Open Access & Market Structure

Order 2000 1999

FERC Order 2000 (1999) — Regional Transmission Organizations (RTOs)

Order 2000 (RM99-2-000, December 1999) encouraged voluntary formation of RTOs and ISOs to administer regional transmission and wholesale markets with independent governance, open access, and efficient regional coordination.

Reference page · Issued 1999 · Updated 2026-07-15

What This Order Did

Order No. 2000, issued in December 1999 in Docket RM99-2-000, encouraged the formation of Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs) to administer regional transmission systems and wholesale markets in ways that improve efficiency and non-discriminatory access. Building on Orders 888 and 889, FERC concluded that voluntary regional institutions with independent governance could better achieve open access, reliability, and efficient wholesale competition than utility-by-utility operation of the bulk power system.

The order described minimum characteristics and functions for RTOs, including independent governance, operational authority over transmission, a regional scope of operations, and authority to maintain short-term reliability. RTOs were expected to provide nondiscriminatory transmission service, manage congestion through market-based mechanisms where appropriate, and plan regional transmission expansions. FERC emphasized that RTO formation should be voluntary but that utilities choosing not to join an RTO would remain subject to individual open-access obligations.

Order 2000 addressed seams issues between regions, tariff reciprocity, and the relationship between state and federal jurisdiction over grid operations. The Commission outlined incentive treatments for transmission owners participating in RTOs, recognizing that structural reform required cooperation from utilities that might otherwise resist ceding operational control. The order did not mandate a single national grid operator but instead set a framework within which multiple regional organizations—such as PJM, MISO, SPP, and CAISO—could evolve.

While not all regions formed RTOs, Order 2000 is a central structural milestone in how much of the U.S. bulk power system is coordinated regionally rather than utility-by-utility. The independent governance and regional planning concepts in Order 2000 informed later reforms including Order 1000's planning requirements and ongoing debates about seams coordination and market participation.

FERC described twelve characteristics for RTOs, including independence, appropriate regional scope, operational authority, and short-term reliability responsibility. The order encouraged formation of single-region RTOs where possible but allowed combinations where operational realities required them. Transmission owners that joined RTOs could access incentive treatments, while those remaining standalone faced continued Commission oversight of open access. Order 2000 also addressed how RTOs would administer congestion management, coordinate with state retail regulators, and provide fair access to market information—questions that would shape organized wholesale markets for decades.

Although some regions never formed full RTOs, the order's emphasis on independent governance and regional coordination influenced every subsequent transmission reform, including planning rules in Order 1000 and market participation requirements for demand response and variable generation. The order remains the Commission's primary policy statement encouraging voluntary regional grid governance rather than mandatory consolidation.

2000
Order Number
1999
Year Issued
Open Access & Market Structure
Category

Who It Applies To

  • Vertically integrated public utilities considering RTO or ISO participation
  • Independent system operators and regional transmission organizations
  • State commissions evaluating grid governance and retail-market implications
  • Transmission owners negotiating RTO membership, tariffs, and cost allocation

Key Holdings & Requirements

  • Encouraged voluntary formation of RTOs with independent governance and regional operational scope.
  • Defined minimum RTO characteristics including nondiscriminatory access and congestion management.
  • Addressed seams coordination and reciprocity between regional transmission arrangements.
  • Outlined incentive policies for transmission owners joining approved RTO structures.
  • Preserved open-access obligations for utilities that declined RTO participation.

Frequently asked questions

Did Order 2000 mandate that all utilities join an RTO?

No. Order 2000 encouraged voluntary RTO formation and described minimum characteristics for Commission-approved organizations. Utilities that chose not to participate remained subject to individual Order 888 open-access obligations in their service territories.

What is the difference between an RTO and an ISO?

Both are independent regional grid operators. RTOs generally meet FERC's Order 2000 minimum characteristics including regional scope and independent governance. ISOs often operate similarly but may differ in tariff structure and market functions. In practice the terms are sometimes used interchangeably.

How does Order 2000 connect to Order 888?

Order 888 required open access and functional unbundling; Order 2000 addressed how regional institutions could administer that access more efficiently. RTOs consolidate transmission operation and market coordination across multiple utilities within a region.

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