FERC Order 1920 Compliance: How Energy Exemplar Helped Shape the Playbook

For years, most new transmission in the U.S. has been justified on a single basis: near term reliability. More than 90% of recent transmission investment falls into that "one need, one fix" category, according to the Energy Systems Integration Group (ESIG). The trouble is that a single transmission line can do a lot more than keep the lights on during a heat wave. It can cut congestion, lower fuel costs, defer expensive local generation, and help the grid survive extreme weather events all at once. If you're only measuring one of those benefits, you're leaving a lot of value on the table, and customers end up footing the bill for it.

FERC Order 1920 was written to fix that. It requires transmission providers to evaluate proposed long-range transmission projects against seven distinct categories of benefits, not just one. What it doesn't do is tell planners exactly how to calculate those seven benefits. That's the gap ESIG's FERC Order 1920 Task Force set out to close with its new Modeling Practice Guide, released this year, and it's a genuinely useful one for anyone working in utility, ISO, RTO, or transmission planning circles.

How did Energy Exemplar contribute to the Order 1920 Modeling Practice Guide?

Energy Exemplar is represented on the FERC Order 1920 Task Force by Jonathan Surls, Mark Doolin, and Chris Nichols, working alongside representatives from PJM, ISOs across the country, national labs, and dozens of other organizations to shape a methodology that the whole industry can actually use. This guide is likely to become a reference point in compliance filings, regulatory proceedings, and stakeholder debates for years, and having a hand in writing it means Energy Exemplar contributed to that conversation rather than just reacting to it.

Why do planners need shared guidance for Order 1920 compliance?

Order 1920 sets a floor, not a formula. Planners now have to look at a minimum 20-year horizon (up from the 10 years common in most regions), quantify at least seven categories of benefits, and be ready to defend those numbers in front of regulators, intervenors, and stakeholders. Without a shared methodology, every region would be left to invent its own approach, which invites inconsistency, invites challenges, and honestly just invites headaches for everyone involved.

So ESIG brought together more than 70 experts from 40 organizations including system operators, utilities, regulators, developers, software providers, and research institutions, to build a consensus-based framework. The result is the first practitioner developed guide that walks through the actual step by step process for quantifying each of the seven Order 1920 benefits, not just naming them.

What benefits must planners evaluate under FERC Order 1920?

The guide breaks the benefits down into a clear set of categories, each with its own primary modeling tool and monetization approach:

• Transmission Reliability – avoided or deferred infrastructure costs
• Resource Adequacy – reduced loss of load probability or planning reserve margin
• Production Cost Savings – fuel, O&M, start up, and emissions savings from smarter dispatch
• Reduced Transmission Energy Losses – less energy lost getting power where it needs to go
• Reduced Congestion from Transmission Outages – value gained from added system redundancy
• Resilience – mitigation of extreme weather and unexpected system stress
• Avoided Capacity from Reduced Losses – capacity savings tied to peak period loss reduction

None of these benefits sit in isolation. They lean on a coordinated suite of models, production cost models, AC power flow models, resource adequacy models, and sometimes capacity expansion models, all passing information back and forth. Get the coordination wrong and you risk double counting the same benefit twice, or worse, undercounting it and shortchanging the actual value transmission provides.

What makes Order 1920 benefit analysis credible?

Beyond the benefit-by-benefit walkthrough, the guide lays out six principles meant to keep the analysis credible no matter which region is running it. Things like making sure benefit identification actually maximizes net value, designing scenarios that reflect real resource mix and policy shifts, avoiding double counting across overlapping benefit categories, and treating the seven required benefits as a floor rather than a ceiling. Planners are explicitly encouraged to go further and quantify additional benefits, like emissions reductions or economic development impacts, where the data supports it.

How does PLEXOS® support Order 1920 transmission planning?

Worth noting: the guide itself sticks to tool category language throughout, referring to production cost models (PCMs), AC power flow models, and resource adequacy tools rather than naming specific software. That's by design, since the framework needs to work across whatever modeling stack a given region already runs.

PLEXOS® supports that type of workflow through nodal production cost modeling, resource adequacy analysis, and capacity expansion modeling. Planners can use PLEXOS to evaluate how transmission investments affect dispatch costs, congestion, losses, resource needs, and reliability across multiple scenarios and planning years.

Just as importantly, PLEXOS is a modern platform designed to work within a broader planning ecosystem. Its modeling outputs and data workflows can integrate with complementary tools, including AC power flow models, helping organizations connect long-term portfolio development with detailed transmission analysis and reliability assessment.

Order 1920 compliance is going to be a long runway of first-generation studies, refinements, and regulatory back and forth. Having modeling tools built for exactly this kind of multi-scenario, multi-benefit analysis, and having helped shape the rulebook those tools will be measured against, puts Energy Exemplar and PLEXOS in a pretty good spot for whatever comes next.