National Corridors for Transmission DOE

U.S. Department of Energy Grid Deployment Office
Initiation of Phase 2 of National Interest Electric Transmission Corridor (NIETC)
Designation Process: Preliminary List of Potential NIETCs
Issued Pursuant to Section 216(a) of the Federal Power Act
May 8, 2024
NIETC Designation Process Action

Date

Phase 2: Issuance of Preliminary List of Potential NIETCs;
Opening of Phase 2 Information Submission Window

May 8, 2024

Phase 2: Closing of Comment Period on Preliminary List of
Potential NIETCs and Phase 2 Information Submission Window

June 24, 2024

Phase 3: In-Depth NIETC Evaluation and Preparation of Draft
Designation Report(s) and NEPA Draft Environmental
Document(s), As Needed

Anticipated to begin Fall
2024

Phase 4: Final Designation Report(s) and NEPA Environmental
Document(s), As Needed

TBD

Transmission Facility Financing Action

Date

Issuance of Minimum Eligibility Criteria; Opening of Scoping
Period

May 8, 2024

Closing of Initial Outreach Period

July 31, 2024

Anticipated Opening of Formal Application and Evaluation
Process

Spring 2025

1

Table of Contents
I.

General Announcement .......................................................................................................... 3

II.

Authority ................................................................................................................................. 5

III. Preliminary List of Potential NIETCs..................................................................................... 5
A. Interpreting the Preliminary List of Potential NIETCs .................................................... 5
B. Relevant Discretionary Factors ........................................................................................ 7
C. Potential NIETCs ............................................................................................................. 8
IV. Comment Period and Phase 2 Information Submission Window......................................... 38
A. Comments on Preliminary List of Potential NIETCs..................................................... 38
B. Phase 2 Information Submissions .................................................................................. 39
C. Procedures for Comments and Information Submissions .............................................. 40
V.

Transmission Facility Financing ........................................................................................... 42

VI. More Information .................................................................................................................. 44
Appendix A: Potential NIETC Maps – New York-New England ................................................ 45
Appendix B: Potential NIETC Maps – New York-Mid-Atlantic ................................................. 48
Appendix C: Potential NIETC Maps – Mid-Atlantic-Canada ...................................................... 51
Appendix D: Potential NIETC Maps – Mid-Atlantic ................................................................... 54
Appendix E: Potential NIETC Maps – Midwest-Plains ............................................................... 57
Appendix F: Potential NIETC Maps – Northern Plains ............................................................... 60
Appendix G: Potential NIETC Maps – Delta-Plains .................................................................... 63
Appendix H: Potential NIETC Maps – Plains-Southwest ............................................................ 66
Appendix I: Potential NIETC Maps – Mountain-Plains-Southwest ............................................. 69
Appendix J: Potential NIETC Maps – Mountain-Northwest ........................................................ 72

2

I.

General Announcement

This issuance, prepared by the U.S. Department of Energy (DOE) Grid Deployment Office’s
(GDO) Transmission Division, initiates Phase 2 of the nonbinding process that DOE plans to
generally follow to designate National Interest Electric Transmission Corridors (NIETC)
pursuant to section 216(a) of the Federal Power Act (FPA), 1 as amended by the Infrastructure
Investment and Jobs Act (IIJA). 2 It also states minimum eligibility criteria for direct loans under
the Inflation Reduction Act’s Transmission Facility Financing (TFF) program and invites input
about the scope of eligible projects and associated project financing requirements. 3
In general, a NIETC is a geographic area where, based on its triennial National Transmission
Needs Study (Needs Study) 4 or other relevant information, DOE has identified present or
expected transmission capacity constraints or congestion that adversely affects consumers, and
that has been designated by the Secretary of Energy (Secretary) as a NIETC. One or more
transmission projects could be located within that geographic area to alleviate such constraints or
congestion. NIETC designation enables DOE and the Federal Energy Regulatory Commission
(FERC) to use valuable federal financing and permitting tools to spur construction of
transmission projects within a NIETC.
DOE released guidance on December 19, 2023, setting forth a NIETC designation process with
four phases (NIETC Guidance). 5 Phase 1 began with the issuance of the NIETC Guidance on
December 19, 2023, and ends with this issuance. This issuance—DOE’s first public
announcement following the close of the Phase 1 information submission window on February 2,
2024—initiates Phase 2. This issuance, hereinafter referred to as the preliminary list of potential
NIETCs, identifies which potential NIETCs DOE is continuing to consider, provides a high-level
explanation of the basis for those potential NIETCs, and opens a public comment period. During
the 45-day comment period (which includes a Phase 2 information submission window), DOE
invites interested parties to comment on the information contained within the preliminary list of
potential NIETCs and to submit additional information on geographic boundaries and potential
impacts on environmental, community, and other resources based on the list included in the
NIETC Guidance for Phase 2. DOE will prioritize which potential NIETCs from the preliminary
list move to Phase 3 based on the available information on geographic boundaries and potential

16 U.S.C. 824p.
Pub. L. No. 117-58 (Section 40105).
3
Pub. L. No. 117-169 (Section 50151); 42 U.S.C. 18715.
4
See 16 U.S.C. 824p(a)(1) (requiring DOE to conduct a triennial nationwide study of transmission capacity
constraints and congestion); DOE, National Transmission Needs Study (Oct. 2023),
https://www.energy.gov/sites/default/files/2023-12/National%20Transmission%20Needs%20Study%20%20Final_2023.12.1.pdf (2023 Needs Study).
5
DOE, Guidance on Implementing Section 216(a) of the Federal Power Act to Designate National Interest
Electric Transmission Corridors, https://www.energy.gov/sites/default/files/2023-12/2023-1215%20GDO%20NIETC%20Final%20Guidance%20Document.pdf (NIETC Guidance); see also Notice of
Availability of Guidance on Implementing the Federal Power Act to Designate National Interest Electric
Transmission Corridors, 89 FR 909 (Jan. 8, 2024).
1
2

3

impacts on environmental, community, and other resources and preliminary review of
comments. 6 Phase 3 includes robust public engagement and DOE’s preparation of draft NIETC
designation report(s) pursuant to the FPA and draft environmental document(s) pursuant to the
National Environmental Policy Act (NEPA), 7 as needed. Phase 4 is the conclusion of the NIETC
designation process with DOE’s issuance of final NIETC designation report(s) and final
environmental document(s), as needed.
Pursuant to FPA section 216(a)(2), DOE has considered the results of its 2023 Needs Study as
well as other information relating to electric transmission capacity constraints and congestion to
develop this preliminary list of potential NIETCs. DOE has also developed this preliminary list
taking into account the preliminary finding in the NIETC Guidance that NIETC designation may
be particularly valuable in geographic areas where the 2023 Needs Study identifies the need for
increased interregional transfer capacity. 8 In addition, this preliminary list was informed by
numerous information submissions and recommendations from interested parties received during
Phase 1 as well as DOE’s internal preliminary analysis of known possible environmental,
community, and other resource impacts. DOE reviewed all information submissions,
recommendations, and comments and is exercising its independent judgment regarding which
potential NIETCs to include in the preliminary list to initiate Phase 2. DOE will similarly review
all information submissions, recommendations, and comments received during Phase 2 focused
on the potential NIETCs in this preliminary list to inform its discretion as to which potential
NIETCs will proceed to Phase 3, with particular focus on additional information gathered on
geographic boundaries and potential impacts on environmental, community, and other resources.
The potential NIETCs included in the preliminary list, depicted on the map below and described
within this issuance, focus on geographic areas where present or expected transmission capacity
constraints or congestion that adversely affects consumers could be alleviated by the construction
of new or upgraded transmission lines. In most cases, the potential NIETCs included in the
preliminary list include one or more potential transmission projects in some stage of
development where a NIETC designation could help advance development of those projects. The
potential NIETCs included here each address key findings in the 2023 Needs Study, especially
with regard to the need to increase interregional transfer capacity to maintain and improve
reliability and resilience in response to events like extreme weather, to lower consumer costs,
and to help meet future generation and demand changes. In addition, the potential NIETCs would
address transmission needs identified by regional transmission planning entities in some
instances, and in all cases, reflect multiple drivers of present and expected transmission capacity
constraints and congestion.
DOE preliminarily finds that the geographic areas contained within these potential NIETCs
constitute targeted, high-priority areas where NIETC designation is likely to catalyze
NIETC Guidance at 36 (describing DOE’s technical completeness assessment and preliminary review of
public comments to determine which potential NIETCs move to Phase 3).
7
42 U.S.C. 4321, et seq.
8
NIETC Guidance at 23-30 (explaining DOE’s preliminary finding).
6

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transmission development to alleviate transmission capacity constraints or congestion and the
associated adverse effects on consumers, thereby making the most efficient and effective use of
DOE’s resources. DOE intends to employ NIETC designation in one or more of these
geographic areas to further the timely buildout of a reliable, resilient, and efficient transmission
system that facilitates the achievement of national energy policy goals while reducing consumer
energy costs.
With respect to the TFF program, under which DOE can provide direct loan support for
transmission facilities located within a NIETC, this issuance provides additional guidance in the
way of minimum eligibility criteria. DOE also invites input from transmission industry
stakeholders about the scope of eligible TFF projects and associated project financing
requirements, including information about specific projects in or near one of the potential
NIETCs in the preliminary list. DOE will use information gathered during this scoping period to
inform its formal TFF application and evaluation process, which is anticipated to open in 2025.

II.

Authority

The authorizing statute for the NIETC designation process is section 216(a) of the FPA, as
amended by the IIJA, codified at 16 U.S.C. 824p(a). 9

III.

Preliminary List of Potential NIETCs
A.

Interpreting the Preliminary List of Potential NIETCs

Below, DOE identifies which potential NIETCs it is continuing to consider in Phase 2, provides
a high-level explanation of the basis for those potential NIETCs, and opens a 45-day public
comment period (including a Phase 2 information submission window) to receive additional
public input specific to these potential NIETCs.
The explanation provided below reflects DOE’s preliminary determination that each potential
NIETC on the preliminary list, whether identified by DOE via review of the 2023 Needs Study
or via review of the information submitted by interested parties during Phase 1 of the NIETC
designation process, encompasses present or expected transmission capacity constraints or
congestion that adversely affects consumers. It is important to emphasize that this is a
preliminary step: a more in-depth evaluation of transmission capacity constraints or congestion
and adverse effects on consumers will follow for those potential NIETCs that proceed to Phase 3
after DOE’s review of information gathered during Phase 2. 10 Interested parties are encouraged
to submit comments and additional information focused on the potential NIETCs in the
preliminary list to inform DOE’s determination as to which potential NIETCs move into Phase 3.

9

For additional explanation of the statutory framework, see NIETC Guidance at 7-8.
NIETC Guidance at 36-41 (describing DOE’s activities during Phase 3 of the NIETC designation

10

process).

