On November 21, 2024, FERC issued Order No. 1920-A, which modified Order No. 1920 to expand the states’ roles in long-term transmission planning and clarified requirements for such planning as set forth in Order No. 1920. FERC made changes in three broad areas, amongst many other modifications: (1) expanding the role of state entities in the transmission planning process, (2) requiring transmission providers to create additional transmission planning scenarios to inform implementation of cost allocation methods upon the request of state entities, and (3) removing the requirement for transmission providers to include corporate financial commitments in Factor Category Seven when developing long-term transmission planning scenarios.
FERC’s Order No. 1920, issued on May 13, 2024, modified FERC’s policies on transmission planning and associated cost allocation, and set requirements for the states’ involvement in such planning processes. Chief among those reforms is requiring the development of long-term transmission planning and cost allocation processes, to account for various scenarios over the course of a 20-year planning horizon. As for state involvement, Order No. 1920-A requires transmission providers to include input from state entities into their planning scenarios. This input shall include how the scenarios are developed and how such scenarios will help satisfy each state’s policies.
Separately, Order No. 1920-A clarified that Order No. 1920’s requirement for transmission providers to develop three long-term planning scenarios can be expanded if a state entity requests additional planning scenarios. Order No. 1920-A also required transmission providers to consult with the states on how their applicable state policies will be affected by such scenarios and permitted states to request a six-month extension of the engagement period.
Next, Order No. 1920-A slightly modified Order No. 1920’s requirement for including seven categories of factors for analysis within the long-term transmission planning scenarios. Category Seven, labeled as “utility and corporate commitments and federal, state, and local goals affecting resource mix and demand” in Order No. 1920, now no longer requires the consideration of corporate commitments because FERC determined such commitments may favor certain projects over others.
Finally, FERC addressed several other comments raised by stakeholders. For example, FERC denied application of the major questions doctrine to this order, noting that authority to grant this order is within FERC’s jurisdiction under the Federal Power Act. Separately, FERC added criteria for planning in coordination with the interconnection of new generation.
This order was approved by three Commissioners. Commissioner See did not participate. Commissioner Christie concurred in part, noting in an appendix to Order No. 1920-A that he agreed with the above changes, which provide the states more input into the long-term transmission planning process.
Requests for rehearing of Order No. 1920-A are due December 23, 2024. A copy of Order No. 1920-A, issued in Docket No. RM21-17-000, can be found here.