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 Octo­ber 192022.

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

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.” 

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.”

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.” 

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.”

Transmission in Focus

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 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 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 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.

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 proposal.

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

Improvements to Generator Interconnection Procedures and Agreements

Notice of Pro­posed Rule­mak­ing (NOPR)

Multistate Comments to FERC

October 13, 2022

States: Connecticut, Delaware, Maryland, Massachusetts, Rhode Island, and Washington, D.C.

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

Notice of Pro­posed Rule­mak­ing (NOPR)

Multistate Reply Comments to FERC

September 19, 2022

States: Connecticut, Maryland, Massachusetts, Rhode Island, Washington, D.C.

Multistate Reply Comments to FERC

September 19, 2022

States: Alabama, Alaska, Arkansas, Florida, Georgia, Kansas, Kentucky, Louisiana, Mississippi, Montana, Nebraska, Ohio, Oklahoma, South Carolina, Texas, Utah, and West Virginia

Multistate Comments to FERC

August 17, 2022

States: Connecticut, Maryland, Massachusetts, Michigan, Rhode Island, Washington, D.C.

Multistate Comments to FERC

August 17, 2022

States: Alaska, Georgia, Idaho, Indiana, Kansas, Kentucky, Louisiana, Mississippi, Montana, Nebraska, North Dakota, Ohio, Oklahoma, South Carolina, Texas, Utah, W. Virginia, Wyoming

Advanced Notice of Pro­posed Rule­mak­ing (ANOPR)

Multistate Reply Comments to FERC

November 26, 2021

States: Connecticut, Delaware, Maryland, Massachusetts, Minnesota, New Jersey, Rhode Island, Vermont, Washington, D.C.

Eleven AGs Call on FERC to Increase Grid Resilience and Make Transmission Planning More Inclusive

October 13, 2021

State Energy & Environmental Impact Center Press Release

Multistate Comments to FERC

October 12, 2021

States: Connecticut, Delaware, Illinois, Maryland, Massachusetts, Michigan, Minnesota, Oregon, Rhode Island, Vermont, Washington, D.C.



See Older Items

Trans­mis­sion Reform in the Media

Court hands win to renew­ables in FERC trans­mis­sion case | E&E News • Niina H. Farah 12/5/22

See Older News Items

Insights by Cen­ter Staff and Advi­so­ry Coun­cil Members

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...


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.