5

While DOE preliminarily finds that the potential NIETCs on the preliminary list are targeted,
high-priority areas for transmission development, DOE does not conclude, preliminarily or
otherwise, that areas excluded from these potential NIETCs are not. Rather, this preliminary list
is the result of DOE’s first initiation of the NIETC designation process following the 2023 Needs
Study and the development of the new four-phase designation process. It reflects DOE’s
consideration of information submissions and recommendations from interested parties received
during Phase 1 as well as internal DOE analysis. It also reflects the fact that NIETC designation,
including conducting environmental reviews, is both time- and resource-intensive, for DOE, as
well as for interested parties engaged in the process, creating a natural limit on the number of
potential NIETCs that can reasonably proceed at this time. The potential NIETCs on the
preliminary list, when considered together, offer diversity in a range of ways, including
geographical location within the United States, as well as variation in size and scope. NIETCs
identified in Phase 1 information submissions that are not included in this preliminary list of
potential NIETCs are not moving forward in this submission window, though resubmissions are
allowed in future Phase 1 information submission windows. 11
The geographic boundaries of any potential NIETC that proceeds to Phase 3 may ultimately
differ from what is presented here. The same is true for any potential NIETC that proceeds
through Phases 3 and 4 as well: the geographic boundaries may change as DOE gathers more
information and conducts more analysis. In other words, the geographic boundaries of a NIETC
are not final until DOE issues a final NIETC designation report, following completion of
environmental review. For that reason, the maps contained within this preliminary list of
potential NIETCs should be viewed as both preliminary and as rough approximations.
The geographic boundaries of potential NIETCs in this preliminary list vary in width and length
due to the nature of the locations, population centers, land status, complexity associated with
conducting meaningful on-the-ground surveys, physical and natural impacts, as well as
transmission needs, including accounting for existing infrastructure. At this time, DOE has not
conducted a full desktop analysis or a baseline assessment to confirm the presence of
environmental impacts. DOE plans to conduct such an assessment and to adjust the geographic
boundaries of each potential NIETC that proceeds to Phase 3 once additional environmental and
community impact information is gathered during Phase 2 and DOE has a better understanding
of potential implications associated with the potential NIETC designations. For example, the
geographic boundaries may be narrowed or shifted based on additional information gathered in
Phase 2 to allow for a more targeted potential NIETC, or similarly the length of the potential
NIETC may be reduced to focus on an area of greatest utility for NIETC designation. Interested
parties are encouraged to submit comments and additional information focused on the specific
geographic boundaries of potential NIETCs in the preliminary list and the resources that may be
located with those boundaries. Interested parties are also encouraged to identify potential
Note that nothing in the NIETC Guidance or this preliminary list of potential NIETCs limits or forecloses
a potential DOE decision to designate a geographic area that DOE determines meets the statutory requirements of
FPA section 216(a)(2)-(4) as a NIETC, notwithstanding the lack of a recommendation from an interested party or
departure from the four-phase process described in the Guidance. Id. at 60.
11

6

transmission projects under development in close proximity to or within these potential NIETCs
that may warrant changes to the geographic boundaries of the potential NIETCs or otherwise
factor into DOE’s assessment of which potential NIETCs proceed to Phase 3. Interested parties
will have the opportunity to submit comments and additional information on these issues for
those potential NIETCs that proceed to Phase 3 as well.
To be clear, this preliminary list of potential NIETCs, and the public comment period that
follows its issuance, does not initiate any environmental review and authorization processes,
including the environmental scoping process under NEPA. The start of these processes will be
addressed in Phase 3 once DOE determines which potential NIETCs will proceed and makes a
decision regarding the appropriate level of environmental review required. At that time, DOE
will complete a full desktop analysis or baseline assessment and prepare a Notice of Intent to
formally announce DOE’s proposed action and the narrow geographic area for potential NIETC
designation to be assessed in Phase 3, as needed based on additional information gathered to
date.

B.

Relevant Discretionary Factors

To designate a NIETC, the FPA requires that DOE find that the geographic area is experiencing
or is expected to experience transmission capacity constraints or congestion that adversely
affects consumers. 12 DOE’s high-level preliminary finding as to this aspect of NIETC
designation is explained under each potential NIETC discussed below.
While the Secretary must consider the findings of the Needs Study or other pertinent information
in designating one or more NIETCs in a designation report, FPA section 216(a)(4) allows the
Secretary to consider several additional factors in determining whether to designate a NIETC
(i.e., “discretionary factors”). DOE’s preliminary assessment of the relevance of the statutory
discretionary factors to the potential NIETCs in this preliminary list revealed that more
information is needed for a meaningful assessment. Therefore, these discretionary factors are not
discussed under each potential NIETC below. That said, the potential NIETCs in the preliminary
list share a few important characteristics that will be relevant to DOE’s consideration of the
discretionary factors moving forward.
First, every potential NIETC in the preliminary list would further one or more national energy
policy goals outlined in the NIETC Guidance, consistent with FPA section 216(a)(4)(D). 13 For
example, almost every potential NIETC would directly address the need for additional
transmission capacity to maintain reliability and bolster resilience to meet the challenges of more
frequent extreme weather and other disruptive events. 14 By targeting areas where there are
present or expected transmission capacity constraints or congestion, the potential NIETCs

16 U.S.C. 824p(a)(2).
NIETC Guidance at 11-13.
14
Id. at 11 (discussing the value of greater resource sharing across wider regions and increased
interregional and cross-interconnection transmission capacity benefits).
12
13

7

naturally focus on reducing costs for consumers, expanding access to more cost-effective
electricity supply. 15 This is not only a national energy policy goal but also a separate
discretionary factor in the statutory framework. 16 These potential NIETCs also have the ability to
unlock significant clean energy potential, including offshore wind generation, in furtherance of
the Biden-Harris Administration’s national goals to reduce U.S. greenhouse gas emissions at
least 50% below 2005 levels by 2030, including by deploying 30 GW of offshore wind energy
by 2030, and to reach net zero emissions by 2050. 17
In addition to national energy policy goals, many of the potential NIETCs in the preliminary list
would maximize the use of existing rights of way, including utility and highway rights-of-way,
and multi-function energy corridors established on federal lands under section 368 of the Energy
Policy Act of 2005, and would “avoid[] and minimize[], to the maximum extent practicable, and
offset[] to the extent appropriate and practicable, sensitive environmental areas and cultural
heritage sites.” 18 DOE intends to continue to pursue these aims as it refines the geographic
boundaries of potential NIETCs in Phases 2 and 3, recognizing that the rough approximation of
geographic boundaries included in this preliminary list for each potential NIETC is based only
on the information that is currently available for evaluation and that additional information
received in Phases 2 and 3 will help refine these boundaries.
For many of the potential NIETCs, transmission development is likely to result in improved
economic vitality and development, economic growth, diversification of supply, and streamlined
generator interconnection, and for some, enhanced energy independence, all of which are
included in the list of discretionary factors that DOE may consider as it proceeds to NIETC
designation through Phases 3 and 4 of the process. 19 More detail on the discretionary factors that
DOE finds are relevant to each potential NIETC designation will be included in the draft
designation report(s) in Phase 3. Interested parties are encouraged to submit comments and
additional information focused on the potential NIETCs in the preliminary list regarding the
relevance of discretionary factors in FPA section 216(a)(4).

C.

Potential NIETCs

Potential National Interest Electric Transmission Corridor (NIETC) areas across the United
States map that are subject to change once additional data is obtained in Phase 2.

Id. at 11-12 (discussing reduced costs for consumers).
See 16 U.S.C. 824p(a)(4)(H) (“[T]he designation would result in a reduction in the cost to purchase
electric energy for consumers.”).
17
NIETC Guidance at 12-13 (discussing clean energy goals at the national and state and local levels); see
also Fact Sheet: Biden Administration Jumpstarts Offshore Wind Energy Projects to Create Jobs (Mar. 29, 2021),
https://www.whitehouse.gov/briefing-room/statements-releases/2021/03/29/fact-sheet-biden-administrationjumpstarts-offshore-wind-energy-projects-to-create-jobs/.
18
16 U.S.C. 824p(a)(4)(G).
19
See generally 16 U.S.C. 824p(a)(4) (listing all discretionary factors that the Secretary may consider in
designating one or more NIETCs).
15
16

8

This preliminary list includes the following potential NIETCs, each of which is described below,
with an overview map illustrating the rough approximation of geographic boundaries, a brief
geographical description, and a high-level explanation of DOE’s preliminary findings of
transmission capacity constraints or congestion within the geographic area that adversely affects
consumers:
1. New York-New England
2. New York-Mid-Atlantic
3. Mid-Atlantic-Canada
4. Mid-Atlantic
5. Midwest-Plains
6. Northern Plains
7. Delta-Plains
8. Plains-Southwest
9. Mountain-Plains-Southwest
10. Mountain-Northwest

9

Geography: The New York-New England potential NIETC is an approximately 1-mile-wide,
60-mile-long east-west geographic area that includes an existing state highway transportation
corridor in eastern New York and high-voltage transmission right of way in western
Massachusetts where new transmission capacity may be co-located. It has the potential to
facilitate interregional transmission between the New York Independent System Operator, Inc.
(NYISO) and ISO New England Inc. (ISO-NE) regions.
Transmission Capacity Constraints or Congestion that Adversely Affects Consumers: The
New York-New England potential NIETC encompasses a geographic area where there is
significant need for increased interregional transfer capacity to maintain and improve reliability
and resilience, reduce congestion, meet future generation and demand growth, lower consumer
costs, and integrate more clean energy resources. These preliminary findings are based on the
2023 Needs Study as well as other relevant information and are consistent with DOE’s
preliminary finding in the NIETC Guidance regarding the particular value of NIETC designation
where there is need for increased interregional transfer capacity.
The 2023 Needs Study identifies the need to improve system reliability and resilience through
additional transfer capacity between the New York and New England regions. Needs Study
findings demonstrate the NYISO system is anticipated to become increasingly stressed during
10

winter cold snaps by mid-2030 as electrification efforts cause the system to become winterpeaking. 20 NYISO finds reliance on neighboring systems will continue to be essential over the
next decade as the New York system will not have adequate resources if not for emergency
assistance. 21 In the ISO-NE region, high levels of anticipated variable energy resource
integration are expected to pose challenges to maintaining reliability. 22 Expanding transmission
to access geographically diverse energy resources would reduce future resource adequacy risks.
Further, recent experience with extreme weather events, such as the January 2018 bomb cyclone
event in the northeastern United States, demonstrate the value additional interregional transfer
capacity would have for consumers in ensuring resilience and lowering costs by ensuring that
energy can be delivered from where it is available to where it is needed during these extreme
events. 23 The Needs Study presents findings that show regions affected by the bomb cyclone,
including New York and New England, could have saved $30-40 million for each additional
gigawatt (GW) of transmission among themselves or other regions. 24
The Needs Study also assessed historic wholesale market price differences between regions,
which signal areas of congestion on the transmission system that could be alleviated with
additional transmission capacity. According to Needs Study analysis, the highest congestion
value of interregional transmission in the Eastern Interconnection from 2012 through 2020 exists
between New York and New England, with an average marginal value of transmission ranging
from $16 to $21/megawatt-hour (MWh). 25 In fact, the congestion value of transmission between
upstate New York and western Massachusetts—the location of this potential NIETC—ranked the
highest of all interregional, non-cross-interconnection links considered in the analysis. 26
The Needs Study finds there is also a need for increased interregional transfer capacity between
New York and New England to meet future generation and demand growth under all scenarios of
future load and clean energy growth assessed in the capacity expansion modeling analysis. Under
scenarios with moderate load growth and high clean energy growth future scenarios, New York
will need an anticipated median increase of 5.2 GW of additional transfer capacity with New
England by 2035, a 255% increase relative to the 2020 system. 27 Under scenarios with high load
growth and high clean energy growth future scenarios—more in line with recently enacted state

2023 Needs Study at 89.
See NYISO, 2022 Reliability Needs Assessment, at 12 (Nov. 2022),
https://www.nyiso.com/documents/20142/2248793/2022-RNA-Report.pdf/ (2022 NYISO RNA); NYISO, 20232032 Comprehensive Reliability Plan, at 9-10 (Nov. 2023),
https://www.nyiso.com/documents/20142/2248481/2023-2032-Comprehensive-Reliability-Plan.pdf/c62634b6-cdad31dc-5238-ee7d5eaece04 (2023-2032 NYISO Comprehensive Reliability Plan).
22
2023 Needs Study at 54.
23
E.g., 2022 NYISO RNA at 91.
24
2023 Needs Study at 57.
25
Id. at v, 37-38.
26
Lawrence Berkeley National Laboratory (LBNL), Empirical Estimates of Transmission Value using
Locational Marginal Prices, at 20 (Aug. 2022), https://emp.lbl.gov/publications/empirical-estimates-transmission
(LBNL Empirical Estimates).
27
2023 Needs Study at 131–133, tbl. VI-4.
20
21

11

laws in New York and New England 28—New York will need an anticipated median increase of
17 GW of additional transfer capacity with New England by 2035, an 835% increase relative to
the 2020 system. 29
In addition to reliability and resilience benefits of resource diversification as stated above,
transmission developed in this potential NIETC would lower consumer costs by enabling the
integration of more low-cost generation resources in upstate New York. New transmission
between these low-priced regions and high-priced regions within New England would allow load
in high-priced markets to draw energy from a larger set of generators and lower their electricity
costs. 30

28
The moderate load/high clean energy growth scenario is the most likely power sector future in many
regions across the United States given recently enacted laws, including the IIJA and Inflation Reduction Act.
However, high load/high clean energy growth scenario findings are likely more appropriate to consider for regions
with enacted state laws anticipated to further increase load and clean energy growth. For example, New York’s 2019
Climate Leadership and Community Protection Act mandates 70% renewable electricity by 2030, a zero-emissions
power system by 2040, a 40% reduction in statewide greenhouse gas emissions from 1990 levels by 2030, and an
85% reduction in statewide greenhouse gas emissions from 1990 levels by 2050. See N.Y. State Senate, Senate Bill
S6599 (signed July 18, 2019), https://legislation.nysenate.gov/pdf/bills/2019/S6599. The majority of New England
states also have both renewable portfolio standards and/or clean energy standards in addition to greenhouse gas
reduction commitments. See NRRI, State Clean Energy Tracker (updated Aug. 2021),
https://pubs.naruc.org/pub/31CA2D90-1866-DAAC-99FB-F8F68F7E53DE.
29
2023 Needs Study at 131-133, tbl. VI-4.
30
Id. at 32.

