Tracking Transmission Reform

A transmission tower in front of an orange sky; a flock of birds flies past; a snippet of text from FERC's Building for the Future NOPR; the State Impact Center logo.

This resource was launched October 29, 2021. It was last updat­ed March 24, 2023.

Hear from state attorneys general about why transmission reform is a critical aspect of climate response and what’s at stake, learn about the broad reform needs in this space, and keep track of opportunities to engage in pushing towards more equitable transmission policy.

AGs Explain What’s at Stake

Then Massachusetts Attorney General Maura Healey

“We have no time to waste in address­ing this cri­sis. [We need to start] build­ing new, equi­table, resilient, and effi­cient elec­tric trans­mis­sion on a big scale, and fast. … These changes need to be trans­par­ent, bold, and cen­ter the peo­ple most deeply impact­ed by the cli­mate crisis.”

– Then-Massachusetts Attorney General Maura Healey

Connecticut Attorney General William Tong

“To reach our state and fed­er­al cli­mate and oth­er goals, we will need sub­stan­tial new trans­mis­sion infra­struc­ture. … Attor­neys gen­er­al have been active par­tic­i­pants before FERC, and we are work­ing now to make sure any new ener­gy infra­struc­ture is effi­cient, resilient, and affordable.”

– Connecticut Attorney General William Tong

Michigan Attorney General Dana Nessel

“I can imag­ine few things that would be more trans­for­ma­tion­al and ben­e­fi­cial for the con­sumers of my state than reform­ing the way we trans­mit ener­gy. It’ll cre­ate jobs, improve pub­lic health, reduce costs, and give us the ener­gy reli­a­bil­i­ty we’ve been demand­ing for years.”

– Michigan Attorney General Dana Nessel

Then Maryland Attorney General Brian Frosh

“FERC’s new focus on trans­mis­sion reform presents an oppor­tu­ni­ty for find­ing cre­ative ways to ame­lio­rate the impacts of our reliance on fos­sil fuel plants in [low-income and major­i­ty minor­i­ty] com­mu­ni­ties. … Pro­mot­ing clean ener­gy gen­er­al­ly will lessen the health effects of fos­sil fuel-based ener­gy sources.”

– Then-Maryland Attorney General Brian Frosh

Transmission in Focus


June 2022

In June 2022, the Federal Energy Regulatory Commission (FERC) issued (1) a proposed rule to address interconnection procedures; and (2) two proposals to address grid reliability against extreme weather.

In a notice of proposed rulemaking titled Improvements to Generator Interconnection Procedures and Agreements, FERC proposes reforms to address the delays and costs that new generation and storage projects can face in attempting to connect to the grid. Aspects of the proposal include: (1) changes to the study process and new readiness requirements for customers; (2) deadlines for processing interconnection studies with associated penalties for failing to meet deadlines; (3) the incorporation of technological advancements; and (4) updated modeling and performance requirements.

In a notice of proposed rulemaking titled Transmission System Planning Performance Requirements for Extreme Weather, FERC proposes to direct the North American Electric Reliability Corporation (NERC) to develop modifications to reliability standards around transmission planning for extreme heat and cold weather. And in a notice of proposed rulemaking titled One-Time Reports on Extreme Weather Vulnerability Assessments, FERC proposes to direct transmission providers to submit a report on their approach to extreme weather vulnerability and risk mitigation. This is an information gathering activity and would not require new assessments.

April 2022

In April 2022, FERC issued a notice of proposed rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection. This proposal addresses several pieces of the inquiry FERC launched in its earlier advanced notice in this proceeding.

The proposal includes:

  • Forward-looking regional transmission planning on a 20-year planning horizon (at minimum) and including accounting for extreme weather events.
  • More robust consideration of dynamic line ratings and advanced power flow control devices.
  • A significant role for states in cost allocation for transmission facilities.
  • Prohibition of the construction-work-in-progress incentive for facilities selected through long-term regional transmission planning.
  • A federal right of first refusal for facilities selected in a regional transmission plan, as long as the incumbent transmission developer established joint ownership with unaffiliated, nonincumbent developers.
  • Enhanced transparency requirements for transmission providers.

Our colleagues at the Institute for Policy Integrity at NYU Law provide a summary of the April 2022 proposal.

July 2021

In July 2021, FERC issued an advanced notice of proposed rulemaking called Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection. FERC’s efforts in this area are likely to be key to facilitating the cost-effective and efficient buildout of the transmission system needed to enable a cleaner, affordable energy future.

