On a napkin
Why transmission takes 10+ years — and what Order 1920 changes Typical major transmission line — 10–15 years Planning 2–4 yrs Siting + permits 3–5 yrs NEPA review 2–3 yrs Litigation 0–3 yrs Construction 2–3 yrs ←————— process, not physical work ——————→ FERC Order 1920 (May 2024) + 1920-A (Nov 2024) + 1920-B (Apr 2025) Long-term planning 20-yr horizon ≥3 distinct scenarios Iterative reassessment Right-sized replacements "Anticipate, don't react" Grid-enhancing tech Dynamic line ratings Advanced power flow ctrl Advanced conductors Topology optimization Cheaper than new lines Cost allocation 7 benefit categories State engagement (6 mo.) Beneficiary-pays bias Backstop fallback Resolves who paysBuilding a major new transmission line in the United States typically takes 10-15 years from concept to commercial operation. Actual construction takes only 2-3 years — the rest is process: regional planning, siting and permitting (split across state and federal agencies), NEPA environmental review on federal lands, litigation, and cost allocation disputes. The grid we need to support data center load growth, electrification, and renewable integration cannot be built within these timelines. FERC Order 1920, issued May 2024, is the most significant attempt in over a decade to fix the planning piece of this problem.
Order 1920 is about planning, not permitting. It forces ISOs and transmission owners to plan for the long-term grid we actually need rather than reactively responding to interconnection requests. It does not change federal or state permitting authority, which remains the harder problem. Order 1977, issued alongside 1920, provides FERC limited backstop siting authority for certain projects designated as nationally significant — a narrower tool than the comprehensive permitting reform the grid arguably needs.
The US has approximately 2,600 GW of generation projects in interconnection queues — more than three times the country's current installed capacity. Most of this queued capacity cannot connect because the transmission system can't accommodate it. The same physical bottleneck constrains the ability to deliver power from low-cost wind and solar resources in the Plains and Southwest to load centers in the Northeast and California. The cost of inadequate transmission shows up as congestion — wholesale electricity prices vary by hundreds of dollars per MWh across short distances, generators are curtailed when they could otherwise produce, and consumers in constrained zones pay more than they should.
Why hasn't transmission been built? Multiple intersecting barriers: regional planning processes have historically not anticipated long-term needs (FERC's previous Order 1000 framework was reactive rather than forward-looking). Cost allocation disputes — when a transmission line benefits ratepayers across multiple states, getting the states to agree on who pays the bill has been politically intractable. NEPA review on federal lands routinely takes 2-3 years. State siting authority is fragmented (some states have centralized siting, many do not). And opposition from affected landowners, communities, and environmental groups (sometimes for legitimate reasons, sometimes through opportunistic litigation) can delay projects by years.
The Order issued May 13, 2024 imposes four major reforms on FERC-jurisdictional transmission providers. First, long-term regional transmission planning over a minimum 20-year horizon, using at least three distinct scenarios incorporating plausible future conditions. This replaces the prior reactive approach where transmission planning responded primarily to current-cycle interconnection requests and near-term reliability needs. Second, formal consideration of seven categories of benefits when evaluating transmission needs — including reliability, economic, resilience, and policy benefits — broadening the analytical framework beyond traditional load growth and reliability.
Third, mandatory consideration of grid-enhancing technologies (GETs) as alternatives or complements to new lines. These technologies — dynamic line ratings, advanced power flow control devices, advanced conductors, and topology optimization — can substantially increase the capacity of existing transmission infrastructure at a fraction of the cost and time required to build new lines. Fourth, structured cost allocation methodologies with a six-month state engagement period and ex ante "backstop" methods that take effect if states cannot agree. Order 1920-A (November 2024) enhanced state regulatory involvement in planning and cost allocation; Order 1920-B (April 2025) further refined timing of the first planning cycle.
Compliance filings to comply with most of Order 1920's requirements were due June 12, 2025, with interregional coordination filings due August 12, 2025. ISOs and transmission providers submitted compliance plans throughout 2025 and into 2026 — NYISO, ISO-NE, PJM, MISO, SPP, and CAISO are all working through their respective compliance processes. NYISO's TPAS process in April 2026 outlined detailed implementation including right-sized replacement evaluation and formal reevaluation triggers. The first long-term planning cycles will begin in 2026-2027, with actual transmission projects emerging from these processes in the late 2020s. Real-world impact on the grid won't fully materialize until the early 2030s.
One critical legal uncertainty: the Supreme Court's 2024 decision in Loper Bright Enterprises v. Raimondo overturned the Chevron doctrine, which had required courts to defer to reasonable agency interpretations of statutes. Order 1920 was issued under FERC's section 206 authority under the Federal Power Act, and legal challenges to the Order's scope are pending. Without Chevron deference, courts will independently determine whether Order 1920 exceeds FERC's statutory authority — creating meaningful litigation risk that could delay or modify implementation.
Order 1920 fixes planning. It does not fix siting, permitting, NEPA, or eminent domain. These remain the harder problems, requiring congressional action or state-level reform. Order 1977 provides FERC limited backstop siting authority for projects designated as nationally significant in DOE-designated National Interest Electric Transmission Corridors — but the scope is narrow and use of eminent domain by FERC is politically sensitive. Bipartisan permitting reform legislation has been discussed in Congress through 2024-2025 but has not advanced to enactment, partly because of disagreements about whether reform should accelerate clean energy transmission, fossil fuel pipelines, or both.
For commercial and industrial buyers, the implications are mixed. Order 1920 should eventually reduce congestion costs and improve resource adequacy in load-constrained regions — but the timeline is measured in years, not months. In the interim, transmission constraints will continue to push up capacity prices in PJM, NYISO, and ISO-NE, drive nodal price volatility, and constrain interconnection of new generation. Companies considering new large loads (data centers, manufacturing, hydrogen) should expect transmission access to be a multi-year process, with siting decisions increasingly driven by where transmission capacity already exists rather than where it ought to be.
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