12

Geography: The New York-Mid-Atlantic potential NIETC is an approximately 4-mile-wide, 12mile-long north-south geographic area that includes multiple potential points of interconnection
for new transmission capacity between New York and New Jersey, focused around the border
between New York City and northern New Jersey. It has the potential to facilitate interregional
transmission between the NYISO and PJM Interconnection, L.L.C. (PJM) regions and to
integrate offshore wind generation in the Atlantic Ocean by including multiple potential onshore
points of interconnection as well as portions of the Upper New York Bay.
Transmission Capacity Constraints or Congestion that Adversely Affects Consumers: The
New York-Mid-Atlantic potential NIETC encompasses a geographic area where there is
significant need for increased interregional transfer capacity to maintain and improve reliability
and resilience, reduce congestion, lower consumer costs, and meet future generation and demand
growth. These preliminary findings are based on the 2023 Needs Study as well as other relevant
information and are consistent with DOE’s preliminary finding in the NIETC Guidance
regarding the particular value of NIETC designation where there is need for increased
interregional transfer capacity.
The 2023 Needs Study identifies a significant present and anticipated future need for additional
interregional transfer capacity between the New York and Mid-Atlantic regions. Needs Study
13

findings demonstrate the NYISO system is anticipated to become increasingly stressed during
winter cold snaps by mid-2030 as electrification efforts cause the system to transition to winter
peaking. 31 Consequently, NYISO finds reliance on neighboring systems will continue to be
essential over the next decade as the New York system will not have adequate resources if not
for emergency assistance. 32 Such system conditions are expected to have acute impacts in the
New York City area as NYISO has identified a near-term reliability need as soon as summer
2025. 33 Impacts due to extreme weather events pose a threat to New York grid reliability,
especially in New York City, in light of NYISO’s reliability outlook. 34 Recent extreme weather
events demonstrate the value additional interregional transfer capacity would have for consumers
in maintaining and improving reliability and resilience and lowering costs by ensuring that
energy can be delivered from where it is available to where it is needed during these extreme
events. For example, the Needs Study presents findings that show regions affected by the
January 2018 bomb cyclone event in the northeastern United States, including the New York and
the Mid-Atlantic regions, could have saved $30-40 million for each additional GW of
transmission among themselves or other regions. 35 Needs Study findings also demonstrate
significant value of interregional transmission between the New York and Mid-Atlantic regions
during Winter Storm Elliott in 2022. 36
The Needs Study also assessed historic wholesale market price differences between regions,
which signal areas of congestion on the transmission system that could be alleviated with
additional transmission capacity. According to Needs Study analysis of historical wholesale
market prices, high congestion value of interregional transmission from 2012 through 2020
exists between the New York and Mid-Atlantic regions, with an average marginal value of
transmission equal to $18/MWh. 37 A high congestion value indicates that additional transmission
between the regions would reduce system congestion and constraints. Additionally, the New
York City area has experienced persistently high wholesale market prices in the last four to five
years, the longest timeframe analyzed in the Needs Study, indicating the need to deliver costeffective generation to meet demand. 38 Additional transmission to bring cost-effective resources
to demand would help reduce wholesale prices, which could ultimately reduce consumer costs.
The Needs Study finds there is also significant need for increased interregional transfer capacity
between the New York and Mid-Atlantic regions to meet future generation and demand growth
under all scenarios of future load and clean energy growth assessed in the capacity expansion
modeling analysis. Under scenarios with moderate load growth and high clean energy growth
future scenarios, New York will need an anticipated median increase of 2.4 GW of additional

Id. at 89.
See 2022 NYISO RNA at 12; 2023-2032 NYISO Comprehensive Reliability Plan at 9-10.
33
2023-2032 NYISO Comprehensive Reliability Plan at 30.
34
Id. at 48.
35
2023 Needs Study at 57.
36
Id. at 40.
37
Id. at v, 37-38.
38
Id. at 35-36.
31
32

14

transfer capacity with the Mid-Atlantic region by 2035, a 122% increase relative to the 2020
system. 39 Under scenarios with high load growth and high clean energy growth future
scenarios—more in line with recently enacted New York state laws 40—New York will need an
anticipated median increase of 8.2 GW of additional transfer capacity with the Mid-Atlantic by
2035, a 412% increase relative to the 2020 system. 41
The final Action Plan for Offshore Wind Transmission Development in the U.S. Atlantic Region,
released by DOE and the Bureau of Ocean Energy Management (BOEM) in March 2024,
recommends further exploration of interregional offshore high-voltage direct current networks
designed to maximize production cost savings while minimizing overall cable distances. 42 The
potential identified interlinks that would connect ISO-NE, NYISO, and PJM include multiple
points of interconnection that may be located within this potential NIETC. This means that
transmission within this potential NIETC may not only alleviate onshore transmission capacity
constraints or congestion between NYISO and PJM but may also facilitate onshore upgrades
needed for integration of offshore wind generation in the Atlantic Ocean.

Id. at 131-133, tbl. VI-4.
See supra n.28 (describing New York’s 2019 Climate Leadership and Community Protection Act).
41
2023 Needs Study at 131-133, tbl. VI-4. The high load and high clean energy growth scenario group
assumes high load growth in all regions of the United States. Additional interregional transfer capacity will still be
needed to support load growth in New York, though perhaps not as high, even if commensurate load growth is not
as high in the accompanying Mid-Atlantic region.
42
DOE & BOEM, An Action Plan for Offshore Wind Transmission Development in the U.S. Atlantic
Region, at 2 (Mar. 2024), https://www.energy.gov/sites/default/files/202403/Atlantic_Offshore_Wind_Transmission_Plan_Report_v15_Pre-Release.pdf; National Renewable Energy
Laboratory & Pacific Northwest National Laboratory, Atlantic Offshore Wind Transmission Study, app. E (Mar.
2024), https://www.nrel.gov/docs/fy24osti/88003.pdf (identifying candidate points of interconnection included in
the study).
39
40

15

Geography: The Mid-Atlantic-Canada potential NIETC is an approximately one-mile-wide, 42mile-long north-south geographic area from onshore in northern Pennsylvania to the
international border with Canada approximately 33 miles offshore in Lake Erie. It has the
potential to facilitate international transmission between PJM and the Independent Electricity
System Operator (IESO) system in Ontario, Canada.
Transmission Capacity Constraints or Congestion that Adversely Affects Consumers: The
Mid-Atlantic-Canada potential NIETC encompasses a geographic area that includes a potential
international connection and where there is a need to maintain and improve reliability and
resilience and facilitate delivery of clean energy resources to reduce greenhouse gas emissions.
These preliminary findings are based on the 2023 Needs Study as well as other relevant
information and are consistent with DOE’s preliminary finding in the NIETC Guidance
regarding the particular value of NIETC designation where there is need for increased
interregional transfer capacity.
The 2023 Needs Study identifies the need to improve system reliability and resilience in the
Mid-Atlantic region through increased transfer capacity with its neighbors. The Needs Study
finds reliability risks in the PJM footprint may arise in the near term through 2030 largely due to
electricity demand growth, resource retirements, and increases in intermittent and limited-

16

duration resource interconnection requests. 43 Additional transmission to increase generation
imports in the near term would help serve growing load in the face of resource retirements.
PJM’s 2024 Load Forecast Report estimates summer and winter peak load in the PJM footprint
is anticipated to increase by 1.6% and 1.9% annually, a doubling of estimates reported in its
2023 Load Forecast Report over the next decade, due to data center proliferation and
electrification efforts. 44
According to the Needs Study, stronger transmission ties with neighboring regions would also
support the resilience of the Mid-Atlantic region during extreme weather events, such as the
January 2018 bomb cyclone and 2022 Winter Storm Elliott events. The Needs Study presents
findings that show regions affected by the January 2018 bomb cyclone event in the northeastern
United States, including the Mid-Atlantic region, could have saved $30-40 million for each
additional GW of transmission among themselves or other regions. 45 Needs Study findings also
demonstrate significant value of interregional transmission between the Mid-Atlantic region and
its neighbors during Winter Storm Elliott in 2022. 46
International energy transfers between PJM and the IESO system, which currently has a
generation portfolio that is more than 90% emissions-free, 47 could also assist PJM as states and
members in its region seek pathways to reduce greenhouse gas emissions. PJM finds robust
transmission interconnection between systems can facilitate increased renewable resource
integration by accessing geographically diverse generation resources rather than relying on
clusters of renewable resources within its footprint. 48

2023 Needs Study at 61.
PJM, PJM Resource Adequacy Planning Department, PJM Load Forecast Report January 2024, at 2
(revised Feb. 1, 2024), https://www.pjm.com/-/media/library/reports-notices/load-forecast/2024-load-report.ashx
(2024 PJM Load Forecast Report); see also PJM, PJM Resource Adequacy Planning Department, PJM Load
Forecast Report January 2023, at 2 (Jan. 2023), https://wired.pjm.com/-/media/library/reports-notices/loadforecast/2023-load-report.ashx (2023 PJM Load Forecast Report).
45
2023 Needs Study at 57.
46
Id. at 40.
47
IESO, Pathways to Decarbonization, at 6 (Dec. 2022), https://www.ieso.ca//media/Files/IESO/Document-Library/gas-phase-out/Pathways-to-Decarbonization.pdf.
48
PJM, Energy Transition in PJM: Framework for Analysis, at 3 (Dec. 2021), https://www.pjm.com//media/library/reports-notices/special-reports/2021/20211215-energy-transition-in-pjm-frameworks-foranalysis.ashx.
43
44

17

Geography: The Mid-Atlantic potential NIETC includes multiple parallel sections, each
approximately two miles wide and up to 180 miles in length, including parts of West Virginia,
Pennsylvania, Maryland, and Virginia—entirely within the Mid-Atlantic region (and PJM)—east
from the Ohio River to just west of Washington, DC. It extends west to the 765 kV transmission
system in PJM, encompasses multiple interconnection points within the different sections, and
largely parallels existing 500 kV transmission facilities, attempting to avoid areas where
transmission is less likely to be built.
Transmission Capacity Constraints or Congestion that Adversely Affects Consumers: The
Mid-Atlantic potential NIETC encompasses a geographic area where there is significant need for
increased within-region transmission capacity in PJM to maintain and improve reliability and
resilience, lower consumer costs, and meet future generation and demand growth. These
preliminary findings are based on the 2023 Needs Study as well as other relevant information.
PJM’s 2022 Regional Transmission Expansion Plan (RTEP) identifies a need to both prepare for
the anticipated retirement of 11 GW of fossil-fuel generators across the PJM footprint and meet a
7.5 GW increase in load in northern Virginia, located near the end terminus of the Mid-Atlantic

