DOE Releases Draft Study Calling for More Interregional Transmission

On February 24, 2023, the U.S. Department of Energy (DOE) released for public comment a draft of its National Transmission Needs Study (“Needs Study”), which endorses boosting overall transmission capacity—and transmission between grid regions in particular. The final Needs Study, expected this summer, could have significant implications for federal transmission planning and permitting, including by informing the potential designation of National Interest Electric Transmission Corridors.


Based on a review of publicly available data and dozens of industry, governmental, academic, and consultant reports, the draft Needs Study “establishes findings of need in order for industry and the public to suggest best possible solutions for alleviating them.” It does not recommend any particular solutions.

The Needs Study began in January 2022 as part of DOE’s Building a Better Grid Initiative, which seeks to enhance the nation’s high-voltage transmission capability and overall grid resilience. Although previously conducted under a requirement of the Federal Power Act, this iteration is the first time the triennial transmission study considers future—in addition to historical—constraints, thanks to new language added by the Bipartisan Infrastructure Law.

The study’s initial phase sought feedback from certain “consultation entities”—states, tribes, and regional grid entities—who submitted comments on a first draft in fall of 2022. The latest draft incorporates revisions based on feedback from those consultation entities and invites comments from the public.

Key Findings

The draft study’s key findings include the following:

  • There is a pressing need for additional electric transmission infrastructure. While far from the first to point out the need for increased transmission capacity, the draft study concludes that nearly all parts of the country will benefit from improved grid reliability and resilience through additional transmission infrastructure. It also emphasizes that increasing transmission capacity will, among other things, support renewable energy and electrification efforts, as well as reduce congestion and curtailment. The draft cites a decrease in historical transmission investment, regional and interregional wholesale electricity price differentials, and a record backlog of new generation and storage capacity in interconnection queues across the country as key indicators that current and future transmission needs are not being met. The top four regions needing increased transmission are the Midwest, Southeast, Plains, and Texas.
  • Increasing interregional transmission will maximize grid benefits. The draft study states that increasing interregional transmission will help improve overall system resilience by providing access to diverse generation, particularly across different climate zones. Key areas that would benefit from additional interregional transmission to help meet load demands and clean energy targets include the Mid-Atlantic to Midwest, Midwest to Plains, Delta to Plains, and Plains to Texas. The draft also highlights New York and New England as needing increased interregional transmission.
  • Transmission needs will shift over time. For example, significant deployment will be needed as soon as 2030 in the Plains, Midwest, and Texas to meet demand, while the Mountain, Mid-Atlantic, and Southeast regions will experience heightened demand by 2040.


The Needs Study, once final, will support implementation of existing DOE initiatives, including various federal grid financing programs set to receive billions of dollars in funding from the Inflation Reduction Act (IRA).

Notably, DOE has also stated that the final study could also inform the designation of National Interest Electric Transmission Corridors (“National Corridors”). The Energy Policy Act of 2005 authorizes DOE to designate National Corridors (i.e., geographic areas designated as transmission-constrained or congested) and authorizes the Federal Energy Regulatory Commission (FERC) to issue permits for construction or modification of electric transmission facilities within such corridors.

As we’ve previously noted, FERC has issued a notice of proposed rulemaking to implement its newly clarified authority under the 2021 Infrastructure Investment and Jobs Act to issue permits if a state denies an applicant’s request to site transmission facilities within a designated National Corridor. Thus, while no National Corridor designations are currently in effect, the final Needs Study likely will inform future designations and, in turn, empower FERC to step in where states reject, delay, or obstruct interstate transmission development in the country’s most congested areas.

Moreover, transmission projects located in National Corridors will be eligible for a portion of $2 billion in direct loan funding under the IRA.

Note that DOE plans to engage in further process prior to proposing any National Corridor designations, which will take into account several other factors specified by the Bipartisan Infrastructure Law—including considerations of economic vitality, diversity of supply, reduction of consumer cost, and national energy security and independence—in addition to the Needs Study results.

Public Comment Period

Comments are due April 20, 2023 and should be sent in PDF format to DOE has asked the public, in particular, for feedback on additional data or studies that should be included in the final report, as well as what additional analysis should be conducted based on the considered data.

Interested in more transmission news? My colleague, Josh Rosen, published a post discussing a transmission concept paper submitted by the New England states in response to a funding opportunity from the DOE’s Grid Resilience & Innovation Partnership (GRIP). The concept paper seeks funding for the development of three new high voltage direct current (HVDC) transmission lines and related onshore system upgrades to support the injection of new offshore wind resources in New England.

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