DOE Announces Efforts to Address Transmission Development for West Coast Offshore Wind

April 6, 2023

Reading Time : 6 min

In February 2023, the U.S. Department of Energy (DOE) released its West Coast Offshore Wind Transmission Literature Review and Gaps Analysis (“Transmission Review”) aimed at identifying areas where additional transmission studies will be required to support the development of offshore wind projects off the coasts of California, Oregon and Washington.1 DOE followed up the release of its Transmission Review with an announcement that it would be conducting a new 20-month West Coast Wind Transmission Study (“Transmission Study”), which will provide a roadmap for developing the transmission infrastructure necessary to eliminate the transmission constraints currently limiting offshore wind development along the west coast.2 Given the Biden administration, California and Oregon’s aggressive offshore wind goals and the fact that existing onshore transmission is insufficient to accommodate these goals, the Transmission Review and Transmission Study are likely to play a key role in planning for the build-out of transmission necessary to deploy major west coast offshore wind projects.

Background

The Biden administration has set a goal of bringing 15 gigawatts (GWs) of floating offshore wind online by 2035 and both California and Oregon have established offshore wind goals of 2-5 and 3 GWs by 2030, respectively.3 In line with these goals, the Bureau of Ocean Energy Management (BOEM) has established two Wind Energy Areas (WEAs) off the coast of California and two Call Areas off the coast of Oregon for the development of wind projects.4 BOEM conducted a lease sale for the two California WEAs representing five lease areas and 373,268 acres in early December 2022.5

But the WEAs and Call Areas established by BOEM—while representing high capacity wind areas—are located up to 65 miles from shore and are generally isolated from the high voltage transmission that will be necessary to transmit energy from offshore wind projects to high load areas.6DOE’s Transmission Review represents an initial first step towards addressing the transmission needs associated with west coast offshore wind projects by evaluating the existing west coast offshore wind transmission analyses and identifying other considerations that transmission planning analyses will need to take into account for these projects going forward. The Transmission Study will build on the Transmission Review by evaluating multiple pathways to ensure transmission is available to meet the administration and state offshore wind goals and will be used “to develop practical plans through 2050 to address transmission constraints that currently limit offshore wind development along the nation’s West Coast.”7

Transmission Review

Of the more than 30 west coast electric generation and transmission studies that were reviewed as part of the Transmission Review, DOE found a number of common themes, including a lack of:8

  • Transmission capacity at potential onshore interconnection points and transmission networks, particularly in northern California, necessary to connect offshore wind at the scale contemplated by the WEAs and Call Areas.
  • Suitable points of interconnection near the WEAs or Call Areas.
  • Consensus regarding the optimal ocean grid infrastructure or offshore transmission network for serving these projects.
  • Analysis that considers multiple interconnection points and/or multiple transmission systems.
  • Studies considering subsea transmission options.

DOE concludes that additional studies will be required to fully illuminate these themes, particularly if transmission development to support these important projects is pursued in a coordinated fashion.9

Additionally, the Transmission Review identifies a number of subjects that will need to be addressed going forward to ensure that adequate transmission infrastructure is developed to support the delivery of the electricity produced by west coast offshore wind projects. At the top of DOE’s list is the lack of interregional coordination.10 The Transmission Review notes that utilities in the West increasingly rely on long distance transmission to serve their loads and thus make interregional transmission coordination essential. Offshore wind, if coordinated with the resource needs of a large number of western load serving entities, could result in a holistic plan that integrates offshore wind projects for the benefit of multiple regions.11

The Transmission Review also suggests other technical considerations of offshore wind transmission development that should be evaluated in future analyses. Analyzing the interregional portfolios of loads and generation and how they are likely to change over time to accommodate state policy objectives could, for example, affect offshore wind’s role in the resource mix. Understanding the technological readiness of transmission and offshore wind infrastructure along with viable undersea cable routes would also be helpful to identifying alternative pathways for delivering energy from offshore wind projects to high load areas. And developing more concrete generation attribute and project cost estimates will be important for performing cost-benefits analysis related to these projects and their development paths.