18

potential NIETC. 49 PJM notes that, despite recent new substation construction in the area to
interconnect into nearby existing transmission, there continues to be a need for additional
transmission to address reliability criteria violations in the face of load growth and anticipated
resource retirements in the PJM footprint. PJM’s 2024 Load Forecast Report estimates summer
and winter peak load in the PJM footprint is anticipated to increase by 1.6% and 1.9% annually,
respectively, over the next decade, a doubling of estimates reported in its 2023 Load Forecast
Report, due to data center proliferation and electrification efforts. 50 PJM finds the Dominion
Energy zone in northern Virginia to be driving much of this increase in anticipated peak load as
summer and winter peak load is anticipated to increase by 5.5% and 5% annually, respectively,
within that particular zone over the next decade. 51
Similarly, the 2023 Needs Study identifies the need to improve system reliability and resilience
in the Mid-Atlantic region with additional within-region transmission. The Needs Study finds
reliability risks in the PJM footprint may arise in the near term through 2030 largely due to
electricity demand growth, resource retirements, and increases in intermittent and limitedduration resource interconnection requests. 52 Additional transmission and upgrades to existing
transmission in the near term would help maintain resource adequacy. Needs Study findings also
demonstrate the significant value of within-region transmission in the Mid-Atlantic region during
recent extreme weather events, including Winter Storm Elliott in 2022. Needs Study findings
demonstrate that during the event, multiple transmission constraints within PJM limited PJM’s
ability to support export transactions across its southern interfaces. 53
Needs Study findings also demonstrate the need to provide access to cost-effective generation
resources to meet demand in the Mid-Atlantic region. Specifically, findings show eastern
Maryland and Virginia—at the eastern terminus of the potential NIETC—have experienced
persistently high wholesale market prices in recent years. 54 Additional transmission to bring
cost-effective resources to demand would help reduce these wholesale prices, ultimately
lowering congestion and reducing costs for consumers.
The Needs Study finds there is a moderate need for increased within-region transmission in the
Mid-Atlantic to meet future generation and demand growth under certain scenarios of future load
and clean energy growth assessed in the capacity expansion modeling analysis. Under scenarios
with moderate load growth and high clean energy growth future scenarios, the Mid-Atlantic
region will need an anticipated median increase of 3.3 GW of additional within-region
transmission by 2035, a 23% increase relative to the 2020 system. 55

PJM, PJM’s Role in Regional Planning/2022 RTEP Window 3 (Nov. 2023), https://www.pjm.com//media/committees-groups/committees/teac/2023/20231205/20231205-pjms-role-in-regional-planning-2022-rtepwindow-3.ashx; PJM, 2022 Regional Transmission Expansion Plan, at 222 (Mar. 2022), https://www.pjm.com//media/library/reports-notices/2022-rtep/2022-rtep-report.ashx.
50
See 2024 PJM Load Forecast Report at 2; 2023 PJM Load Forecast Report at 2.
51
2024 PJM Load Forecast Report at 35, 39.
52
2023 Needs Study at 61.
53
Id. at 58.
54
Id. at 35-36.
55
Id. at 123-124, tbl. VI-3.
49

19

Geography: The Midwest-Plains potential NIETC is an approximately 5-mile-wide, 780-milelong east-west geographic area that includes parts of Kansas, Missouri, Illinois, and Indiana, and
portions of an existing 345 kV transmission facility. It has the potential to facilitate interregional
transmission between PJM, the Midcontinent Independent System Operator, Inc. (MISO), and
the Southwest Power Pool (SPP) regions.
Transmission Capacity Constraints or Congestion that Adversely Affects Consumers: The
Midwest-Plains potential NIETC encompasses a geographic area where there is a significant
need for increased interregional transfer capacity to maintain and improve reliability and
resilience, lower congestion and consumer costs, meet future generation and demand growth, and
increase clean energy integration. These preliminary findings are based on the 2023 Needs Study
as well as other relevant information and are consistent with DOE’s preliminary finding in the
NIETC Guidance regarding the particular value of NIETC designation where there is need for
increased interregional transfer capacity.
As discussed in the Needs Study, generator retirements in the Midwest region are anticipated to
result in near-term capacity shortfalls in the absence of additional generation or import transfer

20

capacity additions. 56 The North American Electric Reliability Corporation (NERC) anticipates
MISO will experience an estimated 4.7 GW capacity shortfall. 57 As a result, NERC has
categorized the MISO region as a “high risk area” vulnerable to extreme temperatures and
prolonged severe weather events. 58 Similarly, Need Study findings demonstrate reliability risks
in the PJM footprint for the near term through 2030 largely due to electricity demand growth,
resource retirements, and increases in intermittent and limited-duration resource interconnection
requests. 59 Additional transmission to increase generation imports to the PJM footprint in the
near term would serve growing load in the face of resource retirements.
Further, recent experience with extreme weather events, such as Winter Storms Uri and Elliott,
demonstrate the value additional interregional transfer capacity would have for consumers in
ensuring reliability and resilience and lowering costs by ensuring that energy can be delivered
from where it is available to where it is needed during these extreme events. During Winter
Storm Uri in February 2021, Needs Study findings show the Plains region was unable to import
additional available generation capacity during the cold weather event, which negatively
impacted resource adequacy and introduced high price spikes. 60 Needs Study findings also
demonstrate significant value of interregional transmission between the Plains and Midwest
regions, as well as between the Mid-Atlantic and its neighbors, during Winter Storm Elliott in
2022. 61 Increased transfer capacities between the Plains, Midwest, and Mid-Atlantic regions
would improve system reliability during extreme weather events.
Needs Study findings also demonstrate the need to alleviate transfer capacity limits between the
Plains and Midwest regions. According to Needs Study analysis of historical wholesale market
prices, high congestion values of transmission from 2015 through 2020 exist between the
Midwest and Plains regions, ranging from $4/MWh to $15/MWh on average. 62 These high
congestion values have been increasing year after year since 2015. 63 A high congestion value
indicates that additional transmission between the regions would reduce system congestion and
constraints.
Needs Study findings also demonstrate the need to bring cost-effective resources to demand in
the Midwest region, particularly low-cost wind resources in the southern Plains region near the
Oklahoma and Kansas border. 64 High congestion at flowgates in Missouri, Kansas, and
Oklahoma, however, constrain the power flows into higher-priced areas in the Midwest as

Id. at 56, 61.
NERC, 2023 Long-Term Reliability Assessment, at 7 (Dec. 2023),
https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_LTRA_2023.pdf (2023 NERC
LTRA).
58
Id.
59
2023 Needs Study at 61.
60
Id. at 39, 56-57
61
Id. at 40.
62
Id. at v, 37-38.
63
LBNL Empirical Estimates at 22.
64
2023 Needs Study at 70-71.
56
57

21

indicated by significant increases in market-to-market payments (M2M) from SPP to MISO. 65
As MISO’s wind penetration continues to increase, SPP’s M2M flowgates will continue to be
affected and potentially lead to an increase in the M2M payments from MISO. Increased
interregional transfer capacity between the Plains and Midwest regions would help alleviate
congestion and facilitate delivery of lower cost resources into the Midwest.
The Needs Study finds there is also significant need for increased interregional transfer capacity
between the Plains and Midwest regions to meet future generation and demand growth under all
scenarios of future load and clean energy growth assessed in the capacity expansion modeling
analysis. Under scenarios with moderate load growth and high clean energy growth future
scenarios, the Plains region will need an anticipated median increase of 21 GW of additional
transfer capacity with the Midwest region by 2035, a 175% increase relative to the 2020
system. 66

65
66

Id.
Id. at 131-133, tbl. VI-4.

22

Geography: The Northern Plains potential NIETC is comprised of multiple sections, each from
10 to 50 miles wide and up to 400 miles from north to south and 300 miles from east to west,
located in parts of North Dakota, South Dakota, and Nebraska. This potential NIETC includes
land of several Tribal Nations and incorporates multiple interconnecting elements with SPP. The
sections narrowly focus on existing 115/230 kV infrastructure that needs upgrades to address the
lack of extra high-voltage transmission in this area at the western edge of SPP and the Eastern
Interconnection while avoiding large areas where transmission is less likely to be built.
Transmission Capacity Constraints or Congestion that Adversely Affects Consumers: The
Northern Plains potential NIETC encompasses a geographic area where there is significant need
for new transmission, especially extra high-voltage transmission, to relieve system congestion,
lower consumer costs, meet future generation and demand growth, increase clean energy
integration, and improve energy justice among Tribal communities. These preliminary findings
are based on the 2023 Needs Study as well as other relevant information.
The 2023 Needs Study identifies a significant present and anticipated future need for additional
transmission within the Plains region. Findings demonstrate the need to deliver cost-effective
generation to meet demand in the Plains region as indicated by low wholesale electricity prices

23

in the northern region and high prices to the south. 67 These price differences show that the Plains
region requires additional transmission capacity to alleviate transfer capacity limits between the
north and south. 68 According to the Need Study’s analysis of historical wholesale market prices,
high congestion value of transmission exists between the northern and southern Plains region
from 2015 through 2020, with an average marginal value between the two areas equal to
$11/MWh. 69 These high congestion values have been increasing year after year since 2015. 70 A
high congestion value indicates that additional transmission between the areas would reduce
system congestion and constraints and reduce costs to consumers.
A large driver of this need in the Plains region is the lack of existing extra high-voltage
transmission (345 kV and above) at the western edge of SPP to bring an abundance of low-cost
energy resources in the potential NIETC area to meet demand. However, as referenced in the
Needs Study, transmission development to bring generation in location-constrained areas with
limited existing transmission infrastructure to demand may cause developers with projects to
incur significant network upgrade costs to interconnect with the bulk power system. 71 This
dynamic disproportionately impacts Indian Tribes in the area, which have expressed a significant
need and interest in developing their own energy resources, implementing energy efficiency and
renewable energy technologies, stabilizing energy costs, and spurring local economic
development. 72 Further, transmission development within the region is likely to enhance system
reliability on Tribal lands. DOE Office of Indian Energy survey findings show that over 54,000
American Indian and Alaska Native peoples across the United States do not have access to
electricity today, and among those that do have access to electricity, respondents
overwhelmingly (92%) reported regular electricity outages, often because of inadequate
infrastructure or because they are serviced by a single power line that lacks redundancy. 73
The Needs Study finds there is also significant need for increased within-region transmission in
the Plains region to meet future generation and demand growth under all scenarios of future load
and clean energy growth assessed in the capacity expansion modeling analysis. Under scenarios
with moderate load growth and high clean energy growth future scenarios, the Plains region will
need an anticipated median increase of 8.3 GW of additional within-region transmission by
2035, a 119% increase relative to the 2020 system. 74

Id. at 32-33.
Id. at 32-33, 77.
69
Id. at v, 37-38.
70
LBNL Empirical Estimates at 22.
71
2023 Needs Study at 48-49.
72
Id. at 84-88.
73
Id. at 84-85.
74
Id. at 131-133, tbl. VI-4.
67
68

24

Geography: The Delta-Plains potential NIETC is an approximately 645-mile-long geographic
area, ranging in width from 4–18 miles, crossing Oklahoma from its western to eastern border,
with a fork near Tulsa, and continuing into Arkansas, where it forks in a north-south direction. It
encompasses multiple interconnection points as well as existing transmission facilities. It has the
potential to facilitate interregional transmission capacity between SPP and the southern portion
of the MISO region, as well as potential cross-interconnection transmission at the western end
between the Eastern and Western Interconnections.
Transmission Capacity Constraints or Congestion that Adversely Affects Consumers: The
Delta-Plains potential NIETC encompasses a geographic area where there is significant need for
increased interregional transfer capacity to maintain and improve reliability and resilience,
relieve congestion, meet future generation and demand growth, and increase clean energy
integration. This potential NIETC may also increase transfer capacity between the Eastern and
Western Interconnections, pending deployment of back-to-back ties. These preliminary findings
are based on the 2023 Needs Study as well as other relevant information and are consistent with
DOE’s preliminary finding in the NIETC Guidance regarding the particular value of NIETC
designation where there is need for increased interregional transfer capacity.

