Interconnection queues have become a planning and execution constraint for much of the U.S. power sector. At the end of 2022, there were more than 10,000 active interconnection requests nationwide, representing more than 2,000 gigawatts (GW) of proposed generation and storage. Those requests do not translate cleanly into built projects: Berkeley Lab found that, among a subset of queues with available data, only 21% of projects (and 14% of capacity) seeking interconnection from 2000-17 had been built as of the end of 2022. Wait times have also grown, with a median of five years from request to commercial operation for projects built in 2022.
For transmission providers and other utilities supporting interconnection, this is a workflow issue amplified by the increase in interconnection requests. Traditional, serial study processes can increase timing and cost volatility when prior-queued projects change scope or withdraw. As the mix of interconnection requests has shifted toward inverter-based resources, storage and hybrid configurations, study execution also depends more heavily on data completeness and consistent modeling assumptions. In that context, “queue reform” is effectively about systematizing how studies are run and how outcomes are explained.
Bringing New Order to the Queue
Federal Energy Regulatory Commission (FERC) Order 2023 was designed to address these conditions by replacing the standard first-come, first-served serial approach with a first-ready, first-served cluster study process, setting firmer timelines and adding new readiness requirements for interconnection customers. The rule took effect Nov. 6, 2023, and FERC issued Order 2023-A on March 21, 2024, to revise or clarify parts of the original order.
FERC framed Order 2023 around three practical outcomes: reducing backlogs, improving certainty in interconnection timelines and outcomes, and maintaining access for newer technologies. The center of gravity is the cluster study process itself, but the rule also adds supporting structure intended to reduce speculative entries and make information available earlier in the process.
One example is transparency before a request is submitted. Order 2023 requires transmission providers to maintain a publicly available visual “heat map” of available transmission capacity so prospective interconnection customers can evaluate congestion and point-of-interconnection options sooner.
The Shift to Cluster Studies
Under a serial model, each request is studied in queue order, typically with the assumption that prior-queued projects will be built and that their identified upgrades will already be in place. When a request withdraws, later projects can inherit required system modifications and shifted upgrade responsibilities.
Order 2023 replaced that structure with studies conducted in batches, grouping interconnection requests into equal-priority clusters rather than studying each project independently. The rule also defines a study sequence that includes a 150-day cluster study, followed by a facilities study before an interconnection agreement.
From a utility execution standpoint, the difference is not only that more projects are studied at once. Rather, the cluster approach increases the value of repeatable, programmatic study mechanics: consistent base-case management, intake validation, disciplined treatment of “material modifications,” and clear documentation that supports both technical review and stakeholder discussions.
Proportional Cost Sharing
Cluster studies also change how network upgrade costs are assigned. Under Order 2023, network upgrade costs within a cluster are allocated using a “proportional impact method,” defined by FERC as a technical analysis that determines the degree to which each generating facility contributes to the need for a specific network upgrade. In effect, the method spreads upgrade costs across multiple projects that contribute to the upgrade driver, rather than assigning the full cost to the single project that happened to cross a threshold under prior serial assumptions.
A practical way to interpret proportional impact is to tie cost responsibility to the study metric that drives the upgrade. For a breaker replacement driven by fault duty, proportional impact can be based on each project’s fault current contribution at the affected location relative to the cluster total. While this kind of allocation can reduce the financial risk developers may face based on queue position, it also puts more weight on transparent assumptions and defensible calculations, because more parties share in each outcome.
Order 2023 also addresses restudies when a cluster needs to be reanalyzed, including scenarios in which a major project with a higher or equivalent queue position is withdrawn. From a utility perspective, that matters because proportional allocations can shift after withdrawals, which could affect decisions behind other projects and lead to additional churn.
Readiness Requisites
Cluster studies are intended to move faster, but speed depends on studying projects that have a reasonable likelihood of moving forward. Order 2023 responds with additional financial readiness and site control requirements, as well as withdrawal penalties under defined conditions.
FERC’s explainer describes four primary levers:
- Higher study deposits.
- Required demonstration of site control.
- A "commercial readiness" deposit framework.
- Withdrawal penalties.
For site control specifically, interconnection customers generally must provide evidence of 90% site control at the time of submitting the interconnection request and 100% site control at the time of executing the facilities study agreement, with limited circumstances in which a deposit can be used in lieu of site control when legal constraints make site control infeasible.
These requirements can reduce the time that transmission providers spend on low-maturity requests, but they also move readiness enforcement closer to the front end of the process and can increase the need for consistent queue administration.
Utility Pressure Points
Order 2023 pairs firm study timelines with penalties if transmission providers fail to complete studies on time, with limited exceptions, including use of the proportional impact method for affected system network upgrade costs. That structure raises the operational stakes for schedule management. Late model changes, incomplete data and shifting project configurations in a high-volume cluster can translate into rework across a large set of queued requests.
Resource availability is another constraint. Even when readiness requirements reduce speculative entries, a cluster can still represent a concentrated block of power flow, short-circuit and stability work, plus coordination across affected systems.
Data quality and model governance can be additional pain points as the queue mix evolves. Order 2023 requires more granular and accurate modeling data for nonsynchronous resources such as wind, solar and battery storage, and it references capability standards tied to reliability performance. Although that requirement can improve study fidelity over time, it does also heighten the importance of intake validation, model version control and clear rules for how changes are handled midcycle.
Finally, proportional cost sharing can change the tone of stakeholder interactions. When dozens of projects share responsibility for multiple upgrades, study results are more likely to be scrutinized at the assumption level. That increases the value of documentation that is technically complete, consistent across upgrades, and written with clarity that holds up under external review.
Planning Considerations
For utility planning teams, Order 2023’s cluster construct can be treated less like an ad hoc queue and more like a recurring program. That shift tends to favor utilities that align study execution with broader planning rhythms: maintaining base cases continuously, formalizing study intake and review checkpoints, and synchronizing interconnection assumptions with affected system coordination.
The rule also expands what a cluster study might need to evaluate. FERC requires transmission providers to evaluate alternative transmission technologies during cluster studies and lists examples such as advanced conductors, advanced power flow control, transmission switching, static VAR compensators and synchronous condensers. Having a consistent internal approach for when and how these options are screened can reduce friction inside the study window.
Order 2023 also requires transmission providers to allow colocated resources to share a site behind a single point of interconnection and to share a single interconnection request. As hybrid and colocated configurations become more common in the queue, planning teams may see greater need to align study assumptions with how these resources are modeled, dispatched and represented in steady-state and dynamic cases.
Taken together, cluster studies are not simply a different study format; they change the pacing of interconnection work, how costs are assigned and how study results are defended. For transmission providers, the main planning implication is that interconnection outcomes will increasingly reflect the quality of program execution.
The impacts of Order 2023 on the interconnection backlog and speed to build are still unknown, but they will be felt over the coming years. Disciplined models, predictable governance and a repeatable process for translating technical findings into transparent, auditable results are the keys to optimizing the process and ultimately benefiting from more predictable and fair cost-sharing for necessary grid upgrades.
