urgency of Planned Offshore Wind Transmission B|37 opportunities
310、 for expanding transmission capabilities,including interregional transfer.For example,the median price difference between regional power markets was$24/MWh in 2021,compared to$11/MWh within regions.47 While the highest interregional price differences have historically been observed in the interior o
311、f the U.S.,average 2021 and 2022 price differences between ISO-NE,NYISO,and PJM indicate that expanding interregional transmission capacity between any two of these regions by 1,000 MW would have saved$100300 million per year in wholesale power purchases.That benefit is anticipated to grow over time
312、 as more low-cost clean energy is added to the grid.The benefits of planned interregional transmission extend beyond U.S.borders.For example,an MIT study of the Northeastern U.S.and Canada found that“adding 4 GW of transmission between New England and Canada(Quebec in particular)is estimated to lowe
313、r the costs of a zero-emission power system across New England and Quebec by 1728%.”48 The study further notes that“in a low-carbon future,it is optimal to shift the utilization of the existing hydro and transmission assets away from facilitating one-way export of electricity from Canada to the U.S.
314、and toward a two-way trading of electricity to balance intermittent U.S.wind and solar generation.Doing so reduces power system cost by 56%depending on the level of decarbonization.”49 A nationwide MIT study found that in a deeply decarbonized U.S.electricity system,an optimally expanded interregion
315、al transmission system could reduce the wholesale power price by 20%from$91/MWh to$73/MWh,when compared with a scenario without expanded interregional transmission capacity.50 The Massachusetts Decarbonization Pathways report found that to achieve a cost-effective regional electricity system,signifi
316、cant transmission expansion would be necessary between New England and its neighboring regions in addition to expanding transmission within New England.For example,for the lower-cost,coordinated scenario,the study estimates that 6 GW of additional transfer capability would be cost effective between
317、New York and PJM,that 2.3 GW of additional transmission would be cost effective between New York and New England(Connecticut and Massachusetts),and that 6.76.8 GW of additional transmission would be beneficial between Quebec and each of New York and New England(Maine,47 LBNL,Empirical Estimates of T
318、ransmission Value Using Locational Marginal Prices,2022,at 3 and 1819.48 E.Dimanchev,et al.,MIT CEEPR,Two-Way Trade in Green Electrons:Deep Decarbonization of the Northeastern U.S.and the Role of Canadian Hydropower,2020,at 1.49 Ibid.50 P.Brown,et al.,The Value of Inter-Regional Coordination and Tra
319、nsmission in Decarbonizing the US Electricity System,2021,Figure 2.The Benefit and Urgency of Planned Offshore Wind Transmission B|38 Vermont and Massachusetts).51 At least some of this additional interregional transfer capability may be provided most cost-effectively through a well-designed offshor
320、e transmission network.A recent General Electric Study for the Natural Resources Defense Council(GE-NRDC study)showed that expanding interregional transmission capability by 87 GW on various paths within the Eastern U.S.would provide$83 billion in estimated generation cost savings and avoided custom
321、er outage value.52 The GE-NRDC study specifically concluded that interregional transmission would need to be expanded between New England and New York(by approximately 2 GW),between New York and PJM(by approximately 5 GW),and between PJM and the Southeast(by approximately 8 GW)53all paths for which
322、networked offshore transmission may be the most feasible and/or cost-effective solution.The GE-NRDC study illustrated resilience benefits based on system performance during a 2035 Polar Vortex,during which increased interregional transmission capability on the East Coast would provide$1 billion in r
323、esilience value(during the single event)by preventing around 2 million customers losing power in Boston,New York City,Baltimore,and Washington,DC.The GE-NRDC study similarly analyzed a heat wave event,during which the added interregional capability provided$875 million of benefits by preventing 740,
324、000 customers from losing power in New York City and Washington,DC.54 These resilience benefits of interregional transmission have generally been broadly recognized in the industry and by its regulators.As a FERC staff report has emphasized,“the ability to share resources across regions,through use
325、of the high voltage transmission system,provides important reliability and resilience benefits when the resources in one area are impacted due to an unexpected disruptive event.”55 Although the resilience value of expanding interregional transmission is difficult to quantify with the simulation mode
326、ls commonly utilized,the LBNL Study of historical wholesale energy market price differentials separately analyzed periods of stressed system conditions,which provides a strong indication of the importance of these benefits.The LBNL Study 51 R.Jones,et al.,Energy Pathways to Deep Decarbonization:A Te
327、chnical Report of the Massachusetts 2050 Decarbonization Roadmap Study,Evolved Energy Research,December,2020,Table 8,p.64.52 S.Tandon Manz,et al.,Economic,Reliability,and Resiliency Benefits of Interregional Transmission Capacity Case Study Focusing on the Eastern United States in 2035,prepared by G
328、eneral Electric for NRDC,October 17,2022,at 26.53 Id.,Figure 15).54 Id.,at 22.55 Report on Barriers and Opportunities for High Voltage Transmission,Prepared by the Staff of the Federal Energy Regulatory Commission,at 8(June 2020),(“FERC High Voltage Transmission Report”).The Benefit and Urgency of P
329、lanned Offshore Wind Transmission B|39 documented that 40%to 80%of the energy market value of transmission links is concentrated in only 5%of all hours of a year,reflecting the most challenging system conditionsincluding storms,cold snaps,and heat wavesthat are often not considered in system simulat
330、ions.56 LBNL concluded that such spikes in transmission values“occur in different regions in different years”and that“extreme conditions in a single year,or even season,can materially increase the 10-year value of a transmission link.”57 Proactive planning efforts can determine the extent to which o
331、ffshore transmission networks offer the most feasible and cost-effective solutions to provide valuable additional interregional transmission capabilities between the regions along the nations coasts.This opportunity to utilize offshore networks to expand interregional transmission capabilities has b
332、een broadly recognized.For example,the New York Public Service Commission highlighted that offshore transmission networks may create additional benefits in terms of trading opportunities and increased reliability by making available alternative delivery routes through a neighboring system in the eve
333、nt offshore outages should affect the direct transmission links.”58 OSW generation developers have similarly noted in their New England RFI comments that“large-scale OSW project development across the Northeast presents unique opportunities to develop regional and interregional transmission infrastructure.”59 The recent GE-NRDC study further notes that the additional interregional transmission wou