25

As discussed in the Needs Study, generator retirements in the Delta region are anticipated to
result in near-term capacity shortfalls in the absence of additional generation or import transfer
capacity additions. 75 NERC anticipates MISO will experience an estimated 4.7 GW capacity
shortfall due to generation retirements. 76 As a result, NERC has categorized the MISO region as
a “high-risk area” vulnerable to extreme temperatures and prolonged severe weather events. 77
NERC states extreme cold, particularly in the MISO South region (which corresponds to the
Delta region in the Needs Study), increases load in the region and increases associated loss of
load risk. 78
Recent experience with extreme weather events demonstrates the value additional interregional
transfer capacity would have for consumers in maintaining and improving reliability and
resilience and lowering costs by ensuring that energy can be delivered from where it is available
to where it is needed during these extreme events. During Winter Storm Uri in February 2021,
Needs Study findings show that the Plains region was unable to import additional available
generation capacity during the cold weather event, which negatively impacted resource adequacy
and introduced high price spikes. 79 Needs Study findings also demonstrate significant value of
interregional transmission between the Plains and Delta regions during Winter Storm Elliott in
2022. 80 Similarly, Hurricanes Ida and Laura exposed further weaknesses in the Delta region’s
connectivity, especially in certain transmission constrained areas, some of which experienced
load shedding. 81 Increased transfer capacities between the Plains and Delta regions would
improve system reliability during extreme weather events.
Needs Study findings also demonstrate the need to alleviate transfer capacity limits between the
Plains and Delta regions. According to Needs Study analysis of historical wholesale market
prices, high congestion value of transmission from 2012 through 2020 exists between the Plains
and Delta regions, with an average marginal value of transmission equal to $13/MWh. 82 These
high congestion values have been increasing year after year since 2015. 83 A high congestion
value indicates that additional transmission between the regions would reduce system congestion
and constraints and lower costs for consumers. 84 Needs Study findings show this is largely due to
insufficient transmission to support low-cost wind resource delivery from the Plains region near
the Oklahoma and Kansas border into the combined Midwest and Delta region to the east. High
congestion at flowgates in Missouri, Kansas, and Oklahoma demonstrate the persistence of

Id. at 56, 61.
2023 NERC LTRA at 7.
77
Id.
78
Id. at 41.
79
2023 Needs Study at 39, 56-57
80
Id. at 40.
81
Id. at 57-58.
82
Id. at v, 37-38.
83
LBNL Empirical Estimates at 22.
84
2023 Needs Study at 70-71.
75
76

26

constrained power flows into the Delta region. 85 Increased interregional transfer capacity
between them would help alleviate congestion and constraints.
Transmission buildout to support additional west-to-east transfers within the SPP footprint would
also likely reduce persistent congestion in southeastern SPP. As described in SPP’s 2022 Annual
State of the Market Report, there has been a historical lack of high-voltage transmission between
western and eastern SPP, and while transmission buildout has allowed higher levels of low-cost
wind generation to flow from southwestern SPP to load centers to the east, high levels of
congestion remain at the southeastern edge of the region extending from northern Missouri to
southern Oklahoma. 86 In Oklahoma, SPP finds persistently high levels of congestion in areas
around Tulsa, Oklahoma City, and southeast Oklahoma. 87 In fact, SPP notes prices in southeast
Oklahoma were some of the highest in SPP in 2022 with an average real-time price of
$98/MWh. 88
The Needs Study finds there is also significant need for increased interregional transfer capacity
between the Plains and Delta regions to meet future generation and demand growth under certain
scenarios of future load and clean energy growth assessed in the capacity expansion modeling
analysis. Under future scenarios with moderate load growth and high clean energy growth, the
Plains region will need an anticipated median increase of 20 GW of additional transfer capacity
with the Delta region by 2035, a 414% increase relative to the 2020 system. 89
The Delta-Plains potential NIETC, while interregional, may have cross-interconnection
implications due to its western terminus at the Eastern–Western Interconnection seam. As
discussed in the Needs Study, the U.S. grid is anticipated to require a sizeable increase of
transmission expansion across the interconnection seam to improve system reliability and
resilience. 90 Transmission expansion across the interconnections can serve to diversify load and
generation across large geographic areas, which increases system operating flexibility. 91 The
Needs Study finds there is significant need for increased interregional transfer capacity across
the interconnection seam between the Southwest and Plains regions to meet future generation
and demand growth under all scenarios of future load and clean energy growth assessed in the
capacity expansion modeling analysis. Under future scenarios with moderate load growth and
high clean energy growth, the Southwest region will need an anticipated median increase of 3.7
GW of additional transfer capacity with the Plains region by 2035, a 914% increase relative to
the 2020 system. 92

Id.
SPP Market Monitoring Unit, State of the Market 2022, at 180 (May 2023)
https://www.spp.org/documents/69330/2022%20annual%20state%20of%20the%20market%20report.pdf.
87
Id. at 182.
88
Id. at 180.
89
2023 Needs Study at 131-133, tbl. VI-4.
90
Id. at 62-63.
91
Id.
92
Id. at 131-133, tbl. VI-4.
85
86

27

Geography: The Plains-Southwest potential NIETC is an approximately 345-mile-long from
east to west and 220-mile-long from north to south geographic area of significantly varying
width (from less than five miles to near 100 miles). The Plains-Southwest potential NIETC
crosses the Eastern–Western Interconnection seam, including portions of New Mexico, Texas,
Oklahoma, and Kansas. It has the potential to facilitate interregional (and cross-interconnection)
transmission between the WestConnect, SPP, MISO, and PJM regions (and even to the
California Independent System Operator, Inc. (CAISO) via existing or planned transmission
projects under development to the west).
Transmission Capacity Constraints or Congestion that Adversely Affects Consumers: The
Plains-Southwest potential NIETC encompasses a geographic area where there is significant
need for increased interregional transfer capacity to maintain and improve reliability and
resilience, meet future generation and demand growth, and increase clean energy integration.
This potential NIETC may also increase transfer capacity between the Electric Reliability
Council of Texas (ERCOT) and both the Eastern and Western Interconnections, pending
deployment of back-to-back ties between ERCOT and the other interconnections. These
preliminary findings are based on the 2023 Needs Study as well as other relevant information
and are consistent with DOE’s preliminary finding in the NIETC Guidance regarding the

28

particular value of NIETC designation where there is need for increased interregional transfer
capacity.
The 2023 Needs Study identifies a significant present and anticipated future need for additional
cross-interconnection transfer capacity between the Southwest and Plains regions. Recent
experience with extreme weather events, such as Winter Storm Uri, demonstrate the value
additional interregional transfer capacity would have for consumers in ensuring resilience and
lowering costs by ensuring that energy can be delivered from where it is available to where it is
needed during these extreme events. During Winter Storm Uri in February 2021, Needs Study
findings show the Plains region was unable to import additional available generation capacity
during the cold weather event, which negatively impacted resource adequacy and introduced
high price spikes. 93 Similarly, NERC’s 2023 Long-Term Reliability Assessment finds
anticipated generation retirements and increasing demand in both the SPP and Western
Electricity Coordinating Council (WECC)-Southwest regions are expected to reduce reserve
margins, putting both regions at risk of resource shortfalls during extreme weather events. 94 Due
to these anticipated system conditions, NERC has categorized both regions as “elevated risk
areas.” 95 Transmission expansion across the interconnections can serve to diversify load and
generation across large geographic areas, which increases system operating flexibility. 96
Increased transfer capacities between the Plains and Southwest regions would improve system
resilience during extreme weather events.
SPP’s 2021 Integrated Transmission Planning (ITP) assessment identified the Southwestern
Public Service (SPS) south region as a target area requiring additional transmission development
to resolve reliability needs driven by load growth, generation retirements, and limited
transmission connections with the SPP generation fleet. 97 SPP identifies three interfaces in
southeastern New Mexico and the Texas and Oklahoma Panhandle area, which are anticipated to
experience overloads as power flows into the SPS system to displace generation retirements and
meet load growth. SPP further states the SPS south zone has been an area of focus for the last
decade and concludes “[w]ithout a forward-thinking, proactive approach to transmission
solutions in this area, SPP can expect to continually observe incremental needs with reactive
solution proposals,” which “provide limited short-term relief to system needs where continued
growth is expected to occur.” 98 Indeed, SPP has continued to identify incremental reliability
needs in this area in subsequent ITP assessments released in 2022 and 2023, and SPS’s 2023
Integrated Resource Plan (IRP) finds significant levels of projected load growth in the area will
require additional transmission facilities and/or local generation to address future reliability

Id. at 39, 56-57
2023 NERC LTRA at 7-9.
95
Id.
96
Id.
97
SPP, 2021 Integrated Transmission Planning Assessment Report & Addendum, at 1 (Dec. 2022),
https://www.spp.org/documents/66812/2021%20itp%20report%20&%20addendum%20v2.0.pdf (2021 SPP ITP
Assessment Report).
98
Id. at 106.
93
94

29

concerns. 99 The Plains-Southwest potential NIETC can facilitate increased power transfers
between the two regions, which can simultaneously contribute to addressing future SPS-related
reliability concerns while also reducing reliance on other existing, constrained pathways from the
Mountain to Southwest regions, such as Qualified Path 31 located across the Colorado-New
Mexico border. 100
The Needs Study also assessed historic wholesale market price differences between regions,
which signal areas of congestion on the transmission system that could be alleviated with
additional transmission capacity. This analysis, which considers data from 2012 to 2020, finds
that the highest congestion value of transmission anywhere in the country is between the
interconnections. 101 Cross-interconnection congestion value between the Plains and its neighbors
has been increasing year after year since 2015. 102 Notably, wholesale market price differentials
between the Southwest and Plains regions was not assessed in the Needs Study, but it is expected
that congestion trends between these two regions would be similar to congestion values found
between the Eastern and Western Interconnections.
As discussed in the Needs Study, the U.S. grid is anticipated to require a sizeable increase of
transmission expansion across the Eastern and Western Interconnection seam to improve system
reliability and resilience. 103 Specifically, the Needs Study finds there is a significant need for
increased interregional transfer capacity between Southwest and Plains regions to meet future
generation and demand growth under all scenarios of future load and clean energy growth
assessed in the capacity expansion modeling analysis. Under future scenarios with moderate load
growth and high clean energy growth, the Southwest region will need an anticipated median
increase of 3.7 GW of additional transfer capacity with the Plains region by 2035, a 914%
increase relative to the 2020 system. 104
The Plains-Southwest potential NIETC has additional cross-interconnection implications
between ERCOT and both the Eastern and Western Interconnections should additional back-to-

