As Welton’s article illuminates, the electric sector is not as organized as it appears. Welton references the recent Supreme Court decision, FERC v. Elec. Power Supply Ass’n, and suggests that the case may provide FERC with not only the authority, “but ‘indeed, the duty’” to ensure just and reasonable rates through non-traditional means, such as true parity in treatment of non-transmission alternatives. Welton’s analysis is accurate, however both FERC v. Elec. Power Supply Ass’n and current transmission planning challenges are symptomatic of larger upheaval in the electric sector. This Comment endeavors to provide context for this upheaval, by first exploring and suggesting a cause for the ongoing foundational change. Next, the implications of FERC v. Elec. Power Supply Ass’n are discussed. This Comment ends with a broader estimation of how the sector could develop in the future in response to ongoing transformation.