FERC Order 2023 Site Control Coverage Thresholds by RTO and Stage

Why a single threshold number is misleading

Ask a developer "what's the site control threshold for PJM?" and you'll get one answer: "100%." Ask again at application and the real answer is 50%. The threshold is not a property of the RTO alone — it's a function of three variables: RTO, queue stage, and instrument type.

FERC Order 2023 formalized what some RTOs already practiced informally: graduated site control requirements that increase as a project advances through the interconnection queue. At early stages, options-to-lease count at full weight. By IA execution, most RTOs exclude options entirely and require 100% coverage with executed instruments only.

This article consolidates the threshold data across all seven RTOs — the six FERC-jurisdictional markets (PJM, MISO, CAISO, ISO-NE, NYISO, SPP) plus ERCOT — broken down by stage, eligible instrument types, option weights, encumbrance handling, and BLM ROW requirements. It is the reference table that doesn't exist anywhere else.

How FERC Order 2023 changed site control

Before Order 2023 (effective January 2024 for most RTOs), site control requirements varied wildly. Some RTOs had no formal threshold at application. Others required "reasonable demonstration" without defining what that meant. The result was a queue clogged with speculative projects that had little or no land control.

Order 2023 changed three things:

1. Graduated thresholds. RTOs must define stage-specific coverage percentages, increasing from application through IA execution. No more single-threshold-fits-all.
2. Instrument type eligibility. Options-to-lease are explicitly allowed at early stages but must be converted to executed instruments by IA execution. Each RTO defines exactly which instrument types qualify at each stage.
3. Compliance filing timeline. Each RTO filed its compliance plan with FERC. CAISO's compliance filing (ER24-2042) was accepted in May 2025 with an effective date of June 12, 2024. PJM, MISO, ISO-NE, NYISO, and SPP implemented their rules effective January 1, 2024.

The ERCOT exception. ERCOT is not FERC-jurisdictional. It does not have formal site control thresholds mandated by FERC Order 2023. The thresholds shown for ERCOT in this article are internal best-practice recommendations based on industry conventions, not regulatory requirements.

The 5-filter coverage audit framework

A site control coverage percentage is not simply "acres controlled / total project acres." Before an instrument's acreage counts toward coverage, it must pass five filters:

1. Active status. The instrument has not expired, been terminated, or been superseded. Only instruments in executed or recorded status count.
2. Eligible instrument type. The instrument type (fee simple, executed lease, option-to-lease, easement, etc.) must be in the RTO's eligible list for the current queue stage. At PJM IA execution, for example, options are excluded entirely.
3. Encumbrance policy. Parcels with active encumbrances (Williamson Act, conservation easements, Chapter 61A ROFR) may be disqualified, flagged, or allowed depending on the RTO's policy at the current stage.
4. Owner signature verification. If any natural-person owner on the instrument has not signed, the instrument's coverage_effective flag is false and its acreage is excluded from coverage.
5. BLM ROW status gate. For BLM right-of-way permits (relevant primarily in CAISO), the permit must have reached a minimum status (e.g., grant_issued at IA execution) to count toward coverage.

Only after an instrument's parcels pass all five filters does its acreage enter the spatial union (PostGIS ST_Union) that computes coverage percentage against the project boundary.

RTO-by-stage reference table

The following tables show the threshold, eligible instruments, option treatment, encumbrance policy, and BLM ROW requirements for each RTO at key queue stages. Data is current as of the FERC Order 2023 compliance effective dates (January 1, 2024 for most RTOs; June 12, 2024 for CAISO).

PJM

Source: PJM M-3.1S site control requirements.

Eligible instruments at IA execution: fee simple, executed lease, easement, ROW agreement. Setback buffers required from application onward per state-specific rules.

MISO

Source: MISO GIP, FERC Order 2023 compliance filings.

MISO maps its Definitive Study Agreement (DSA) stage to "system impact" in the FERC framework. A conversion deadline alert fires 90 days before IA execution for any project containing unconverted options.

CAISO

Source: CAISO GIDAP BPM, FERC Order 2023 compliance filing ER24-2042 (accepted May 2025). Effective date: June 12, 2024.

CAISO is unique in three ways: (1) it uses cluster study phases instead of the traditional feasibility/system impact stages, (2) it has explicit BLM right-of-way status gates at every stage, and (3) option weight decreases gradually from 1.0 at cluster study to 0.75 at facilities to 0.0 at IA execution. Options are tracked at 0.5 weight even at pre-application for internal gap analysis.