See SPP 2022 Integrated Transmission Planning Assessment Report, at 19 (Dec. 2022),
https://www.spp.org/documents/68410/2022%20itp%20report%20v1.pdf (2022 SPP ITP Assessment Report); see
also SPP, 2023 Integrated Transmission Planning Assessment Report, at 63 (Nov. 2023),
https://www.spp.org/documents/70584/2023%20itp%20assessment%20report%20v1.0.pdf (2023 SPP ITP
Assessment Report); Southwestern Public Service Company, 2023 New Mexico Integrated Resource Plan, at 40-41
(Oct. 2023), https://www.xcelenergy.com/staticfiles/xeresponsive/Company/Rates%20&%20Regulations/Resource%20Plans/2023%20SPS-IRP%20Plan.pdf (2023 SPS
NM IRP).
100
Note: Qualified Paths in the West designate transmission with the highest levels of congestion. See 2023
Needs Study at 42-44; see also WECC, 2023 Path Rating Catalog, at 32 (2023),
https://www.wecc.org/Reliability/2023%20Path%20Rating%20Catalog%20Public.pdf (2023 WECC Path Rating
Catalog).
101
2023 Needs Study at v, 37-38; see also LBNL Empirical Estimates at 20.
102
LBNL Empirical Estimates at 22.
103
2023 Needs Study at 62-63.
104
Id. at 131-133, tbl. VI-4.
99

30

back ties be constructed within the potential NIETC. 105 Interconnection with ERCOT would
include additional benefits such as improving resilience, relieving congestion, and meeting future
demand growth. The Needs Study presents NERC and FERC findings that demonstrate limited
interconnections between ERCOT and neighboring systems significantly affected its ability to
make up for the capacity shortage experienced during Winter Storm Uri. 106 Improving transfer
capability via increased ties with neighboring regions would increase ERCOT’s ability to import
power to address capacity shortages when its system is stressed under emergency conditions.
Needs Study analysis of wholesale electricity prices also finds the highest congestion values of
interregional transmission from 2012 through 2020 across the entire United States exists between
ERCOT and the Plains region, ranging from $15/MWh to $69/MWh. 107 Similarly high
congestion values of transmission exist between ERCOT and the Southwest region
($25/MWh). 108
Further, the Needs Study demonstrates there is significant need for increased crossinterconnection and interregional transfer capacity between ERCOT and the Plains region to
meet future generation and demand growth under all scenarios of future load and clean energy
growth assessed in the capacity expansion modeling analysis. Under future scenarios with
moderate load growth and high clean energy growth, ERCOT will need an anticipated median
increase of 9.8 GW of additional transfer capacity with the Plains region by 2035, a 1,200%
increase relative to the 2020 system. 109

See ERCOT, Area by County (last visited Mar. 26, 2024),
https://www.ercot.com/files/assets/2022/12/13/ERCOT-Maps_Area-by-county.jpg.
106
2023 Needs Study at 56-57.
107
Id. at v, 37-38. Geographic region boundaries defined in the 2023 Needs Study generally align with the
relevant reliability entity and transmission planning entity boundaries wherever possible. The Texas region, as
defined in the Needs Study, aligns with the ERCOT and Texas reliability entity footprints. When referring to “Texas
region”-specific Needs Study findings in this document, however, DOE refers to “ERCOT” rather than the “Texas
region” to provide greater specificity given the narrower focus of potential NIETC geographic areas.
108
Id.
109
Id. at 131-133, tbl. VI-4.
105

31

Geography: The Mountain-Plains-Southwest potential NIETC is an approximately 20- to 100mile-wide, 540-mile-long north-south geographic area from Colorado into New Mexico along
the border with Oklahoma and then Texas. It includes multiple substations and existing
transmission facilities to make a link between the Eastern and Western Interconnections possible
at several locations. It has the potential to facilitate interregional transmission between
WestConnect and SPP, and cross-interconnection transmission as well.
Transmission Capacity Constraints or Congestion that Adversely Affects Consumers: The
Mountain-Plains-Southwest potential NIETC encompasses a geographic area where there is
significant need for increased cross-interconnection and interregional transfer capacity to
maintain and improve reliability and resilience, alleviate congestion, meet future generation and
demand growth, and increase clean energy integration. This potential NIETC may also increase
transfer capacity between ERCOT and both the Eastern and Western Interconnections, pending
deployment of back-to-back ties between ERCOT and the other interconnections. These
preliminary findings are based on the 2023 Needs Study as well as other relevant information
and are consistent with DOE’s preliminary finding in the NIETC Guidance regarding the
particular value of NIETC designation where there is need for increased interregional transfer
capacity.

32

Recent experience with extreme weather events, such as Winter Storm Uri, demonstrate the
value additional interregional transfer capacity would have for consumers in ensuring reliability
and resilience and lowering costs by ensuring that energy can be delivered from where it is
available to where it is needed during these extreme events. During Winter Storm Uri in
February 2021, Needs Study findings show the Plains region was unable to import additional
available generation capacity during the cold weather event, which negatively impacted resource
adequacy and introduced high price spikes. 110 In addition, the Southwest region is approaching
system conditions that present the risk of load curtailment during extreme weather events and
wildfires. 111 Increased transfer capacities between the Plains and Southwest regions would
improve system resilience during extreme weather events.
SPP’s 2021 ITP assessment identified the SPS south region as a target area requiring additional
transmission development to resolve reliability needs driven by load growth, generation
retirements, and limited transmission connections with the SPP generation fleet. 112 SPP identifies
three interfaces in southeastern New Mexico and the Texas and Oklahoma Panhandle area,
which are anticipated to experience overloads as power flows into the SPS region to displace
generation retirements and meet load growth. SPP further states the SPS south zone has been an
area of focus for the last decade and concludes “[w]ithout a forward-thinking, proactive approach
to transmission solutions in this area, SPP can expect to continually observe incremental needs
with reactive solution proposals,” which “provide limited short-term relief to system needs
where continued growth is expected to occur.” 113 Indeed, SPP has continued to identify
incremental reliability needs in this area in subsequent ITP assessments released in 2022 and
2023, and SPS’s 2023 IRP finds significant levels of projected load growth in the area will
require additional transmission facilities and/or local generation to address future reliability
concerns. 114 The Mountain-Plains-Southwest potential NIETC can facilitate increased power
transfers between the regions, which can simultaneously contribute towards addressing future
SPS-related reliability concerns while also reducing reliance on existing, constrained pathways
from the Mountain to Southwest region, such as Qualified Path 31 located across the ColoradoNew Mexico border. 115
The 2023 Needs Study identifies a significant present and anticipated future need for additional
cross-interconnection and interregional transfer capacity at the Mountain, Southwest, and Plains
regional interface. As discussed in the Needs Study, the Western Interconnection is anticipated to
become more dependent on generation in the Southwest and western Mountain region by 2038 to
meet future generation and demand needs. 116 Among the drivers increasing the need for

Id. at 39, 56-57
Id. at 56.
112
2021 SPP ITP Assessment Report at 1.
113
Id. at 106.
114
See 2022 SPP ITP Assessment Report at 19; 2023 SPP ITP Assessment Report at 63; see also 2023 SPS
NM IRP at 40-41.
115
2023 Needs Study at 42-44; 2023 WECC Path Rating Catalog at 32.
116
2020 Needs Study at 71-72.
110
111

33

additional interregional transmission is the displacement of coal generation in the Western
Interconnection and constraints on highly utilized existing pathways, which will become even
more critical to expand as the eastern Mountain region transitions from a net energy exporter to a
net importer. 117
The Needs Study also assessed historic wholesale market price differences between regions,
which signal areas of congestion on the transmission system that could be alleviated with
additional transmission capacity. According to Needs Study analysis of historical wholesale
market prices, high congestion value of transmission from 2012 through 2020 exists between the
Mountain and southern Plains regions, with an average marginal value of transmission equal to
$19/MWh. 118 The congestion value of that link continued to increase in recent years, up to
$39/MWh in 2021 and $54/MWh in 2020. 119 Cross-interconnection congestion value between
the Mountain and Plains regions has been increasing year after year since 2015. 120
The Needs Study finds there is a significant need for increased interregional transfer capacity
between the Mountain, Southwest, and Plains regions’ interface to meet future generation and
demand growth under certain scenarios of future load and clean energy growth assessed in the
capacity expansion modeling analysis. Under future scenarios with moderate load growth and
high clean energy growth, the Southwest region will need an anticipated median increase of 1.7
GW of additional transfer capacity with the Mountain region by 2035, a 41% increase relative to
the 2020 system. 121 Under the same scenario, the Southwest region will need an anticipated
median increase of 3.7 GW of additional transfer capacity with the Plains region by 2035, a
914% increase relative to the 2020 system. 122 Similarly, findings show the Mountain region will
need an anticipated median increase of 2.7 GW of additional transfer capacity with the Plains
region by 2035, a 287% increase relative to the 2020 system under moderate load growth and
high clean energy growth future scenarios. 123
The Mountain-Plains-Southwest potential NIETC has additional cross-interconnection
implications between ERCOT and both the Eastern and Western Interconnections should
additional back-to-back ties be constructed within the corridor. 124 Interconnection with ERCOT
would include additional benefits such as improving resilience, relieving congestion, and
meeting future demand growth. The Needs Study presents NERC and FERC findings that
demonstrate limited interconnections between ERCOT and neighboring systems significantly
affected its ability to make up for the capacity shortage experienced during Winter Storm Uri. 125

Id.
Id. at v, 37-38.
119
Id.
120
LBNL Empirical Estimates at 22.
121
2023 Needs Study at 131-133, tbl. VI-4.
122
Id.
123
Id.
124
See ERCOT, Area by County (last visited Mar. 26, 2024),
https://www.ercot.com/files/assets/2022/12/13/ERCOT-Maps_Area-by-county.jpg.
125
2023 Needs Study at 56-57.
117
118

34

Improving transfer capability via increased ties with neighboring regions would increase
ERCOT’s ability to import power to address capacity shortages when its system is stressed under
emergency conditions. Needs Study analysis of wholesale electricity prices also finds the highest
congestion values of interregional transmission from 2012 through 2020 across the entire United
States exists between ERCOT and the Plains region, ranging from $15/MWh to $69/MWh. 126
Similarly high congestion values of transmission exist between ERCOT and the Southwest
region ($25/MWh). 127 Further, the Needs Study demonstrates there is significant need for
increased cross-interconnection and interregional transfer capacity between ERCOT and the
Plains region to meet future generation and demand growth under all scenarios of future load and
clean energy growth assessed in the capacity expansion modeling analysis. Under scenarios with
moderate load growth and high clean energy growth future scenarios, ERCOT will need an
anticipated median increase of 9.8 GW of additional transfer capacity with the Plains region by
2035, a 1,200% increase relative to the 2020 system. 128

Id. at v, 37-38.
Id.
128
Id. at 131-133, tbl. VI-4.
126
127

35

Geography: The Mountain-Northwest potential NIETC is approximately 0.3-mile-wide (1,500
feet), 515-mile-long, north-south geographic area between Esmeralda County, Nevada, and
Jefferson County, Oregon. It is co-located with existing Bureau of Land Management (BLM)
Section 368 energy corridors 129 through most of Nevada and follows existing infrastructure for
most of its length. It has the potential to facilitate interregional transmission between CAISO and
NorthernGrid.

129
Several agencies worked to establish multi-function (including transmission) energy corridors on federal
lands in 11 western states (Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah,
Washington, and Wyoming) under section 368 of the Energy Policy Act of 2005. 42 U.S.C. 15926. Section 368
directs several agencies, including DOE, to designate these multi-use corridors on federal lands. Section 368 also
directs the agencies to, when designating such corridors, account for the need for upgraded and new infrastructure
and to take actions to improve reliability, relieve congestion, and enhance the capability of the national grid to
deliver energy. On April 20, 2022, the Bureau of Land Management, the U.S. Forest Service, and DOE released the
Final Regional Review Report for the West-wide Energy Corridors, which designated 5,000 miles of energy
corridors for potential placement of electricity transmission and distribution infrastructure, among other energy
transport projects. On December 1, 2023, the Bureau of Land Management published a Notice of Intent to Amend
Resource Management Plans for Section 368 Energy Corridor Revisions and Prepare an Associated Environmental
Impact Statement, which announced a land use planning effort to evaluate modifying seven designated West-wide
corridors and opened a scoping comment period.

