In their recent piece, What if Bruce Lee Had Set Federal Transmission Policy?, Vincent Duane and Caitlin Shields argue that the Federal Energy Regulatory Commission should repeal Order 1000 and return transmission planning authority to utilities. While their article rightly identifies the failure of FERC’s Order 1000, it draws the wrong conclusions about how to fix transmission planning and misses a key opportunity for reform that is already in place to enable a more robust transmission buildout: FERC Order 1920. 

The core problem with Order 1000 is that it has failed to deliver the regional and interregional transmission projects necessary for grid reliability and affordability by leaving loopholes in place to the competition it introduced. The clearest proof of this failure is the interconnection queue backlog, which now totals over 2.5 terawatts of proposed resources stuck waiting to connect. For projects that make it through the queue, they face inordinately expensive network upgrade costs to interconnect — in PJM, tenfold what they paid in 2017 — due to a lack of proactive transmission planning. As a result, the grid today is less reliable and more expensive because regional transmission has not been sufficiently planned to connect new supply, putting our country’s load growth ambitions and economic development at risk.

Instead of investing in regional projects, utilities have prioritized local transmission projects, which fail to deliver similar benefits. While the authors correctly note this trend, they fail to mention the underlying reasons. As RMI documented in its Mind the Regulatory Gap report last year, local projects are often not subject to rigorous regulatory review at the federal, regional, or state levels. The result: utilities can earn a return on local projects with little oversight.

This practice has been extensively documented across the United States. From 2016 to 2023, annual spending on local transmission projects in New England increased eightfold to nearly $800 million. In PJM, local transmission spending grew from 9% of total investment in 2005-2013 to 73% in 2014-2021. Nationwide, as a result, miles of high-voltage regional transmission built has declined to an all-time low of only 55 miles in 2023.

The good news is that FERC took action last year to promote regional planning and address some of the failures of Order 1000 by issuing Order 1920. Order 1920 mandates a 20-year regional transmission planning horizon that will help the U.S. prepare for pressing demands like load growth and generator interconnection today in a holistic manner. It also requires more consideration of local projects in regional processes, helping to close the regulatory gap.

Regions already doing long-term planning akin to Order 1920, such as the Midcontinent Independent System Operator’s Long-Range Transmission Planning process, have seen and begun reaping the benefits of robust regional planning. RMI’s new High Voltage, High Reward Transmission report shows that regional and interregional lines can deliver significant savings while meeting a variety of reliability and public policy goals.   

While more work remains to be done, Order 1920 is a critical first step and key opportunity to improve transmission planning that the authors unfortunately overlook. Repealing Order 1000 wouldn’t fix the issues in transmission planning we face today. It would simply give utilities more control over a process that already struggles to deliver the regional and interregional transmission our grid needs. Rather than calling for a return to the past, the focus should be on making Order 1920 — our Dragon — as strong as possible to correct the failures of Order 1000 and finally unlock the large-scale transmission projects critical to a clean, reliable and affordable energy future.