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`UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
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`Docket No. RM21-17-000
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`18 CFR Part 35
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`Building for the Future Through
`Electric Regional Transmission
`Planning and Cost Allocation
`and Generator Interconnection
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`COMMENTS OF THE PRYSMIAN GROUP
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`The Prysmian Group (Prysmian) appreciates the opportunity to comment on the Federal Energy
`Regulatory Commission’s April 21, 2022 Notice of Proposed Rulemaking (“NOPR”) in the above-captioned
`proceeding. As a worldwide leader in developing, manufacturing, and installing the cables and conductors
`for power transmission and with 20 factories located in the United States, we are both a large industrial user
`of electricity and a technology provider to transmission service providers. As an industrial user, energy costs
`make up a substantial portion of our operating expenses. As such, we applaud the consideration of advanced
`transmission technologies such as dynamic line rating and power flow control in regional transmission
`planning as these technologies can serve to cost effectively enable more capacity from existing transmission
`lines. The NOPR requests comment on additional transmission technologies that should be considered in
`regional transmission planning. As a leader in transmission technologies we are continually investing to
`develop solutions that allow transmission lines to operate more efficiently and reliably. Prysmian would
`encourage consideration of two additional transmission technologies. First, we encourage consideration of
`the reconductoring of existing transmission lines where higher capacity advanced conductors can replace
`existing legacy conductors. Instead of building new lines, reconductoring existing structures with advanced
`conductors with heat dissipating coatings can typically double the capacity of older lines. Reconductoring
`has been performed for decades and with the advent of advanced conductors with heat dissipating coatings,
`existing structures can typically be reused with little to no modification. We encourage reconductoring to be
`considered as an option in all regional planning. Secondly, we encourage consideration of the process of
`retrofitting heat dissipating coatings on existing transmission lines. These durable coatings can be applied
`robotically to installed lines and act to both reduce solar heating and to increase the heat emitted from the
`conductor. Static, ambient adjusted, or dynamic line ratings can be increased by as much as 25%. This
`increase in capacity is relatively easy to model, requiring modification to only two variables in line rating
`calculations. It also leads to more accurate line ratings because assumed rating variables are replaced by
`tested values. Prysmian’s trade name for a heat dissipating coating is E3X® and has been used on dozens of
`utility projects to increase capacity of transmission lines. Prysmian encourages that in additional to dynamic
`line rating and power flow controls, advanced conductors for reconductoring and heat dissipating coatings
`also be considered to cost effectively and quickly increase capacity of the existing grid.
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`Respectfully Submitted,
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`Joseph Coffey
`Director of Transmission
`Prysmian Group
`4 Tesseneer Drive
`Highland Heights, KY 41076
`Joseph.coffey@prysmiangroup.com
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