Eligible instruments at IA execution: fee simple, executed lease, easement, BLM ROW permit. All Williamson Act non-renewal notices must be filed and BLM ROW must have reached grant_issued status.

ISO-NE

Source: ISO-NE GIS, FERC Order 2023 compliance filing.

ISO-NE projects in Massachusetts face Chapter 61A ROFR risk on agricultural parcels, where municipalities have 120 days to exercise their right of first refusal after a Notice of Intent to Convert is filed. Parcels with pending ROFR have blocks_coverage=true and are excluded from coverage calculations.

NYISO

Source: NYISO GIP, Article 17 ORES requirements.

NYISO's site control deadline is derived from the class year applicant acceptance deadline. AG District notification under NY Agriculture and Markets Law §305-a must be complete before system impact submission.

SPP

Source: SPP Tariff Attachment V.

SPP follows the standard FERC Order 2023 pattern closely. Eligible instruments at IA execution: fee simple, executed lease, easement, ROW agreement.

ERCOT

Source: ERCOT GIM. ERCOT is not FERC-jurisdictional. These thresholds are internal best-practice recommendations, not regulatory requirements.

ERCOT's thresholds ramp more gradually than FERC-jurisdictional RTOs: 25% at application, 50% at feasibility, 75% at system impact. This reflects ERCOT's less prescriptive approach — the thresholds are governance benchmarks rather than compliance gates. However, project finance lenders and offtake counterparties increasingly require site control evidence that aligns with FERC-jurisdictional standards, making these benchmarks effectively binding for most commercial-scale projects.

Cross-RTO summary: key stages

* ERCOT thresholds are internal best-practice benchmarks, not FERC-mandated requirements.

The pattern is consistent: every FERC-jurisdictional RTO requires 100% coverage with executed instruments (no options) at IA execution. ERCOT follows the same pattern as an industry best practice. The differences are in the early-stage thresholds, stage naming conventions, and market-specific requirements like CAISO's BLM ROW gates, MISO's DSA conversion deadline, and ERCOT's more gradual ramp.

Why options are treated differently

An option-to-lease gives a developer the right to execute a lease but is not itself an executed lease. At early stages, RTOs accept this because developers need flexibility to assemble land packages before committing to full lease execution costs. As the project advances, that flexibility diminishes.

Option weight follows a lifecycle across stages:

• Early stages (application, feasibility): Options count at full weight (1.0) in all RTOs. The rationale: developers need time to negotiate executed leases, and requiring 100% executed instruments at application would create an impossible chicken-and-egg problem with interconnection study costs.
• Mid stages (system impact, facilities): Most RTOs still accept options at 1.0. CAISO is the exception — at facilities study, CAISO discounts options to 0.75 weight, signaling that conversion should begin.
• IA execution: All RTOs set allow_options = false. Option types are removed from the eligible instruments list entirely. Option weight drops to 0.0. Any acreage covered only by unconverted options falls out of the coverage calculation.

This creates a critical conversion window. A developer entering the queue with 95% coverage (50% fee simple, 45% options) must convert those options to executed leases before IA execution or face a coverage deficiency.

Common misconceptions

"One RTO, one threshold"

This was approximately true before FERC Order 2023 for some RTOs. It is no longer true for any. Every RTO defines different thresholds at different stages. A developer who thinks PJM's threshold is "100%" will overprepare at application (where 50% suffices) and may allocate resources inefficiently.

"Options count at IA execution"

They do not, in any RTO. This is the single most expensive mistake a developer can make. If your coverage calculation includes options at IA execution, your actual compliant coverage is lower than you think. CAISO begins discounting options even earlier (0.75 weight at facilities study).

"Conservation easements don't matter"

Conservation easements, Williamson Act land, and Chapter 61A/61B classifications can all cause parcels to be excluded from coverage when the encumbrance policy is disqualify. At system impact and later stages for most RTOs, these parcels are removed from the spatial union entirely. A project that looks like 92% coverage can drop to 85% after encumbrance filtering.

"BLM ROW permits just need to be filed"

For CAISO, filing an application (application_submitted) is sufficient at pre-application. But by IA execution, the BLM ROW must have reached grant_issued status. The BLM permitting process can take 2-5 years. Developers who file late risk having their coverage disqualified at IA execution even if the underlying land is controlled.

"ERCOT follows FERC rules"

ERCOT operates outside FERC jurisdiction. It has no legally mandated site control thresholds. The thresholds used in practice are internal governance benchmarks, not regulatory requirements. However, project finance lenders and offtake counterparties increasingly require site control evidence that aligns with FERC-jurisdictional standards.