Customer demand, state and federal policies, and cost competitiveness have driven the country’s power generation mix towards cleaner technologies. We are shifting from large resources sited near population centers to renewables, which are often located far from population centers, based on sun or wind patterns. Current transmission policies have led to backlogs in adding new renewable generation to the grid. Serious reform is needed to access these resources in a cost-effective and efficient way. As FERC Chair Richard Glick and Commissioner Allison Clements said in a statement: “With the clean energy transition gaining steam, we can either continue with the status quo, trying to meet the transmission needs of the future by building out the grid in a myopic, piecemeal fashion, or we can start holistically and proactively planning for those future transmission needs.”

In its advanced notice of proposed rulemaking, FERC asked for comment on potential reforms in broad areas, including how costs of new transmission and upgrades should be allocated, whether the planning process should take into account likely future generation, and what kind of oversight there should be. FERC’s news release and staff presentation that accompanied issuance of the advanced notice provide additional information. This is the beginning of a longer process that will have further opportunities for stakeholder and public engagement.

Important Dates



AG Work

Transmission Planning and Cost Management & Joint Federal-State Task Force on Electric Transmission

Post-Technical Conference Comments

Improvements to Generator Interconnection Procedures and Agreements

Notice of Proposed Rulemaking (NOPR) - Comments

Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection

Notice of Pro­posed Rule­mak­ing (NOPR) - Reply Comments

Notice of Pro­posed Rule­mak­ing (NOPR) - Comments

Advanced Notice of Proposed Rulemaking (ANOPR) - Reply Comments

Advanced Notice of Proposed Rulemaking (ANOPR) - Comments



A transmission tower stands against a blue sky filled with fluffy but scattered clouds that are tinted pink ostensibly by the sunset, reminiscent of cotton candy

National Transmission Planning Study Webinar

Department of Energy

October 21, 2022

See Older Items

Transmission Reform in the Media

A transmission tower sits on a sloping green hill against a blue sky filled with wispy white clouds

The U.S. Has Billions for Wind and Solar Projects. Good Luck Plugging Them In.

The New York Times Brad Plumer

February 23, 2023

See Older News Items

Insights by Center Staff and Advisory Council Members

An illustration depicting a clean energy future: wind turbines and a gust of wind; solar panels and a bright sun; a green skyline sits on the globe.

Unjust, Unreasonable, Unwelcome: EJ Barriers at FERC

Sasha George Ruiz, Jessica Bell | January 26, 2023

A look at the Federal Energy Regulatory Commission's recent commitment to prioritizing environmental justice, where there is still room for improvement, and opportunities for public engagement...

Solar panels on a building with corrugated metal siding; text from a Department of Energy press release sits in the sky behind the building

Get a GRIP on DOE Funding

Jessica Bell | November 10, 2022

The acronym soup of fed­er­al laws that will tur­bocharge clean ener­gy is ready for prime­time. This week, we’ll take a look at the Infra­struc­ture Law, signed last year (some­times referred to as the BIL or the IIJA)...

A transmission tower

The "Goldilocks" Approach to Transmission Cost Allocation

Gabe Tabak | March 24, 2022

Cleaning up the grid means building electricity transmission for clean energy sources, which can be held up over the contentious issue of “cost allocation”...

Bats flying around a transmission tower

Tricks, Treats, and Transmission: Bringing Equity to Grid Planning

Jessica Bell, Howard Crystal | October 28, 2021

The past year has shown how the climate emergency and severe weather test the transmission system. The current system is failing these tests...


An image of transmission tower in the midground center, with draping transmission lines on either side extending from the foreground to the midground; in the background, a smoky valley in various shades of blue.

Generating Change for a Just Grid

A discussion of important changes underway at the Federal Energy Regulatory Commission on how the electric transmission system is planned and who pays. Hear from FERC Commissioner Willie Phillips, FERC staff, and an expert panel talk about the role for states, equity, and decarbonization in these transmission changes, and how you can get involved.

Power lines receding into the distance connecting to a transmission tower shortly after sunrise; a blue sky with a few clouds; green grass; the black silhouette of a leafless tree.

Building the Grid of the Future: A Discussion of Transmission Reform

The State Impact Center hosted webinar that gave an overview of FERC’s "Building for the Future" advanced notice of proposed rulemaking and discussed how the proceeding relates to state clean energy goals, customer costs, environmental justice, and more.

An abstract image showing solar panels, transmission towers, and text from various articles and documents about FERC.

Energizing Your FERC Practice

New to FERC? The State Impact Center hosted a webinar that gave an overview of the nuts and bolts of engaging in FERC proceedings, highlighted FERC’s major substantive areas of responsibility, and discussed different ways to advocate in front of the Commission.