The Transmission Review also notes that new policy developments will need to be considered as they arise in the planning process for west coast offshore wind.12 Indeed, a majority of the analyses summarized by the Transmission Review were completed prior to the passage of the Inflation Reduction Act and its extension of the tax credits for offshore wind to at least 203413 and appropriation of $100 million for planning interregional transmission development and the development of transmission for offshore wind energy.14And few, if any, of the analyses take into account more recent planning decisions—like the California Independent System Operator Corporation’s proposal to delay queue processing and evaluate whether it’s possible to study offshore wind and certain other long-lead time resources through a separate queue process—that are likely to affect the development of transmission necessary to support offshore wind projects.15

Transmission Study

While the 20-month west coast Transmission Study is just kicking off and few details are available yet, DOE’s corresponding Atlantic Offshore Wind Transmission Study is scheduled to conclude by November of this year and will likely provide some insight into what to expect from the west coast Transmission Study.16 DOE has stated that the Atlantic Offshore Wind Transmission Study will, among other things, identify scenarios and pathways of offshore wind energy deployment with transmission topologies, quantify the impacts of different offshore wind transmission scenarios, compare transmission technologies, and determine a critical point after which the benefits of a coordinated transmission framework will outweigh the benefits of radial generator lead lines.17

Conclusion

The west coast currently lacks the transmission infrastructure necessary to achieve the Biden administration, California or Oregon’s offshore wind goals. To meet these goals and ensure that the offshore wind projects contemplated to be developed in the WEAs and Call Areas are able to deliver their energy to high load centers, transmission planning to support these projects must commence soon. Although offshore wind projects have long lead times (the Transmission Review notes that BOEM’s process timeline anticipates up to seven years for a construction and operations plan to be approved),18 transmission projects cannot be built overnight and thus starting the planning process for the projects necessary to support west coast offshore wind is essential.19 The DOE’s Transmission Review and Transmission Study represent important first steps in that process.


1 U.S. Dept. of Energy, West Coast Offshore Wind Transmission Literature Review and Gaps Analysis (Feb. 2023), https://www.energy.gov/eere/wind/articles/doe-report-helps-understand-west-coast-offshore-wind-transmission-needs.

2 See U.S. Dept. of Energy, New Analysis Studying West Coast Offshore Wind Transmission Options (Feb. 22, 2023), https://www.energy.gov/eere/wind/articles/new-analysis-studying-west-coast-offshore-wind-transmission-options.

3Transmission Review at 8, 19.

4 Id. at 8.

5 U.S. Dept. of the Interior, Biden-Harris Administration Announces Winners of California Offshore Wind Energy Auction (Dec. 7, 2022), https://doi.gov/pressreleases/biden-harris-administration-announces-winners-california-offshore-wind-energy-auction.

6 Transmission Review at 8, 15.

7 U.S. Dept. of Energy, U.S. Department of Energy Announces New Actions to Accelerate U.S. Floating Offshore Wind Deployment (Feb. 22, 2023), https://www.energy.gov/articles/us-department-energy-announces-new-actions-accelerate-us-floating-offshore-wind-deployment.

8 Transmission Review at 10-11.

9Id. at 11.

10Id. at 15.

11Id.

12 Id. at 16.

13 26 U.S.C. §§ 45, 45Y, 48 and 48E.  

1442 U.S.C. § 18715b.

15 Transmission Review at 16.

16National Renewable Energy Laboratory, Atlantic Offshore Wind Transmission Study (last visited: April 2, 2023), https://www.nrel.gov/wind/atlantic-offshore-wind-transmission-study.html.

17 Id.

18 Transmission Review at 8.

19 See, e.g., U.S. Dept. of the Interior, Proposed SunZia Southwest Transmission Project (last visited April 2, 2023), https://www.blm.gov/programs/planning-and-nepa/plans-in-development/new-mexico/proposed-sunzia-transmission-project (noting that National Environmental Policy Act review began in 2009 for transmission project that has not yet commenced construction).

Share This Insight

Previous Entries

Speaking Energy

December 5, 2024

On November 27, 2024, the Federal Energy Regulatory Commission (FERC or Commission) issued Venture Global CP2 LNG, LLC,1 an order that sets aside, in part, the Commission’s prior authorization of the CP2 LNG Terminal and CP Express Pipeline Project (collectively, the CP2 Project) under sections 3 and 7 of the Natural Gas Act (NGA). In anticipation of future appellate challenges to its authorization of the CP2 Project, FERC ordered the initiation of a supplemental environmental impact statement (SEIS) process under the National Environmental Policy Act (NEPA) to assess the CP2 Project’s contribution to cumulative air impacts for nitrogen dioxide (NO2) and particulate matter less than 2.5 micrometers (PM2.5). Accordingly, FERC stated that it would not allow construction to commence on the CP2 Project’s proposed liquefied natural gas (LNG) export terminal and related feed gas pipeline until the SEIS process concluded and a subsequent order was issued. Concurrent with its Venture Global order, FERC issued a projected schedule for the NEPA process that does not conclude until July 24, 2025. Construction on the CP2 Project had been expected to be imminent, with the project sponsor seeking a partial authorization to proceed with construction only hours prior to Venture Global’s issuance.

...