36

Transmission Capacity Constraints or Congestion that Adversely Affects Consumers: The
Mountain-Northwest potential NIETC encompasses a geographic area where there is significant
need for increased interregional transfer capacity to maintain and improve reliability and
resilience, reduce system congestion, meet future generation and demand growth, and increase
clean energy integration. These preliminary findings are based on the 2023 Needs Study as well
as other relevant information and are consistent with DOE’s preliminary finding in the NIETC
Guidance regarding the particular value of NIETC designation where there is need for increased
interregional transfer capacity.
The Needs Study finds the Northwest region faces risk of load curtailment during extreme
weather events and wildfires, particularly as the region becomes increasingly reliant on variable
energy resources to meet peak demand. 130 NERC’s 2023 Long-Term Reliability Assessment
finds anticipated generation retirements and increasing demand in the WECC-Northwest region
are expected to reduce reserve margins and put the region at risk of resource shortfalls during
extreme weather events after 2024. 131 Due to these anticipated system conditions, NERC has
categorized the WECC-Northwest region as an “elevated risk area.” 132 Additional transmission
upgrades would reduce risks to electric reliability from extreme events.
The Mountain-Northwest potential NIETC also provides an alternative path to existing,
congested pathways such as the California-Oregon Intertie, located at the intersection of the
Northwest, California, and Mountain regions, as well as the Pacific DC Intertie, which extends
from northern Oregon, through Nevada, and into southern California. According to CAISO,
congestion on interties across all markets has increased in recent years, predominantly driven by
increased congestion on these two major interties that link CAISO with the Northwest. 133 Needs
Study findings also demonstrate the need to alleviate transfer capacity limits between the
Northwest and Mountain regions. According to Needs Study analysis of historical wholesale
market prices, high congestion value of interregional transmission from 2012 through 2020
exists between the Northwest and Mountain regions, with an average marginal value of
transmission equal to $14/MWh. 134 A high congestion value indicates that additional
transmission between the regions would reduce system congestion and constraints and lower
consumer costs.
The 2023 Needs Study identifies present and anticipated future need for additional interregional
transfer capacity between the Mountain and Northwest regions due to anticipated generation mix
changes and demand growth. As discussed in the Needs Study, the Western Interconnection is
anticipated to become more dependent on generation in the Southwest and western Mountain
region by 2038 to meet future generation and demand needs. 135 Among the drivers increasing the

2023 Needs Study at 56.
2023 NERC LTRA at 9.
132
Id.
133
CAISO, 2022 Annual Report on Market Issues & Performance, at 181 (July 2023),
https://www.caiso.com/Documents/2022-Annual-Report-on-Market-Issues-and-Performance-Jul-11-2023.pdf.
134
2023 Need Study at v, 37-38.
135
Id. at 71-72.
130
131

37

need for additional interregional transmission is the displacement of coal generation in the
Western Interconnection and constraints on highly utilized existing pathways, which will become
even more critical to expand as the eastern Mountain region transitions from a net energy
exporter to a net importer. 136 Additionally, utilities in the Northwest region and the Bonneville
Power Administration anticipate load in the region to increase by 20% over the next five years,
much of which is driven by industrial load growth and electrification. 137 The Needs Study
estimates need for increased interregional transfer capacity between the Northwest and Mountain
regions to meet future generation and demand growth under certain scenarios of future load and
clean energy growth assessed in the capacity expansion modeling analysis. Under future
scenarios with moderate load growth and high clean energy growth, the Northwest will need an
anticipated median increase of 3.3 GW of additional transfer capacity with the Mountain region
by 2035, a 26% increase relative to the 2020 system. 138 Increased transfer capacity between the
Mountain and Northwest regions would help accommodate future generation and load profiles.

IV.

Comment Period and Phase 2 Information Submission Window

As explained in the NIETC Guidance, following issuance of the preliminary list of
potential NIETCs to initiate Phase 2 of the NIETC designation process, DOE invites interested
parties to submit comments on the preliminary list as well as additional information and
recommendations on geographic boundaries and potential impacts on environmental,
community, and other resources for those potential NIETCs included in the preliminary list
based on the Phase 2 information submission requests listed in Section V.B.2 of the NIETC
Guidance. 139 The list of information for Phase 2 is designed to assist DOE in conducting a study
of environmental impacts pursuant to NEPA and examining any requirements that may apply
under other federal statutes in designating one or more NIETCs. Like Phase 1, this window is
open for 45 days.

A.

Comments on Preliminary List of Potential NIETCs

DOE invites comments from interested parties on the potential NIETCs in the preliminary list.
Interested parties are any person or entity, including States and Indian Tribes, concerned with
DOE’s exercise of its discretion to designate a geographic area as a NIETC. To be clear,
interested parties are not limited to those persons or entities that made submissions during the
Phase 1 information submission window.
To assist DOE in determining whether the geographic area of the potential NIETC designation is
experiencing or is expected to experience transmission capacity constraints or congestion that
Id.
Pacific Northwest Utilities Conference Committee, Northwest Regional Forecast of Power Loads and
Resources: August 2023 through July 2033, at 5 (May 2023), https://www.pnucc.org/wp-content/uploads/2023PNUCC-Northwest-Regional-Forecast-final.pdf.
138
2023 Needs Study at 131-133, tbl. VI-4.
139
NIETC Guidance at 48-56, https://www.energy.gov/sites/default/files/2023-12/2023-1215%20GDO%20NIETC%20Final%20Guidance%20Document.pdf.
136
137

38

adversely affects consumers, DOE requested that interested parties provide in their Phase 1
submissions information on transmission needs, adverse effects on consumers, and the relevant
discretionary factors in FPA section 216(a)(4). DOE continues to seek additional information
that was requested during Phase 1 during Phase 2 for the potential NIETCs included in this
preliminary list. The information requested for Phase 1 is available in Section V.B.1 of the
NIETC Guidance. 140 This means that DOE invites interested parties to comment on the
information contained within the preliminary list of potential NIETCs, including commenting on
the present or expected transmission capacity constraints or congestion relevant to the potential
NIETCs in the preliminary list as well as the adverse effects on consumers resulting therefrom
(i.e., the consumer harms resulting from the lack of adequate transmission within the potential
NIETCs). As noted earlier, DOE also encourages interested parties to identify potential
transmission projects under development in close proximity to or within these potential NIETCs
that may warrant changes to the geographic boundaries of the potential NIETCs or otherwise
factor into DOE’s assessment of which potential NIETCs proceed to Phase 3.

B.

Phase 2 Information Submissions

The 45-day window following issuance of this preliminary list also includes the Phase 2
information submission window. DOE invites interested parties to submit additional information
on geographic boundaries and potential impacts on environmental, community, and other
resources based on the list included in Section V.B.2 of the NIETC Guidance for Phase 2. 141 As
noted above, interested parties are not limited to those persons or entities that made submissions
during the Phase 1 information submission window.
The list of information requested for Phase 2 is organized into 13 categories (called resource
reports): (1) geographic boundaries; (2) water use and quality; (3) fish, wildlife, and vegetation;
(4) cultural resources; (5) socioeconomics; (6) Tribal resources; (7) communities of interest; 142
(8) geological resources; (9) soils; (10) land use, recreation, and aesthetics; (11) air quality and
environmental noise; (12) alternatives; and (13) reliability and safety. The Phase 2 information
submission window is focused on gathering additional information on geographic boundaries
and potential impacts on environmental, community, and other resources specific to the potential
NIETCs in the preliminary list to facilitate DOE’s environmental review, which starts in Phase 3.
DOE requests that interested parties provide in their Phase 2 information submissions the
following essential resource information: concise descriptions of any known or potential
environmental and cumulative effects resulting from a potential NIETC designation, including
visual, historic, cultural, economic, social, or health effects thereof. For example, interested
parties may provide information such as the location of wetlands, recreation areas, historic

Id. at 45-48.
Id. at 48-56.
142
As defined in the NIETC Guidance, communities of interest means the following communities that
could be affected by a NIETC designation: disadvantaged communities; rural communities; Tribal communities;
indigenous communities; geographically proximate communities; communities with environmental justice concerns;
and energy communities. Id. at 15.
140
141

39

properties, residences and businesses, abandoned mines, and cropland within the potential
NIETCs on the preliminary list. DOE also requests that interested parties identify any
environmental reviews previously conducted, in progress, or planned for transmission projects
within the potential NIETCs in the preliminary list. To the extent identified, interested parties
may also comment on the existing environmental reviews, including how DOE can access them
and their potential utility for DOE, as well as gaps or other perceived flaws in those reviews.
Interested parties may submit any level of information to help inform DOE’s process of
designating NIETCs under FPA section 216(a)(2). For example, an interested party may only
have information that is relevant to one particular resource report, and even one particular data
request within a resource report. DOE welcomes that narrow information submission. Note that
there is no prohibition on the number of information submissions from an interested party. DOE
values diverse perspectives in the NIETC designation process and anticipates that information
and recommendations from a broad set of sources will only enhance DOE’s ability to efficiently
and effectively comply with its obligations under the FPA and other federal statutes applicable to
NIETC designation.

C.

Procedures for Comments and Information Submissions

DOE requests comments and information submissions be made by 5:00 pm ET on June 24, 2024,
via email to NIETC@hq.doe.gov. Receiving timely submissions will facilitate DOE’s exercise of
its discretion to designate NIETCs in the most efficient and effective manner.
DOE requests submissions be provided in Microsoft Word or PDF format, except for maps and
geospatial submissions. There is no page limit on submissions. Interested parties are encouraged
to organize information submissions in the manner presented in the NIETC Guidance, including
any relevant numbering. DOE requests that information submissions include the name(s), phone
number(s), and email address(es) for the principal point(s) of contact, as well as relevant
institution and/or organization affiliation and postal address.
In response to concerns about maintaining the confidentiality of certain information, including
commercially sensitive information, critical electric infrastructure information (CEII), and
proprietary information, pursuant to 10 CFR 1004.11, any interested party submitting
information as part of the NIETC designation process that the interested party believes to be
confidential and potentially exempt by law from public disclosure should submit two wellmarked copies, one marked “confidential” that includes all the information believed to be
confidential, and one marked “non-confidential” with the information believed to be confidential
deleted or redacted. DOE will make its own determination about the confidential status of the
information and treat it according to its determination. The interested party may request
confidential treatment for all material sent to DOE containing location, character, and ownership
information about cultural resources. Pursuant to 10 CFR 1004.13, any interested party
submitting information that the interested party believes might contain CEII should submit a
request for CEII designation of information. Failure to comply with these marking requirements
may result in the disclosure of the unmarked information under the Freedom of Information Act
40

or otherwise. The U.S. Federal Government is not liable for the disclosure or use of unmarked
information and may use or disclose such information for any purpose. The Government may use
or disclose any information that is not appropriately marked or otherwise restricted, regardless of
source.
With regard to Tribal resources, including sacred sites, DOE recognizes the vital role of
proactive engagement in fostering collaborative relationships with Federally Recognized Indian
Tribes and Tribal interests. DOE will follow federal law, its Policy and Order on Tribal
Consultation, as well as the Best Practices Guide for Federal Agencies Regarding Tribal and
Native Hawaiian Sacred Sites currently in effect, to discern potential impacts of NIETC
designation on Indian Tribes and Tribal interests, for instance, impacts to Indian Land, historic
homelands from which Tribes were removed, cultural sites, sacred sites, burial sites, water rights,
mineral and other subsurface rights, fishing rights, and hunting rights. This includes DOE
determining whether formal consultation is needed with any Indian Tribes. For the purposes of
the NIETC designation process, DOE defines Tribal Resources as follows:
Any available information regarding resources or interests to a Federally recognized
Indian Tribe, including but not limited to Reservation Boundaries, Fee-owned lands,
treaty rights, publicly known or listed Traditional Cultural Properties or other cultural
resources, any known consultation protocols for a given state or region, a list of Federally
recognized Indian Tribes who have pre-contact interest or claims to a project area, and
any other interest or resources that may impact a Federally recognized Indian Tribe.
At this point in the NIETC designation process, DOE is looking for specific information from
interested parties concerning Tribal interests and how they may possibly impact the designation
of potential NIETCs. DOE recognizes that some information may be sensitive and not publicly
disclosed and therefore recommends the following:
Interested Parties:
•

•

•

Interested parties are encouraged to submit only non-sensitive information necessary to
sufficiently support agency actions and avoid submitting any potentially sensitive data. If
DOE determines that additional information is needed to support NIETC designation,
DOE will contact the interested party directly to request that data.
Interested parties are not required to obtain sensitive data from a Federally recognized
Indian Tribe, information that Tribes may be unwilling to share. For any additional
information that a Federally Recognized Indian Tribe is willing to share to further the
purposes of the NIETC designation, DOE may reach out to the affected Tribe directly.
Interested parties should be aware that Section 304 of the National Historic Preservation
Act of 1966 (NHPA) and Section 9 of the Archaeological Resources Protection Act of
1979 protect from public disclosure only information of certain archaeological resources
and historic properties and do not guarantee that the Tribal resource information will be
protected from disclosure pursuant to the Freedom of Information Act.

