Automated Interconnection Studies: How RTOs Are Replacing Serial Reviews (PJM, MISO, CAISO, ERCOT)

What “automated” actually means

The phrase automated interconnection studies is doing two jobs in 2026 industry conversation, and it helps to separate them. The first job is descriptive: a label for the screening, gating, and deficiency-detection software RTOs have built to operate at the speed FERC now demands. The second job is aspirational: a shorthand for “we wish the whole study process — including the engineering — were faster.” Only the first is real today. The engineering is still done by humans.

FERC Order 2023, issued July 28, 2023, did not mandate automation by name. What it mandated was structural: cluster studies replace serial first-come-first-served review, applicants must demonstrate commercial readiness at every milestone (including site control), and the RTO is on the hook financially if it misses study deadlines. Those three changes together made manual processing impossible at the queue volumes the industry now sees — over 2,600 GW nationally per LBNL Queued Up 2025. Automation is the operational byproduct of compliance, not the goal.

Concretely, here is the split between what the cluster-era systems automate and what they do not:

The shift is best understood as moving the screening layer out of human hands so that the engineering layer has a chance of finishing on time. The screening layer is what touches site control. The engineering layer is what determines network upgrade dollars. Developers who confuse the two end up arguing with the wrong people on the wrong timeline.

The serial-to-cluster shift, in one paragraph

Before Order 2023, an interconnection request was studied in the order it arrived. Project A's System Impact Study had to finish (and any restudy triggered by Project B's withdrawal had to finish) before Project C could start. Withdrawals cascaded one at a time. Queue ages of 4–6 years, with median time-to-COD near 5 years, were the inevitable consequence. Order 2023's cluster study rule batches all applicants in a defined window and studies them together against a single base case. First-ready-first-served replaces first-come-first-served: a project advances based on demonstrated readiness (site control, deposit posted, financial backing) rather than calendar position. Withdrawal cascades become matrix recomputations rather than serial restudies. That single change is what makes automated screening both possible and necessary.

PJM’s automation trajectory: Cycle 1 and the cure loop

PJM’s reform under Order 2023 took the form of a two-track transition: Transition Cycles (TC1 and TC2) processed legacy queue projects under modified pre-Order-2023 rules, while Cycle 1 opened in Q2 2026 as the first true cluster cycle under Tariff Part VII, Subpart C, Sections 301–306. Cycle 1 is where PJM’s automation actually shows up.

The most visible piece of automation is the Application Review Phase clock. The procedural framework, defined in PJM’s Manual 14H, runs a tightly bounded three-step loop:

• 15 Business Days — PJM’s window to issue any deficiency determination after submission. Reasonable Efforts target.
• 10 Business Days — the developer’s window to cure. Hard cap.
• 15 Business Days — PJM’s window to validate or reject the cure. Reasonable Efforts target.

PJM cannot meet a 15-BD deficiency turnaround across a cluster cohort with hundreds of projects using manual review alone. The first 15-BD pass is automated screening: completeness, fee posting, parcel APN cross-check, Manual 14H Section 7.1.6 density math (1 acre per MW for solar, etc.), Section 7.2 parcel-modification grammar checks, and Officer Certification template-version validation. Anything that does not bounce on the automated pass goes to a human for substantive review — but the bounce-rate target is high. See our deeper write-up on the most common Cycle 1 deficiency reasons and the Phase 1 study results pattern for the operational picture.

The Officer Certification itself is a load-bearing piece of automation infrastructure. By forcing the developer to attest, in a structured template, to specific facts about site control, lease terms, and parcel coverage, PJM has turned a fuzzy compliance review into a structured-data submission. The auditable claim — backed by personal officer liability — is what allows automated review to work at scale. The shift from “here is a 400-page lease binder” to “here is an Officer Certification with attached APN-keyed instrument schedule” is the core operational change.

