Presentation Order 1920A

HEADLINES

Presentation | Order No. 1920-A, Building
for the Future Through Electric Regional
Transmission Planning and Cost Allocation
November 21, 2024

Order 1920-A | News Release | Chairman Phillips' Statement Concerning Order No. 1920 |
 Explainer on Order No. 1920 | News Release Order 1920
Good morning, Chairman Phillips and Commissioners,
Item E-1 is Order No. 1920-A, a draft order on rehearing and clarification of Order No. 1920,
Building for the Future Through Electric Regional Transmission Planning and Cost Allocation. 
Order No. 1920-A largely sustains the requirements of Order No. 1920, which, pursuant to
section 206 of the Federal Power Act, reformed the Commission’s regional transmission
planning and cost allocation processes to require transmission providers to conduct LongTerm Regional Transmission Planning.  Nevertheless, in some instances, the draft rehearing
order agrees with certain arguments raised on rehearing and clarification, and in those
instances it clarifies the meaning of Order No. 1920 or modifies the discussion and sets aside
Order No. 1920, in part.  Staff will turn to these modifications shortly.
On May 13, 2024, the Commission issued Order No. 1920.  The reforms adopted in Order No.
1920 remedy deficiencies in the existing transmission planning requirements to ensure that
Commission-jurisdictional rates remain just and reasonable and not unduly discriminatory or
preferential.  The Commission initially considered these reforms in its July 2021 Advanced
Notice of Proposed Rulemaking, later issued an April 2022 Notice of Proposed Rulemaking that
proposed specific reforms, and then issued Order No. 1920.  In response to Order No. 1920, the
Commission received 49 timely filed requests for rehearing and clarification that raise issues
related to nearly all the reforms adopted in Order No. 1920. 
Order No. 1920-A provides a number of clarifications on the required reforms and, in some
instances, sets aside, in part, Order No. 1920 requirements in response to arguments made on
rehearing.  For example, Order No. 1920-A further enhances the role of Relevant State Entities
in Long-Term Regional Transmission Planning, especially their role in shaping scenario
development and cost allocation.  Order No. 1920-A requires transmission providers to
incorporate state input about how future scenarios used in Long-Term Regional Transmission
Planning will be developed, given that the scenarios will necessarily reflect how the states plan
to meet their laws, policies, and regulations.  Order No. 1920-A also requires transmission

providers to include in the transmittal or as an attachment to their compliance filings any ex
ante cost allocation method or State Agreement Process agreed to by the Relevant State
Entities, even if the transmission provider chooses not to propose the method or process in
compliance with Order No. 1920.  Transmission providers must include in their compliance
filings any information related to Relevant State Entities’ agreed-upon cost allocation method
or State Agreement Process that Relevant State Entities request that transmission providers
include on compliance.  Order No. 1920-A makes clear that the Commission will consider the
entire record—including the Relevant State Entities’ agreed-upon cost allocation method or
process and a transmission provider’s proposal, should they differ.  The Commission may
adopt any cost allocation method or process proposed by the Relevant State Entities and
submitted on compliance, so long as it complies with Order No. 1920 and the cost causation
principle.
Order No. 1920-A further clarifies that, if Relevant State Entities request additional time to
complete cost allocation discussions, the Commission will extend the Engagement Period for
up to an additional six months to ensure that Relevant State Entities have sufficient time to
engage in fulsome discussions.  Relatedly, in the event of such an extension to the Engagement
Period, Order No. 1920-A also provides that the Commission will extend the relevant Order No.
1920 compliance deadlines.
Going beyond the compliance stage, Order No. 1920-A requires transmission providers to
consult with Relevant State Entities before amending their Long-Term Regional Transmission
Cost Allocation Method or State Agreement Process or Processes that is on file with the
Commission, or later, if Relevant State Entities seek for the transmission provider to amend the
method or process consistent with their chosen method to reach agreement.  In an effort to
increase transparency, Order No. 1920-A requires that transmission providers post on a public
website the results of their consultations with Relevant State Entities before filing such an
amendment, and explain why they have chosen not to propose any amendments preferred by
Relevant State Entities.  These requirements will further ensure that states have the
opportunity for increased involvement in establishing cost allocation methods for Long-Term
Regional Transmission Facilities beyond the Order No. 1920 compliance stage. 
Next, Order No. 1920-A clarifies that, while transmission providers must develop three LongTerm Scenarios that meet all of the requirements adopted in Order No. 1920, transmission
providers may develop additional scenarios to provide Relevant State Entities with information
that they can use to inform the development of Long-Term Regional Cost Allocation Methods
or State Agreement Processes.  Transmission providers have the flexibility to depart from Order
No. 1920’s requirements related to the development of the required Long-Term Scenarios
while developing these additional, optional scenarios.  Order No. 1920-A requires that if
Relevant State Entities request additional scenarios to inform their consideration of cost
allocation methods, transmission providers must develop a reasonable number of those
scenarios.  As long as transmission providers engage in the robust planning process and meet

transparency requirements, transmission providers are free to develop and consider additional
information beyond what is required under Order No. 1920.   
Order No. 1920-A also sets aside, in part, the requirement to use seven categories of factors in
Long-Term Regional Transmission Planning.  Order No. 1920 had described Factor Category
Seven as taking into account utility and corporate commitments and federal, federallyrecognized Tribal, state, and local policy goals that affect Long-Term Transmission Needs.  In
response to requests for rehearing that suggest that Factor Category Seven could
unnecessarily account for the needs of particular transmission users, Order No. 1920-A sets
aside the requirement to incorporate corporate commitments from Factor Category Seven into
each required Long-Term Scenario. 
Order No. 1920-A further specifies that, while transmission providers are not required to use
the set of seven required benefits to help inform their identification of Long-Term Transmission
Needs, the identification of those needs should rely on economic and reliability drivers.
Finally, Order No. 1920-A requires transmission providers to propose a date, no later than two
years from the date on which initial compliance filings to comply with Order No. 1920 are due,
on which they will commence the first Long-Term Regional Transmission Planning cycle.  This
is a change from Order No. 1920’s requirement that the first Long-Term Regional Transmission
Planning cycle begin no later than one year after initial Order No. 1920 compliance filings are
due.  This modification balances the need to ensure that transmission providers timely
implement Order No. 1920’s requirements to avoid unnecessary delays in delivering these
beneficial reforms for customers, with providing transmission providers sufficient time to
implement Long-Term Regional Transmission Planning and align the Long-Term Regional
Transmission Planning cycle with existing transmission planning cycles, which could be longer
than one single year. 
Thank you, this concludes our presentation.  We are happy to address any questions.

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