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Plan to Zero (#18) Get out of the Way III

Doug Houseman's picture
Visionary and innovator in the utility industry and grid modernization, Burns & McDonnell

I have a broad background in utilities and energy. I worked for Capgemini in the Energy Practice for more than 15 years. During that time I rose to the position of CTO of the 12,000 person...

  • Member since 2017
  • 273 items added with 104,863 views
  • Mar 31, 2023

Red tape…delays…hearings…lawsuits…studies…BANANA’s

Our world is full or regulatory and legal delays.

Interconnect permission 3-7 years.

FERC Hydropower relicensing 8-years, new permit 15 years.

NRC licensing 7 to 12 years.

State hearings on new transmission lines 2 to 13 years.

FERC approvals on new transmission line 4 to 14 years.

Many plans hinge on new transmission, new nuclear, new solar, wind and storage for 2035.

Sorry, if your application is not already in process, likely whatever you need likely will not make it when you add 2 to 5 years for equipment to be delivered.

For projects that are 2-3 Megawatts (MW) in size you can likely skip much of the permitting and permission. At that small size, you can deal directly with the distribution utility.

But to replace a 1-gigawatt (GW) coal plant you need to build over 2,000 3MW solar farms,] and roughly 6,000 3 MW by 4-hour storage projects to fully replace that coal plant 24/365.

Most distribution utilities can handle 2-10 projects a month of this size, and one per circuit of each solar and storage. You are looking at 800 months to interconnect all 8,000 sites (solar and separate storage), and you need roughly 3,000 circuits – about the number that a 3 million customer utility would have typically.

That same utility in a Polar Vortex or heat dome would need 8-17 GW of generation to supply 3 million customers.

What do we do?

Start with changing the law.

Regulatory agencies have from the day of application to a decision 18 months, if they don’t finish, it is automatically approved. Narrow the grounds for disapproval, and for lawsuits. All Federal agencies are on the exact some timeline. Environmental and other studies must be complete before applying. Missing data stops the application, but the agency has 15 business days to determine information is missing.

No notice of missing data, then the decision must be made in 18 months with the data they have in hand.

Similar laws and regulations for ISO/RTO. Model laws from DOE need to be used by the regulatory assistance projects to get them passed at the state level too, so state level reviews are done in the same 18-month time. Rejection criteria need to be technical in nature and specific.

Equipment certification needs to be on a similar timeline, apply and the agency (e.g., the NRC) has 18 months to approve or deny. In most cases the bias must be to approve, not deny.

A Federal ombudsman needs to bird dog the process, across all agencies, state, federal and local. They need to have the authority to remove barriers.

If needed ombudsman need to ability to wield eminent domain.

Jim Stack's picture
Jim Stack on Apr 4, 2023

Speeding up the approval is nerded for sure. But i would say only forxRenewable Energy projects not for nuke or other big projects. 

Doug Houseman's picture
Thank Doug for the Post!
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