Manual 14H Section 7.2 (parcel modification grammar) is also written in a way that makes automated checking possible. The rules — supplement always, substitute often, expand rarely — can be evaluated against a parcel diff between submissions. Adjacency is a GIS predicate. Easement coverage is a recorded-instrument lookup. None of this requires an attorney to evaluate at first pass. The human only gets involved when the automated pass cannot resolve the parcel.

MISO: the DPP, ERAS, and the Attachment E affidavit

MISO’s Generator Interconnection Procedures (GIP) structure interconnection through the Definitive Planning Process (DPP): an annual cluster cycle of three phases (DPP-I, DPP-II, DPP-III) that culminates in execution of the Definitive Study Agreement (DSA). MISO’s graduated thresholds — 50% site control at application, 90% at System Impact Study, 100% at DSA execution — are designed to be machine-checkable from the start. See our full MISO DPP site control walkthrough for the per-stage detail.

Two pieces of MISO automation deserve specific attention:

ERAS (Expedited Resource Addition Study)

ERAS is MISO’s analog to PJM’s Reliability Resource Initiative (RRI): a one-time, expedited path for a small set of mature projects that can come online quickly to address near-term reliability gaps. Functionally, ERAS is a separate queue entirely — selected projects bypass the DPP cycle and run on an accelerated study path. The selection process itself is a scoring exercise (capacity value, study readiness, location relative to reliability needs), and the operational signature is automation: a scoring rubric, a deadline-driven evaluation window, and a structured submission package.

The Attachment E affidavit as an auto-checkable artifact

MISO’s site control attestation lives in the Attachment E affidavit, a structured sworn statement defined in the MISO tariff. Like PJM’s Officer Certification, Attachment E forces the developer to submit a typed, itemized, notarized table of parcels, instruments, dates, and acreage — not a binder of PDFs to be interpreted. MISO’s rejection patterns (mismatched acreage, missing gen-tie parcels, expired instruments listed as active) are precisely the patterns an automated checker will catch on first pass: numerical comparisons, date arithmetic, presence/absence of fields. Attachment E is the load-bearing artifact for MISO automation just as the Officer Certification is for PJM.

What MISO has not automated — and shows no near-term sign of automating — is the engineering judgment in the System Impact Study itself, particularly for Affected Systems coordination across MISO’s seam with PJM, SPP, and TVA. Network upgrade scoping at MISO seams remains a meeting-driven, manual process.

CAISO Cluster 15: scoring as the automation engine

CAISO took the most aggressive automation path of the three FERC-jurisdictional RTOs by making commercial viability scoring the central queue-management tool. Cluster 15 was the first cluster studied under CAISO’s post-Order-2023 rules (compliance filing accepted in FERC Docket ER24-2042, effective June 12, 2024), and it produced the most striking single dataset of the reform era: 347 GW of applicants narrowed to roughly 68 GW of advancing projects. The scoring rubric — covering site control, deposit posting, off-take status, financing, BLM ROW progress, and developer track record — is published, weighted, and applied programmatically. See our Cluster 15 scoring results breakdown for the full picture.

CAISO’s scoring approach has two operational consequences that distinguish it from PJM and MISO:

• Ranking, not gating, drives the cut. Where PJM and MISO use threshold gates (you either meet 100% or 90% or you don’t), CAISO ranks applicants and admits projects in order until cluster transmission capacity is exhausted. Two projects that both technically meet site control thresholds can have very different outcomes based on relative score — which means optimizing toward higher scores (executed leases instead of options, BLM ROW further along, off-take signed) is now a queue-positioning strategy, not just a compliance bar.
• BLM ROW status is encoded as a discrete progression. CAISO’s rules step through specific BLM permit milestones: application_submitted, accepted_for_processing, environmental_review, grant_issued. Each is a code, not a narrative. That makes the BLM coverage component of a CAISO score machine-checkable.

The scoring rubric is also adjustable cluster-to-cluster. Cluster 16’s rubric, expected in the next compliance update, is widely anticipated to weight off-take and financing more heavily as CAISO learns which scoring inputs best predict actual COD success.

