Defensibility by design: What FERC Order 1920 requires

There is little debate about the transmission system's importance in meeting America’s rapidly growing electricity demand.

Long-term planning for new infrastructure to address increasing demand and more frequent extreme weather calls for tools and methods that better accommodate today’s electric system and the uncertainties in its evolution. A lack of needed high-capacity lines, growing congestion, rising costs and delays can result from the difficulty to effectively plan for the future electric system.

The Federal Energy Regulatory Commission’s (FERC) Order 1920 aims to ensure the long-term planning needed to develop and build the necessary transmission infrastructure takes place regularly and consistently, and considers a rigorous set of scenarios that reflect the full range of pressures shaping the grid’s future, from data center load growth to the increasing penetration of renewable generation.

Finalized in 2024 after three years of development and stakeholder feedback, FERC Order 1920 requires transmission operators to:

• Conduct long-term regional transmission planning over a minimum 20-year horizon
• Update plans at least every five years
• Use a plausible and diverse set of at least three scenarios using the best available data
• Consider the use of grid-enhancing technologies and the potential to “right-size” aging infrastructure rather than replace it

Planning decisions that are transparent, explainable, and defensible

A planning platform built for defensibility

Meeting FERC Order 1920’s requirements demands a planning infrastructure capable of managing complexity, maintaining consistency across distinct yet interdependent workflows, and ultimately producing results that withstand scrutiny from regulators, states and other stakeholders.

GE Vernova’s PlanOS software platform and Consulting Services are developed to do just that. The foundation of the integrated planning PlanOS allows is a common data environment. This allows production cost modeling, resource adequacy analysis, capacity expansion, and power flow studies to all be run using a single, shared model of the power system. This removes the need to manually reconcile separate data sets used by different planning tools. The use of a single, shared model vastly improves visibility into the data, the assumptions used and any changes that occurred between studies.

There’s another important advantage that flows from different workflows sharing a common foundation: the ability to do genuinely integrated analysis. For example, planners can determine new asset siting and calculate resource adequacy and nodal production cost within an expansion analysis itself, rather than separately, enabled by reimagining the system with a common data model. A more holistic approach allows simultaneous assessment of economics, reliability and policy, rather than separate workflows followed by reconciliation.

That integration is especially important when addressing FERC Order 1920’s requirement to perform scenario analysis across a 20-year planning horizon. For instance, system operators running multiple scenarios will typically produce widely divergent future generation mixes. This poses a dilemma for decision-makers. Which scenario should drive investments?

PlanOS addresses this uncertainty with a stochastic capacity expansion feature that develops multiple plausible futures, assigns probability weights to each, and then enhances them simultaneously rather than sequentially. A traditional capacity expansion study builds a plan around a single scenario. By contrast, a stochastic analysis considers a range of plausible futures to identify the best action to take right now. “The goal is to identify the best possible step to take right now that will eventually meet all the economic, policy, and other requirements across all the plausible futures rather than showing only edge case outcomes,” Meyer said.

Where software provides the structure, consistency, and traceability that FERC Order 1920 requires, GE Vernova’s Consulting Services provide an essential layer of judgment and industry expertise. That means helping develop assumption governance frameworks, stress testing results before they go in front of regulators and translating planning outcomes to be clear to all planning stakeholders.

Formal FERC Order 1920 compliance deadlines will phase in over the next few years. But what the order has already done is force a change in planning expectations, particularly about how planning decisions get made and communicated. Embracing the tools and processes FERC Order 1920 requires isn’t just about compliance. “When the stakes are this high, defensibility isn’t optional,” Meyer said. “It’s completely necessary.”

Learn how GE Vernova's Consulting Services can help your organization build transparent, defensible transmission plans aligned with FERC Order 1920 requirements.