41

•

If an interested party believes sensitive information exists in its submission to DOE, it
should clearly mark that information as “sensitive” or “proprietary.”

DOE:
•

•
•

•

•

•

•
•
•

V.

If DOE receives any potentially sensitive information, in addition to publicly available
data, DOE will take appropriate measures to protect the confidentiality of any Tribal
Resources including but not limited to pursuing protection from disclosure under Section
304 of NHPA and Section 9 of the Archaeological Resources Protection Act, if
applicable.
DOE will also follow its current document retention schedule consistent with the
National Archives and Records Administration requirements.
DOE may enter into a confidentiality or data-sharing agreement with a Tribe detailing the
information federal personnel may access and how they may access it, consistent with the
Freedom of Information Act requirements and requirements related to documenting
federal decisions related to the NIETC designation.
DOE will develop a Tribal Engagement Plan for each potential NIETC that will serve as
a framework for establishing meaningful and forthcoming partnership between DOE and
the Federally Recognized Indian Tribes that may have interest in the NIETC designation.
DOE will follow Controlled Unclassified Information Guidelines for protection of
archaeological resources and historic properties as outlined here:
https://www.archives.gov/cui/registry/category-detail/archaeological-resources.
DOE will be transparent with Tribes regarding the limits of DOE’s ability to protect
agency records containing Tribal Resources from disclosure under relevant legal
authorities.
DOE will seek only minimally required information necessary to sufficiently support
agency action.
DOE will engage with the affected Tribes prior to disclosure of any potentially sensitive
information.
DOE will endeavor to disclose Tribal Resources information (unless publicly available)
in any Federal Register notice, agency website, or other federal publication only after
obtaining consent from the appropriate Tribes.

Transmission Facility Financing

As discussed in the NIETC Guidance, the Inflation Reduction Act established a Transmission
Facility Financing (TFF) program, under which DOE can provide direct loan support for
transmission facilities designated by the Secretary to be necessary in the national interest under
FPA section 216(a). 143 While Congress did not specify a maximum volume of loans that may be
issued, Congress appropriated $2 billion to carry out the program, which may be used to pay the

143

Pub. L. No. 117-169 (Section 50151); 42 U.S.C. 18715.

42

Credit Subsidy Cost for loans made under this program. 144 DOE stated in the NIETC Guidance
that it intends to deem transmission facilities that would be located within a NIETC designated
pursuant to the NIETC Guidance eligible to receive a loan under the TFF program. DOE also
stated that details about how to apply for a TFF loan were forthcoming at a later date. Additional
guidance is provided below.
To be eligible for a TFF loan, applicants must meet the following minimum criteria:
•
•
•
•
•

•

The applicant must be a non-federal borrower;
The applicant must be constructing or modifying electric transmission facilities;
The applicant’s project must include electric transmission facilities located within a
geographic area that the Secretary of Energy has designated as a NIETC pursuant to
section 216(a)(2) of the FPA;
The construction or modification of the relevant electric transmission facilities must
address the transmission capacity constraints or congestion underlying the Secretary of
Energy’s designation of the associated NIETC;
The applicant must be seeking a loan that:
o Has a term of the lesser of 90% of the projected useful life of the facility or 30
years;
o Does not exceed 80% of the project costs; and
o Is subject to the condition that the direct loan is not subordinate to other
financing.
All loan disbursements to the project must occur prior to September 30, 2031.

Projects that are expected to benefit from other certain forms of federal support may not be
eligible to receive a TFF loan. 145 Examples include such federal support as grants, cooperative
agreements, or other loans or loan guarantees from federal agencies or entities. Limited
exceptions may apply, which may be considered on a case-by-case basis. 146
DOE invites input from transmission industry stakeholders about the scope of eligible TFF
projects and associated project financing requirements. DOE is also interested in hearing from
utilities or project developers who are considering seeking TFF support for a specific project in
or near one of the potential NIETCs identified in this issuance. DOE will use data gathered
during this scoping period to inform its formal TFF application and evaluation process, which is
anticipated to open in Spring 2025. Transmission developers, utilities, and other interested
parties interested in providing input on the development of DOE’s formal TFF application and
evaluation process may contact DOE at TFF@hq.doe.gov by July 31, 2024. After July 31, 2024,
DOE may continue to gather information from transmission industry stakeholders, as needed, to
complete development of the formal TFF application and evaluation process.

See OMB Circular No. A-11, Preparing, Submitting, and Executing the Budget, Section 185.2.
Pub. L. No. 117-169 (Sections 50151(b), 50141(d)(2)); 42 U.S.C. 18715.
146
Pub. L. No. 117-169 (Section 50141(d)(3)).
144
145

43

As explained in the NIETC Guidance, designation of a NIETC does not constitute selection of or
a preference for a specific transmission project for DOE funding purposes. Developers of
transmission facilities within a NIETC may apply for DOE funding opportunities, and DOE will
evaluate such applications based on the criteria for those funding opportunities, including for
direct loans through the TFF program.

VI.

More Information

Questions regarding this preliminary list of potential NIETCs and the NIETC program more
generally can be directed to NIETC@hq.doe.gov. More information on NIETCs is also available
at www.energy.gov/gdo/national-interest-electric-transmission-corridor-designation-process.

44

Appendix A: Potential NIETC Maps – New York-New England
Disclaimer: All data, information, and maps are provided “as is” without warranty of any
representation of accuracy, timeliness, or completeness. They should be used for illustration
purposes only and not be considered legal documents. DOE makes no claims or warranties,
express or implied, concerning the validity or accuracy of the GIS data presented on these maps.
The displayed geographic boundaries are subject to change once additional data, including but
not limited to environmental and community data, are obtained in Phase 2.

Shaded Potential NIETC Geographic Area

45

Electrical Infrastructure

46

Environmental Information
jurisdiction

47

Appendix B: Potential NIETC Maps – New York-Mid-Atlantic
Disclaimer: All data, information, and maps are provided “as is” without warranty of any
representation of accuracy, timeliness, or completeness. They should be used for illustration
purposes only and not be considered legal documents. DOE makes no claims or warranties,
express or implied, concerning the validity or accuracy of the GIS data presented on these maps.
The displayed geographic boundaries are subject to change once additional data, including but
not limited to environmental and community data, are obtained in Phase 2.

Shaded Potential NIETC Geographic Area

48

Electrical Infrastructure

49

Environmental Information

50

Appendix C: Potential NIETC Maps – Mid-Atlantic-Canada
Disclaimer: All data, information, and maps are provided “as is” without warranty of any
representation of accuracy, timeliness, or completeness. They should be used for illustration
purposes only and not be considered legal documents. DOE makes no claims or warranties,
express or implied, concerning the validity or accuracy of the GIS data presented on these maps.
The displayed geographic boundaries are subject to change once additional data, including but
not limited to environmental and community data, are obtained in Phase 2.

Shaded Potential NIETC Geographic Area

51

Electrical Infrastructure

52

Environmental Information

53

Appendix D: Potential NIETC Maps – Mid-Atlantic
Disclaimer: All data, information, and maps are provided “as is” without warranty of any
representation of accuracy, timeliness, or completeness. They should be used for illustration
purposes only and not be considered legal documents. DOE makes no claims or warranties,
express or implied, concerning the validity or accuracy of the GIS data presented on these maps.
The displayed geographic boundaries are subject to change once additional data, including but
not limited to environmental and community data, are obtained in Phase 2.

Shaded Potential NIETC Geographic Area

54

Electrical Infrastructure

55

Environmental Information

56

Appendix E: Potential NIETC Maps – Midwest-Plains
Disclaimer: All data, information, and maps are provided “as is” without warranty of any
representation of accuracy, timeliness, or completeness. They should be used for illustration
purposes only and not be considered legal documents. DOE makes no claims or warranties,
express or implied, concerning the validity or accuracy of the GIS data presented on these maps.
The displayed geographic boundaries are subject to change once additional data, including but
not limited to environmental and community data, are obtained in Phase 2.

Shaded Potential NIETC Geographic Area

57

Electrical Infrastructure

58

Environmental Information

59

Appendix F: Potential NIETC Maps – Northern Plains
Disclaimer: All data, information, and maps are provided “as is” without warranty of any
representation of accuracy, timeliness, or completeness. They should be used for illustration
purposes only and not be considered legal documents. DOE makes no claims or warranties,
express or implied, concerning the validity or accuracy of the GIS data presented on these maps.
The displayed geographic boundaries are subject to change once additional data, including but
not limited to environmental and community data, are obtained in Phase 2.

Shaded Potential NIETC Geographic Area

60

Electrical Infrastructure

61

Environmental Information

62

Appendix G: Potential NIETC Maps – Delta-Plains
Disclaimer: All data, information, and maps are provided “as is” without warranty of any
representation of accuracy, timeliness, or completeness. They should be used for illustration
purposes only and not be considered legal documents. DOE makes no claims or warranties,
express or implied, concerning the validity or accuracy of the GIS data presented on these maps.
The displayed geographic boundaries are subject to change once additional data, including but
not limited to environmental and community data, are obtained in Phase 2.

Shaded Potential NIETC Geographic Area

63

Electrical Infrastructure

64

Environmental Information

65

Appendix H: Potential NIETC Maps – Plains-Southwest
Disclaimer: All data, information, and maps are provided “as is” without warranty of any
representation of accuracy, timeliness, or completeness. They should be used for illustration
purposes only and not be considered legal documents. DOE makes no claims or warranties,
express or implied, concerning the validity or accuracy of the GIS data presented on these maps.
The displayed geographic boundaries are subject to change once additional data, including but
not limited to environmental and community data, are obtained in Phase 2.

Shaded Potential NIETC Geographic Area

66

Electrical Infrastructure

67

Environmental Information

68

Appendix I: Potential NIETC Maps – Mountain-Plains-Southwest
Disclaimer: All data, information, and maps are provided “as is” without warranty of any
representation of accuracy, timeliness, or completeness. They should be used for illustration
purposes only and not be considered legal documents. DOE makes no claims or warranties,
express or implied, concerning the validity or accuracy of the GIS data presented on these maps.
The displayed geographic boundaries are subject to change once additional data, including but
not limited to environmental and community data, are obtained in Phase 2.

Shaded Potential NIETC Geographic Area

69

Electrical Infrastructure

70

Environmental Information

71

Appendix J: Potential NIETC Maps – Mountain-Northwest
Disclaimer: All data, information, and maps are provided “as is” without warranty of any
representation of accuracy, timeliness, or completeness. They should be used for illustration
purposes only and not be considered legal documents. DOE makes no claims or warranties,
express or implied, concerning the validity or accuracy of the GIS data presented on these maps.
The displayed geographic boundaries are subject to change once additional data, including but
not limited to environmental and community data, are obtained in Phase 2.

Shaded Potential NIETC Geographic Area

72

Electrical Infrastructure

73

Environmental Information

74