ERCOT’s GINR: similar pressures, different rulebook

ERCOT operates outside FERC jurisdiction as an intrastate market. FERC Order 2023 does not apply. ERCOT’s interconnection process runs under the Generator Interconnection Notification Requirements (GINR), governed by ERCOT Nodal Protocols and overseen by the Public Utility Commission of Texas (PUCT). GINR has its own structural reforms in motion — including SB 6, the 2023 legislation directing PUCT to study queue reforms, and ongoing nodal protocol revision requests (NPRRs) tightening site control evidence and study readiness.

The practical reality for developers is convergence. ERCOT’s queue volumes — especially for solar, storage, and load-side data center interconnections — are at levels that make manual processing untenable, and project finance lenders increasingly require Order-2023-equivalent documentation regardless of jurisdiction. ERCOT projects today are typically prepared to a documentation standard indistinguishable from a FERC-jurisdictional submission, even where the procedural rules differ. The same Officer Certification, parcel-keyed instrument schedule, and machine-readable evidence package that PJM and MISO require is now table stakes for any utility-scale ERCOT financing.

For deeper context on the queue volume pressures driving all of this — and how data center load is interacting with renewable supply queues — see Data Centers vs. Renewables in the Interconnection Queue.

What automation breaks: the PDF tax

Automation assumes machine-readable inputs. Site control evidence in 2026 mostly is not. The legacy package — scanned lease PDFs, photographed signature pages, handwritten margin amendments, inconsistent parcel naming across documents — was built for a world where a PJM staff attorney sat down with a binder. That world is gone, but the binders persist. The cost of submitting one is now measurable in cure cycles.

Three concrete patterns make up the “PDF tax” that legacy developers pay:

1. OCR fallback. A scanned PDF without a text layer cannot be parsed by the RTO’s automated screener. The package routes to manual review. Manual review is slower, less consistent, and more likely to bounce on a substantive question rather than a structural one.
2. Inconsistent parcel identifiers. When the project boundary uses APN 045-321-009, the lease references “the property described in Exhibit A,” the title commitment references parcel 45.321-009, and the Officer Certification spells out the address — the automated cross-check fails. A human resolves it, but the cure cycle eats time the developer cannot recover.
3. Amendment chains that exist only in PDF. A 2018 lease, a 2021 amendment expanding the premises, a 2023 memorandum of lease, and a 2025 SNDA — if these are not consolidated and APN-keyed, the automated system sees four separate documents and cannot determine the current state of the lease. Manual review can, but again at the cost of cycle time.

The fix is not glamorous. It is a structured submission convention: an APN-keyed instrument schedule (CSV or table), a single source-of-truth Officer Certification or Attachment E, a clean PDF with an embedded text layer for each instrument, and a parcel-level coverage table that ties to the GIS project boundary. Developers who can produce this consistently move through cure cycles measurably faster — and at scale, faster cure cycles compound into meaningfully earlier COD dates. This is the gap that purpose-built compliance platforms (Zonevex among them) emerged to close. The platform value is not the GIS or the parser; it is producing a submission package that does not fall to manual review.

Implications for the developer workflow

Automation changes the cadence of the developer’s side of the interconnection process more than it changes the substance. The substantive bar — demonstrate site control, post deposits, hit milestones — is the same. What changes:

• Fewer cure cycles, but each one is shorter and harder. Order 2023’s readiness gates and the RTOs’ automated screening together remove ambiguity from early cycles. Where PJM might historically have allowed multiple back-and-forth iterations on a marginal package, the post-Order-2023 cycle assumes the developer arrives complete. PJM’s 10-BD developer cure cap is hard. MISO’s DSA execution deadline is hard. CAISO’s scoring is point-in-time. The window for “we’ll fix it next round” has narrowed dramatically.
• Evidence packages must be machine-readable. See the previous section. This is no longer optional.
• Officer Certifications and Attachment E affidavits create personal liability that did not previously exist at this granularity. An officer attesting to specific parcel coverage facts is making a claim that the RTO’s automated checker can verify. Misstatements that would once have been corrected in a follow-up call are now formal certification failures.
• Parcel-level cross-check across applications matters. PJM cross-references parcel APNs across queue tracks (Cycle 1, RRI, TC2). A developer with multiple projects must keep separate, non-overlapping parcel sets — the automated checker will catch double-counting on a first pass.
• Tooling adoption has accelerated. Compliance platforms purpose-built for the cluster era — for parcel-level coverage math, instrument schedule generation, parcel-modification grammar checking, and machine-readable submission packages — have moved from optional to mainstream over 2024–2026. The platform layer exists because the manual workflow does not scale to the cluster cadence. Zonevex is one of these platforms; we built it because the spreadsheets and shared drives that worked in 2019 do not survive a 10-business-day PJM cure window.