Read More

Speaking Energy

December 5, 2024

On November 27, 2024, in Venture Global, CP2 LNG, LLC,1 the Federal Energy Regulatory Commission’s (FERC or Commission) explicitly overruled precedent set in Northern Natural Gas Co.,2 a 2021 decision in which FERC made an affirmative finding that an interstate natural gas pipeline project it was certificating under section 7 of the Natural Gas Act (NGA) would not make a “significant” contribution to global climate change. Northern Natural is the only FERC decision in which a so-called significance determination was made with respect to greenhouse gas emissions (GHG) arising from a FERC-regulated natural gas infrastructure project. In Venture Global, FERC rejected arguments that it needed to follow Northern Natural and assess the significance of GHG emissions in all NGA certificate proceedings to comply with the National Environmental Policy Act (NEPA). NEPA requires federal agencies, including FERC, that perform “major federal actions,” which include issuing NGA section 7 certificates, to prepare an environmental impact statement (EIS) if the action will “significantly affect[] the quality of the human environment.”3 FERC has been under pressure to fully explain why it has chosen not to apply Northern Natural’s significance analysis in subsequent cases, and that issue is currently before FERC on remand from the U.S. Court of Appeals for the District of Columbia (D.C. Circuit) in Healthy Gulf et al. v. FERC, which reviewed FERC’s approval of a liquefied natural gas (LNG) terminal under NGA section 3.

...

Read More

Speaking Energy

December 4, 2024

On November 21, 2024, the Federal Energy Regulatory Commission (FERC or Commission) issued Order No. 1920-A1 addressing requests for rehearing and clarification of FERC’s landmark final rule on transmission planning and cost allocation issued in May 2024. While the Commission largely affirmed the final rule, the order grants rehearing of some of the more controversial aspects of Order No. 1920.

...

Read More

Speaking Energy

August 7, 2024

*Thank you to JaKell Larson, 2024 Akin Summer Associate, for her valuable collaboration on this article.

...

Read More

Speaking Energy

July 31, 2024

Interstate oil, liquid and refined products pipelines regulated by the Federal Energy Regulatory Commission (FERC) will soon be able to raise their transportation rates (provided they were set using FERC’s popular Index rate methodology) in the wake of a significant new decision by the District of Columbia Circuit (the D.C. Circuit) in Liquid Energy Pipeline Association v. FERC (LEPA).

...

Read More

Speaking Energy

July 29, 2024

On Wednesday, July 24, 2024, the U.S. House of Representative Committee on Energy and Commerce held a Subcommittee on Energy, Climate, and Grid Security hearing to review the Federal Energy Regulatory Commission (FERC or Commission) Fiscal Year 2025 Budget Request. Members of the Subcommittee had the opportunity to hear testimony from all five Commissioners, including FERC Chairman Willie Phillips and Commissioner Mark Christie, as well as the three recently confirmed commissioners, David Rosner, Lindsay See and Judy Chang. In addition to their prepared remarks, the five commissioners answered questions on FERC’s mandate to provide affordable and reliable electricity and natural gas services nationwide, while also ensuring it fulfills its primary mission of maintaining just and reasonable rates.

...

Read More

Speaking Energy

July 29, 2024

On July 9, 2024, the U.S. Court of the Appeals for the D.C. Circuit held that the Federal Energy Regulatory Commission (FERC or the Commission) erred in ordering refunds for certain bilateral spot market transactions in the Western Energy Coordinating Council (WECC) region that exceeded the $1,000/megawatt-hour (MWh) “soft” price cap for such sales.1 Finding FERC failed to conduct a “Mobile-Sierra public-interest analysis” before “altering” those contracts by ordering refunds, the court vacated FERC’s orders and remanded the case to FERC for further proceedings.2

...

Read More

Speaking Energy

July 8, 2024

On June 28, 2024, in Loper Bright Enterprises v. Raimondo, the U.S. Supreme Court overruled Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., which for 40 years required court deference to reasonable agency interpretations of federal statutes in certain circumstances, even when the reviewing court would read the statute differently. The Court ended “Chevron deference” and held that courts “must exercise their independent judgment in deciding whether an agency has acted within its statutory authority.” In doing so, the Court upended a longstanding principle of administrative law that is likely to make agency decisions more susceptible to challenge in the courts.

...

Read More

© 2024 Akin Gump Strauss Hauer & Feld LLP. All rights reserved. Attorney advertising. This document is distributed for informational use only; it does not constitute legal advice and should not be used as such. Prior results do not guarantee a similar outcome. Akin is the practicing name of Akin Gump LLP, a New York limited liability partnership authorized and regulated by the Solicitors Regulation Authority under number 267321. A list of the partners is available for inspection at Eighth Floor, Ten Bishops Square, London E1 6EG. For more information about Akin Gump LLP, Akin Gump Strauss Hauer & Feld LLP and other associated entities under which the Akin Gump network operates worldwide, please see our Legal Notices page.