FERC Filings
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE SCOPE OF THE RTO ENVIRONMENTAL ASSESSMENT
FOCUS OF THE NOPR ON TRANSMISSION
As this NOPR focuses on transmission, it is not likely to raise significant environmental issues, which in the electricity industry are related principally to generation. Should any transmission infrastructure changes result from this rulemaking, they are very unlikely to be sufficient to raise new or increased environmental risks or concerns. This is due to the extensive regulatory processes in place to thoroughly review transmission projects, such as FERC and/or state licensing process and the environmental permitting and review process. If new transmission lines are constructed or existing lines are rebuilt, any potential undesirable impacts on habitats, views, wetlands or other impacts would be identified and managed through these processes.
The potential environmental impacts associated with this rulemaking, therefore, would largely result from its remote and indirect effects on generation through RTOs' support of efficient markets. In fact, any such impacts would have more to do with the evolution of the industry generally than this particular rulemaking. In defining the scope of the RTO NOPR EA, it will be important for the Commission to differentiate between those impacts that flow directly from this rulemaking and those that are caused by other changes in the marketplace. Also, to the extent that any environmental impacts are expected to result from the NOPR, it is important to consider the positive effects-such as greater probability that cleaner, more efficient plants will have comparable market access and displace older plants-as equally as any negative effects.
On balance, EPSA believes that the proposed rulemaking, when considered in the broader context of the increasingly competitive marketplace, can only bring environmental benefits.