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December 5, 2025
Stakeholder Forum | Opinion
Stakeholder Forum: The Facts About FERC Order 1920 and Why It’s Essential

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As the tides of deregulation swell, Gretchen Kershaw of Grid Strategies wants to "set the record straight" on FERC Order 1920 and why it's essential.

By Gretchen Kershaw

As the tides of “deregulation” swell, I write to set the record straight on FERC Order 1920. As Mark Twain said, “Get your facts first, then you can distort them as you please.” Here are the facts. 

Gretchen Kershaw

We need a significant amount of transmission in this country. Study after study shows a pressing need today as well as in the future, and that need is driven by threats to the reliability and resilience of the grid, high energy costs, and congestion and constraints on the existing system. 

At the same time, demand is surging, driven by electrification, increases in domestic manufacturing, and, of course, new load from artificial intelligence (AI) data centers and other large customers. 

So, everyone is asking: How do we meet potentially exponential demand growth reliably and affordably? Generation will be needed, but it cannot meet this demand alone; transmission is essential. So is FERC’s Order No. 1920. Here are a few key facts. 

Fact 1: The status quo incremental and reactive approach to building the grid we need is the most expensive option and will contribute to rising electricity bills. FERC aimed to fix the broken paradigm with Order 1920, establishing a baseline across the country that reflects best practices, such as planning on a 20-year forward-looking basis. Well-planned transmission, as envisioned by Order 1920, benefits all users of our electric system. 

Fact 2: Well-planned transmission improves reliability and resilience. The reality is that all generators have outages, whether “behind the meter” or grid-connected. A more networked system, connecting areas that have peak loads and generation outages at different times, always has been the way to ensure steady power supply. 

Looking at extreme weather events, transmission consistently allows more resources to be shared across regions and move energy from where it is available to where it is needed. Witness Winter Storms Uri and Elliott, where regions that could import power avoided prolonged outages that plagued regions that were more islanded. 

As my colleague Michael Goggin says: We need a grid bigger than the weather. Building this insurance policy against future extreme events requires planning that is proactive and that accounts for a wide range of drivers and addresses uncertainty by identifying projects that are beneficial under multiple scenarios. 

Fact 3: Well-planned transmission saves consumers money. Electricity rates are increasing for several reasons, one of which is transmission. But despite transmission spending hitting an all-time high in recent years, the miles of new high-voltage transmission that is being built has dropped year-over-year. 

So, transmission owners are investing — not surprising, given our aging electric grid — but not adding new large-scale transmission capacity nearly fast enough. The National Transmission Planning Study, released by DOE last year, found the lowest-cost electricity system to meet future demand and reliability needs includes substantial transmission expansion — and that accelerated and coordinated expansion could save upward of $490 billion through 2050. We cannot afford to abandon Order No. 1920; instead, we should implement it faster to significantly benefit sooner. 

Fact 4: Order 1920 benefits all kinds of generation, and our country needs more transmission no matter the generation type. Abundant American energy supply is within reach. But we cannot access it reliably and affordably without transmission. 

Let’s be clear: Utilities are investing more than ever in upgrading a rapidly aging grid. Order 1920 provides a collaborative road map for more efficient and cost-effective grid upgrades. Grid hardening is critical, as is squeezing more from our existing system by deploying grid enhancing technologies and high performance conductors. 

Congress knew this when it acted, on a bipartisan basis, to establish federal funding programs in the Infrastructure Investment and Jobs Act in 2021 for just this type of investment. Regrettably, delays in these critical enhancements may indeed happen, but not from Order 1920; instead, delays may happen from blocking use of federal funds specifically for these needs. 

Those are the facts. How impactful Order 1920 will be is yet to be seen, but to cut it off at the pass is to threaten grid reliability and resilience, impose higher costs on consumers, and threaten America’s ability to compete in the global AI race. 

Gretchen Kershaw is chief operating officer and vice president of strategy at Grid Strategies LLC. 

CommentaryTransmission Planning