February 2, 2021
Docket Nos.
 ER20-3025-000, ER20-3025-001

While I agree with the determination to reject GridLiance’s proposal because it runs contrary to the Commission’s requirements set forth in Order No. 890, I write separately to highlight that the facts of this case illustrate the need for more effective local transmission planning, including mechanisms to address barriers to participation by TDNPUs and other stakeholders in local transmission planning processes.

The electricity grid has undergone significant transformation since the issuance of Order No. 890 almost 15 years ago. Consideration of reform to local planning processes is appropriate as part of broader transmission planning reform, to ensure that TDNPUs are given fair and adequate service, and more broadly to ensure that all transmission system plans – local, regional, and interregional – succeed in identifying cost-effective solutions to established system needs and thereby ensure that any new infrastructure is money well spent by customers. Mechanisms similar to GridLiance’s proposal to empower TDNPUs to conduct their own transmission planning may be appropriately considered as part of a broader discussion on transmission planning reform.

For these reasons, I respectfully concur.

Allison Clements


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