Last May, the Federal Energy Regulatory Commission issued Order No. 1920, a landmark order requiring all transmission providers to engage in multi-value long-term regional transmission planning. The order grants states significant opportunities to engage in this process. In December, the Commission issued Order No. 1920-A, responding to issues raised on rehearing (where parties can argue that the Commission should have ruled differently on specific issues in the final order). Order No. 1920-A expanded the role of states in the planning process. Since then, all the multi-state RTO/ISO regions have requested extensions, giving states and transmission providers additional time to craft compliance plans. States can use this extra time to work together to identify priorities and reach alignment on key questions raised by the order.

Below, we outline the key decisions and actions states can take to influence compliance and to engage in implementation once the planning process begins.

Decisions and Actions States Can Take on Compliance

Order 1920 and 1920-A give states numerous opportunities to either influence or directly develop proposals for components of compliance filings and requires that transmission providers support a six-month “state engagement period” that allows states to align on cost allocation. If states come to agreement, the transmission provider must file it at FERC. Key steps that states can take during the compliance process include:

1. Identify key milestones and deadlines. With extensions granted in most regions, the first step states must take is to identify relevant deadlines and interim milestones. Below is a cheat sheet of where things currently stand for each planning region: 
   
   

   Region	Compliance Deadline	End of State Engagement Period
   CAISO	December 12, 2025 (approved)	Through November 1, 2025
   ISO-NE	June 2027	~Through March 2027
   MISO	June 12, 2026	Through March 11, 2026
   NYISO	April 30, 2026; June 14, 2027 for interregional coordination (approved)	Through ~March 2026
   PJM	December 12, 2025 (approved)	Key engagement through August 15, 2025 – limited through October 31, 2025
   SPP	June 12, 2026 (Pending); August 12, 2025 for interregional coordination	Through November 3, 2025 (Pending)
   NorthernGrid and WestConnect (non-RTO West)	December 12, 2025 (approved)	Through ~end of October
   SCRTP/SERTP (Southeast)	June 12, 2026; August 12, 2026 for interregional coordination (approved)	Through ~ March 10, 2026
   FRCC (Florida)	June 12, 2026; August 12, 2026 for interregional coordination (approved)	Through Spring, 2026

    

2. Reach internal alignment within the state and as a region on roles and responsibilities for engagement. States must determine which entities and individuals should engage in the regional state engagement process, and the states collectively must decide what regional entity will coalesce states. For example, states in the PJM region have created a new committee of the Organization of PJM States, Inc. (OPSI) for the purpose of engaging on Order No. 1920. This new committee, the PJM Area Relevant State Entities Committee (PARSEC), has designated agencies and voting representatives from each PJM state, but is open to “any State entity responsible for electric utility regulation or siting electric transmission facilities within the PJM region.” States will need to identify what other entities will participate in the PARSEC and/or provide input into the decisions and votes of the PARSEC voting representative. 
   
   
3. Engage on cost allocation decisions. The process of determining how the costs of regional transmission facilities should be split among the states that comprise the region is perhaps the most important role given to states under Order No. 1920. States have the option to align on an ex-ante cost allocation method and/or develop a state agreement process by which they would come together to determine cost allocation after a transmission facility or portfolio of facilities has been identified. Transmission providers are required to have at least one ex-ante cost allocation approach on file to ensure that there is a way to pay for any transmission facilities selected as part of a regional plan. Transmission providers are also required to file at FERC any cost allocation method and/or state agreement process that states have agreed to. If states want a say in how the bill for transmission projects is split, they are therefore best served by coming together to align on a method and/or process to be filed at FERC. States must first collectively align on some procedural questions, such as what constitutes “agreement,” and what public information sharing and feedback opportunities they will incorporate throughout the state engagement period. Then they must align on an actual cost allocation method and/or state agreement process, balancing considerations such as fairness, accuracy, ease of implementation, and alignment with the objective of advancing the most cost-beneficial transmission facilities.
   
   
4. Weigh in on key elements of the long-term regional transmission planning process. Order No. 1920 prescribes a framework and certain requirements for the new long-term regional transmission planning process but leaves many decisions to the discretion of the regions. States can weigh in on how key steps in the planning process will be undertaken to ensure a robust role for states and other stakeholders when the planning process gets underway. These include but are not limited to the process for transmission providers to consult states on scenario development and for states to request additional analyses or scenarios; measurement of benefits and identification of any additional benefits to evaluate; the evaluation process and selection criteria for facility selection, including evaluation of Alternative Transmission Technologies (ATTs); the process for voluntary funding of (a portion of) certain transmission facilities that would not otherwise meet selection criteria; and enhancements to the transparency of local transmission planning as an input to regional planning. 

States and regions that follow these steps will end up with a long-term regional transmission planning process that centers states throughout the analysis, facility selection, and cost allocation processes.

Decisions and Actions States Can Take When the Planning Process Goes Live

While engaging in the compliance process is critical to ensure a process that centers states as critical decision-makers, states must engage actively in the planning process itself to successfully influence regional transmission infrastructure outcomes. To do so, states should take the following actions: 

1. Participate in scenario development. State input into scenario development is particularly critical to ensure that relevant state regulations, laws, integrated resource plans, and other factors impacted by state needs or actions are taken into account. States can also work together to request additional scenarios or analyses to inform cost allocation. 
   
   
2. Evaluate assessment of benefits and selection decisions for transmission facilities and/or portfolios. Transmission providers are required to publish information about benefit assessments, selection decisions, and determinations regarding use of ATTs. States should carefully review and provide input into these determinations to ensure final decisions that are in the best interest of the state and region. 
   
   
3. Engage in cost allocation discussions. To the extent that states develop a state agreement process as an alternative to the regional ex ante cost allocation method on file, all states in the region will need to engage actively in this process. Individual states or groups of states can also determine whether to pursue voluntary funding of (a portion of) a transmission facility not otherwise selected by the transmission provider. For example, if a state or group of states places higher value on a transmission facility that did not pass the regional selection criteria, they may decide to pay the incremental cost for the incremental benefit they would receive. 
   
   
4. Participate in local planning input sessions and feedback opportunities. Recognizing the interrelatedness of local and regional planning, FERC in Order No. 1920 required a series of stakeholder meetings with related comment opportunities for discussion of local planning assumptions, needs, and solutions. This process is intended to increase transparency and provide opportunities to identify where facility replacements or local projects identified in local planning could be met more cost-effectively through regional projects or right-sizing. This, especially if combined with other reforms, has the potential to rein in spending on local projects—a significant and growing component of transmission costs. However, it could amount to little more than a box-checking exercise without robust participation by states and stakeholders.

States and regions that foster active state engagement in the planning process will develop scenarios that better reflect states’ collective perspectives, select transmission facilities that maximize net regional benefits, and ultimately build out regional transmission infrastructure that is more aligned with regional needs. The process may be messy—states have a range of different priorities and perspectives—but the results will be worth the work.

Advanced Energy United has compiled an Order No. 1920 Resource Hub to inform states and stakeholders as they engage on compliance. The Resource Hub includes a summary of Order No. 1920 and 1920-A that calls out the specific role given to states, a checklist for state officials outlining the decisions they must make and the opportunities for input, and regional summaries detailing the difference between current rules and Order No. 1920 requirements for ISO-NE, PJM, MISO, and SPP (the four regions where Advanced Energy United’s policy team is actively engaged in advocacy on Order 1920 and other issues). We’ll be adding additional resources to the Resource Hub in the coming months, so check back for more!