A Little Ol' Transmission Fable

At a meeting of western states on the subject of renewable transmission, one state official lamented that the major obstacle to new lines, in some specific cases, was the federal government itself, with disparate agencies creating multiple hurdles. I found the comment non-intuitive. Isn’t transmission siting primarily restricted by disagreements between states on cost recovery and a NIMBY mentality? Since the comment was made in an off-the-record setting, I filed it and moved on until substantial supporting evidence emerged. Now, after reviewing an EPA letter to the Tehachapi project, I understand the state official’s comment. For certain classes of lines – those that have all necessary state-level approvals – the Federal government can act as an unintended barrier.

The Tehachapi project is designed to carry renewable energy, mostly from wind turbines, from the Tehachapi Valley to Southern California. The project has received regulatory rate approval from FERC and the CPUC. However, the latest trip-up comes from the EPA itself. Among other comments, the EPA requests that the developers maximize the use of helicopter construction in order to minimize the habitat damage caused by road construction. While the suggestion is understandable, implementation will raise costs. The EPA then goes on to say that because the South Coast Air Basin is in a non-attainment status for air pollutants, the helicopter construction should take place in fall and winter to minimize ozone formation.

In deference to the little old lady who swallowed a fly, this project thus sets up a cascade of mitigations. Build wind generation to reduce CO2 emissions. Build transmission to get the wind to reduce CO2. Use helicopters to avoid damaging the forest to build the transmission to get the wind to reduce CO2. Restrict operations to avoid emitting particulates but use helicopters to build the transmission to get the wind to reduce CO2.

The irony here is that the layers of regulations designed to protect the environment are hindering the very projects we need to minimize environmental impact. If there is any truth to the children’s tale, we need to break the cycle of circular environmental restrictions to achieve our environmental objectives. As policymakers examine how to expedite transmission construction, the federal government may be as valid a starting point as the states.