Originally posted via LinkedIn
2024 was a breakout year for energy policy from interconnection reforms to transmission planning, and now fast tracks. We now have a new administration incoming within the White House and we all await what changes will come to fruition in 2025. Let’s look back on this year and toward the future to see what lies ahead.
The first two points describe how all RTOs and FERC jurisdictional utilities are reviewing FERC orders that have made, or will be making, and compliance filings in response to those orders. Thus, regulatory and policy professionals are constantly on their toes. They are working to understand impacts to projects and markets as proposal after proposal is reviewed with stakeholders, revised, ultimately filed with FERC, goes through a comment period, and then FERC provides a ruling for all to digest and understand final impacts.
In 2024:
- Compliance filings for Order 2023 RM22-14 were due: FERC has ruled on some compliance filings but has yet to rule on the majority of filings.
- Requires a shift from serial to cluster study process
- Commercial readiness deposits and not necessarily commercial readiness demonstrations
- Withdrawal penalties based upon percentage of Network Upgrades
- Transmission Providers to be assessed penalties if late with studies, and more.
In 2025, we look to understand rulings on all compliance filings that FERC has yet to rule on, as well as court decisions on rehearing request items.
- Order 1920 Released 5/13/24 RM21-17- Requires that FERC jurisdictional Transmission Providers produce a regional transmission plan for at least 20 years to identify long-term needs and the facilities to meet them and more. Compliance filings are due to FERC by June 2025.
- I suspect from 1920A that entities will go past the June 2025 deadline. MISO has already asked for a year extension.
- Fast Tracks- PJM, MISO and SPP are all looking to fast track generation projects. We look for rules to be filed with FERC in late 2024 or early in 2025.
- It will be interesting to see what happens with PJM as many have been vocal with opposition due to lack of clear planning and understanding of PJM’s actual needs.

As the new Administration transitions, we look to further understand the makeup of FERC (Federal Energy Regulatory Commission and its Commissioners) and what the 119th Congressional Session holds.
We look forward to further changes to capacity accreditation and other market reforms as the clean energy transition is still taking place.
2025 will also bring changes to various states’ permitting and siting rules. I look forward to working with Qcells USA Corp. and other industry professionals as we navigate the fastest changing times in energy policy history.
To read more blog posts from Amy Jo Miller, please see her blog here.