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As electricity demand grows and the grid becomes more complex, transmission planning now faces more uncertainty. In response to these challenges, FERC Order 1920 introduces new requirements for long-term regional transmission planning.

These challenges are being driven by rising electricity demand from data centers, electrification, and industrial development. At the same time, utilities and system operators must account for the changing generation mix, aging infrastructure, reliability concerns, and more frequent extreme weather events. Together, these trends have made transmission planning assumptions less certain and increased the complexity of identifying and building cost-effective transmission solutions.

The Federal Energy Regulatory Commission’s (FERC) Order 1920 was created in response to these challenges. It establishes new requirements for long-term regional transmission planning and a more structured framework for evaluating transmission investments. The order also addresses limitations of historical planning approaches, which often focused on shorter-term needs and made it difficult to identify investments with significant long-term value.

As John Meyer, who worked at the New York Independent System Operator before joining GE Vernova's Consulting Services as a technical director, explains, "Effective transmission planning and stakeholder consensus on transmission development projects have become more complex in recent years."

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What is FERC Order 1920?

FERC Order 1920 is a rule issued by the Federal Energy Regulatory Commission (FERC) that establishes new requirements for long-term regional transmission planning across the United States.

The goal is to help transmission providers identify long-term reliability and economic needs earlier through coordinated transmission investments and planning studies that look decades into the future rather than focusing primarily on near-term needs. The order applies to FERC-jurisdictional transmission providers operating under an Open Access Transmission Tariff (OATT). It covers most of the contiguous United States, with Electric Reliability Council of Texas (ERCOT) being the primary exception.
 

What are the key requirements of FERC Order 1920?

The order introduces several significant requirements for long-term regional transmission planning.
Some key requirements include:

  • A planning horizon of at least 20 years
  • Updates to planning studies at least every five years
  • Evaluation of at least three plausible future scenarios
  • Consideration of grid-enhancing technologies
  • Evaluation of right-sizing opportunities when replacing infrastructure
  • Sensitivity analysis and stress testing of planning assumptions
  • Assessment of regional transmission solutions
  • Development of a transparent cost-allocation framework

Rather than relying on a single forecast, planners are expected to evaluate how different futures could affect transmission investment decisions.
 

Why is uncertainty a major challenge under FERC Order 1920?

According to Meyer, "The most difficult thing to deal with in long-term planning is uncertainty, because from one scenario to the next, say high-to-low load growth or levels of renewable generation build, the outcome after 20 years can vary widely."

Looking 20 years into the future means evaluating futures that may differ significantly in load growth, resource mix, technology adoption, and policy priorities. For example, one scenario may assume rapid load growth driven by data center development and electrification, while another assumes slower economic growth and more moderate electricity demand. Both outcomes may be possible over a 20-year planning horizon.

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This makes planning more difficult. A transmission investment that appears to be the best choice under one scenario may be less attractive under another.

The goal is not to predict the future perfectly. Instead, planners need to find solutions that can provide value across a range of different futures while balancing reliability, economics, and policy objectives.
 

How does FERC Order 1920 change transmission planning?

FERC Order 1920 increases both the amount of planning required and the accountability for planning decisions.

In the past, planning studies were often developed for technical audiences. Under the new framework, planners must also be prepared to explain their assumptions, methodologies, and recommendations to:

  • Regulators
  • Policymakers
  • Utilities
  • Consumer advocates
  • And other stakeholders

As transmission projects move from engineering studies into regulatory and policy discussions, planning teams must be able to clearly explain why a project was selected and how conclusions were reached.

Meyer emphasizes the importance of defensible planning decisions: "It is critical to come out communicating a non-ambiguous solution or options that are understandable and can be explained pragmatically."

In practice, this means producing planning results that are transparent, repeatable, and understandable to both technical and non-technical stakeholders. Read Defensibility by design: What FERC Order 1920 requires to learn more about what FERC Order 1920 requires from long-term transmission planners and how defensible, transparent planning methods can help utilities meet regulatory expectations.

Why do traditional transmission planning processes struggle with FERC Order 1920?

Many organizations still rely on separate tools, datasets, and workflows for different planning activities.

Power flow studies, resource adequacy analysis, production cost modeling, reliability assessments, and transmission expansion studies have traditionally been performed using different software platforms and often by different teams. Meyer explains that these silos developed naturally over time as different planning disciplines evolved independently.

But this way of planning can lead to inconsistent assumptions, duplicate work, and planning results that are difficult to match up. For example, a single change in a load forecast or resource assumption may require multiple planning teams to manually update separate models, increasing the chance of delays and inconsistent results.

Today, however, long-term planning increasingly requires those disciplines to work together. FERC Order 1920 means planners now must look at more scenarios, handle greater uncertainty, and work closely across planning functions. Under FERC Order 1920, planners must connect economic and reliability considerations into a single planning framework. That makes collaboration and consistency more important than ever.

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Integrated planning playbook

Want to learn more about why planning silos no longer work?

As the grid transforms, decisions made in isolation create financial and reliability challenges. Drawing on real-world utility challenges, this playbook examines how shared data, aligned assumptions, and integrated planning workflows help utilities move faster and invest with confidence.

How can Integrated Systems Planning help meet FERC Order 1920 requirements?

As planning requirements become more complex, many organizations are moving towards Integrated Systems Planning.

Integrated Systems Planning helps teams:

  • Maintain consistency across studies
  • Improve visibility into assumptions and results
  • Reduce manual reconciliation between tools
  • Evaluate multiple scenarios more efficiently
  • Improve transparency for stakeholders
  • Strengthen confidence in planning recommendations

Most importantly, Integrated Systems Planning creates a clearer connection between planning data, analysis, and final recommendations.
 

What does FERC Order 1920 compliance look like in practice?

Compliance is about more than completing required studies. Organizations must establish repeatable planning processes that support long-term scenario analysis and provide sufficient documentation for stakeholder and regulatory review. Transmission providers must file compliance plans with FERC. Following FERC approval of those filings, providers will follow new planning requirements in accordance with region-specific timelines.

While formal deadlines will continue to phase in over the coming years, many organizations are already developing the frameworks, processes, and analytical tools they need to meet the order's requirements.
 

How does PlanOS support FERC Order 1920?

GE Vernova’s PlanOS is an Integrated Systems Planning platform that connects power flow, resource adequacy, production cost, and capacity expansion workflows through a common data environment. By improving consistency across studies and reducing manual reconciliation between planning activities, PlanOS helps organizations evaluate scenarios more efficiently and support the transparency and defensibility requirements introduced by FERC Order 1920.
 

Preparing for FERC Order 1920

FERC Order 1920 represents a significant shift toward long-term, scenario-based transmission planning. To meet its requirements, organizations will need to evaluate uncertainty more carefully, connect planning disciplines more effectively, and clearly support the decisions behind transmission investments. While implementation timelines continue to evolve, many organizations are already building the processes and analytical capabilities needed to comply and plan for a fast-changing grid. Find out how GE Vernova’s Consulting Services can help your organization build transparent, defensible transmission planning using PlanOS to support FERC Order 1920 and long-term grid planning objectives. 

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