Cross-RTO automation snapshot

Where this is going: Order 2023-A and the 2026/2027 horizon

FERC Order 2023-A, the 2024 clarifying order, refined Order 2023’s requirements rather than overhauling them — tightening readiness language, addressing surety bond mechanics, and clarifying compliance plan obligations. The next regulatory wave is the round of second-compliance filings that RTOs have submitted or will submit through 2026 and 2027 as their first-cycle experience surfaces gaps in their original compliance plans. The pattern will be more, not less, automation: scoring rubrics tuned cluster-to-cluster, Officer Certification templates evolving toward more structured fields, and tighter coupling between deposit posting, readiness verification, and milestone advancement.

Three near-term horizons matter for developers planning into 2026–2027:

• PJM Cycle 2 application window opens late 2026 / early 2027. The Cycle 1 lessons (deficiency patterns, Officer Certification template versions, the Section 7.2 parcel-modification disputes) will be encoded into Cycle 2’s automated screening before Cycle 1 resolves. Cycle 2 will be harder to enter than Cycle 1. See why 2026 is the operational deadline.
• CAISO Cluster 16’s scoring rubric is the leading indicator. The next CAISO scoring update will tell the industry whether the Cluster 15 cut (347 GW → 68 GW) is a one-time stress test or the new equilibrium. Expect tighter weighting on off-take and financing.
• MISO’s DPP cycle compression. MISO has signaled intent to compress DPP cycle timing further, which compresses every threshold transition. Developers entering the queue at exactly the minimum threshold (50%) have less margin in every successor cycle than in the prior one.

The structural conclusion: the cluster-era queue is now an automated screening layer wrapped around a manual engineering layer. That topology will not invert. The engineering will not automate at the same pace as the screening. Developers who optimize for the screening layer — clean submissions, structured evidence, machine-readable packages — reach the engineering layer faster and with less surface area for cure cycles. Developers who do not will pay the PDF tax, again, in every successive cycle.

Glossary

• Cluster study — A batched study of all interconnection applications received in a defined window, replacing serial first-come-first-served review under FERC Order 2023.
• First-ready-first-served — The Order 2023 principle that queue advancement depends on demonstrated readiness (site control, deposit, financing) rather than calendar order of arrival.
• ERAS — Expedited Resource Addition Study. MISO’s expedited path for select mature projects bypassing the standard DPP cycle.
• RRI — Reliability Resource Initiative. PJM’s one-time accelerated study path approved in FERC Docket ER25-712-000 for 51 selected projects.
• DPP — Definitive Planning Process. MISO’s annual cluster cycle process culminating in DSA execution.
• DSA — Definitive Study Agreement. MISO’s late-stage study agreement; analogous to FERC’s System Impact Study terminology.
• GINR — Generator Interconnection Notification Requirements. ERCOT’s interconnection process under PUCT oversight.
• NPRR — Nodal Protocol Revision Request. ERCOT’s mechanism for amending the Nodal Protocols.
• Officer Certification — PJM’s structured sworn statement attesting to specific site control facts; the load-bearing artifact for automated screening.
• Attachment E — MISO’s structured site control affidavit; the load-bearing artifact for MISO automated review.
• Affected Systems — Neighboring transmission systems whose facilities are impacted by a proposed interconnection; coordination remains manual across RTO seams.

