Order 1920 Enters Compliance, Elevates States’ Role

Nov. 18, 2025 — Washington, D.C. — FERC’s landmark transmission‑planning rule, Order 1920, has moved from policy to execution. The Commission published a staggered compliance schedule—two filings per planning region—and outlined a formal state‑engagement window that will shape who pays for long‑distance lines over the next decade. For utility‑scale renewables, this is the pivotal rule that determines when—and whether—new solar and storage can actually connect at scale. (Federal Energy Regulatory Commission)

At its core, the rule requires 20‑year, scenario‑based regional plans refreshed every five years, explicit evaluation of benefits, and provisions to right‑size rebuilds so utilities add capacity when replacing aging equipment. In short: plan earlier, plan bigger, and quantify the value more rigorously. (Federal Energy Regulatory Commission)

Rehearing orders 1920‑A and 1920‑B tightened the governance. They expanded state authority in cost allocation, created a six‑month “Engagement Period” (extendable to 12 months at state request), and pushed the first long‑term planning cycle start to no later than two years after initial compliance filings—giving regions time to build consensus without losing momentum. (Federal Energy Regulatory Commission)

Deadlines now matter. FERC’s schedule shows, for example, PJM and CAISO first filings due Dec. 12, 2025; MISO, SPP and SERTP by June 12, 2026; NYISO by April 30, 2026; and ISO‑NE by June 14, 2027. Each region also owes a second filing focused on interregional coordination. The clock is running, and slippage will be visible. (Federal Energy Regulatory Commission)

The rule also links planning to interconnection pain points. Regions must address “needs that arise repeatedly” in generator interconnection and consider grid‑enhancing technologies (dynamic ratings, topology control) that unlock capacity sooner—key to reducing curtailment and easing queue congestion for solar‑plus‑storage. (California Independent System Operator)

Bottom line: Order 1920 is the operating manual for the next build‑out. It centralizes long‑term transmission planning, formalizes state leverage over cost shares, and sets firm timetables. For sponsors, the practical work is engagement: track your region’s compliance docket, align project siting with 20‑year scenarios, and model benefit‑cost outcomes that will compete for selection in the new regional plans. (NASEO)


Sources

  • FERCOrder No. 1920 Compliance Filings Schedule (two‑stage filings; state Engagement Period and extensions; region‑specific deadlines), June 16, 2025. (Federal Energy Regulatory Commission)
  • FERCFact Sheet: Building for the Future Through Electric Regional Transmission Planning and Cost Allocation (20‑year planning, benefits, right‑sizing), May 13, 2024. (Federal Energy Regulatory Commission)
  • FERCOrder 1920‑A and 1920‑B overviews (expanded state role; two‑year start for first cycle), Nov. 21, 2024 and Apr. 22, 2025. (Federal Energy Regulatory Commission)
  • NASEOOrder 1920 Explainer (scenarios, seven benefits, cost‑allocation engagement), 2024–2025. (NASEO)
  • CAISOOrder 1920 Compliance Presentation (address repeated interconnection needs; consider GETs), Sept. 18, 2025. (California Independent System Operator)
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