What to do this quarter if you are operating in any cluster cycle

1. Audit your evidence package for machine-readability. If your site control PDFs lack text layers, your APNs are inconsistent across documents, or your Officer Certification is not on the current template version — fix it before the next milestone, not during a cure window.
2. Build an APN-keyed instrument schedule and treat it as the source of truth. Every lease, option, easement, and SNDA should be linked to a specific parcel record. The Officer Certification or Attachment E flows from this schedule.
3. Cross-check parcels across all your active applications in a given RTO. The automated screener will catch double-counting on first pass.
4. Track template-version updates. PJM’s Officer Certification template changes; MISO’s Attachment E format changes; CAISO’s scoring rubric changes cluster-to-cluster. The version that was current at your last submission is not necessarily the version current today.
5. Plan around the screening clock, not the engineering clock. The 10-BD PJM cure window, the MISO DSA deadline, and the CAISO scoring cutoff are the timing facts that govern your work. Engineering review timelines are downstream of these.

FAQ

What are automated interconnection studies?

Cluster-based, software-driven screening and deficiency-detection workflows that RTOs adopted under FERC Order 2023 to replace serial first-come-first-served queue review. Automation typically covers application screening, site control coverage math, deficiency-notice generation, restudy triggering on withdrawal, and milestone gating. Network upgrade scoping, Affected Systems coordination, and final System Impact engineering judgment remain manual.

Did Order 2023 require RTOs to automate?

Not by name. Order 2023 mandated cluster studies, first-ready-first-served readiness gates, and binding study deadlines with financial penalties for the RTO if missed. Those mandates make manual serial review impossible at scale. Automation is the operational consequence of compliance.

What is automated in PJM Cycle 1?

Application completeness checking, parcel-level density math against Manual 14H Section 7.1.6, deficiency-notice issuance within the 15-business-day reasonable-efforts window, parcel-modification grammar checks under Section 7.2, and validation of cure submissions. Substantive engineering review of network upgrades and Officer Certification language interpretation remain manual.

How does automation change my evidence package?

It assumes machine-readable inputs. PDFs with handwritten margin amendments, photographed signature pages, and inconsistent parcel identifiers fall back to manual review and slow the cure cycle. Developers who structure submissions around APN-keyed instrument schedules, current-template Officer Certifications or Attachment E affidavits, and clean PDF text layers move through cycles materially faster.

Will ERCOT adopt automated interconnection studies?

ERCOT operates outside FERC jurisdiction and is not subject to Order 2023. The GINR process is moving in a similar direction independently — driven by queue volume pressure, SB 6, and PUCT oversight. Lenders and offtake counterparties increasingly require Order-2023-equivalent documentation regardless, so ERCOT’s effective evidence bar tracks the FERC-jurisdictional markets even where procedural rules differ.

Sources

• FERC Order 2023 — Interconnection Final Rule Explainer
• FERC Docket ER24-2042 — CAISO Order 2023 Compliance Filing
• FERC Docket ER25-712-000 — PJM Reliability Resource Initiative
• PJM Manual 14H — Sections 6 and 7
• MISO Generator Interconnection Procedures (GIP)
• CAISO Business Practice Manuals
• LBNL Queued Up 2025 — Characteristics of Power Plants Seeking Transmission Interconnection
• ERCOT Resource Integration — Generator Interconnection

Related reading

• FERC Order 2023 Site Control Compliance Guide — The full cross-RTO survey of thresholds, instrument types, and compliance workflow.
• PJM Cycle 1 Phase 1 Study Results Guide — What the first true cluster cycle in PJM produced and what it means for Cycle 2.
• CAISO Cluster 15 Scoring Results — How 347 GW of applicants narrowed to 68 GW, broken down by scoring component.
• MISO DPP Site Control Requirements — The Definitive Planning Process stage thresholds and Attachment E mechanics.
• FERC 2023 Compliance: Why 2026 Is the Operational Deadline — The timing argument for getting your evidence package machine-readable now.
• Data Centers vs. Renewables in the Interconnection Queue — The volume pressure that makes automation non-optional.