Did RRI require 100% site control at application?

Yes. RRI applicants were required to demonstrate 100% site control of the Generating Facility, including the high side of the Main Power Transformer (MPT), at the Application Deadline of March 14, 2025. The standard is identical to Cycle 1 and follows Tariff Part VII, Subpart A, Section 302.

What was the minimum term required on RRI site control evidence?

Site control evidence had to demonstrate exclusivity for a minimum term of one year from the Application Deadline (March 14, 2025). For RRI projects, that minimum coverage period expired around March 14, 2026, which means most RRI projects now require refreshed or extended evidence ahead of TC2 Decision Point I submissions.

Can RRI projects add new parcels at Decision Point I?

Yes, with two restrictions. New parcels added at DP1 must be either adjacent to the initial Site submitted at application, or covered by a recorded easement to the initial Site. Each addition must independently satisfy the Section 7.1 requirements for term, exclusivity, and conveyance. Demonstration of site control for parcels removed from the original Site is not required.

How does RRI site control differ from Cycle 1?

The site control evidentiary standard is identical to Cycle 1: same Section 302 instruments, same density rules, same Officer Certification. The differences are downstream: RRI projects waive the right to a one-year milestone extension under Section 6.5 of the form GIA, must be offered into the RPM auction or FRR for ten consecutive delivery years, and cannot change MFO or CIR before GIA execution.

Is the RRI Deposit refundable?

The RRI Deposit ($4,000/MW) is fully refundable to projects that were not selected. For selected projects, 50% becomes at-risk at the start of TC2 Phase II and 100% becomes at-risk when the GIA or WMPA is accepted by FERC. The full deposit is refunded when the project achieves the commercial operation milestone and is forfeited if RRI is withdrawn or the GIA/WMPA is terminated.

PJM Reliability Resource Initiative (RRI) Site Control: What the 51 Selected Projects Need to Know in TC2

The 51 in plain numbers

On May 2, 2025, PJM selected 51 projects from a pool of 94 RRI applications. The cap was originally 50 projects; a tie in the weighted scoring pushed the count to 51. Together, the selected portfolio represents 9,361 MW of unforced capacity (UCAP) — 2,108 MW from 39 uprates and 7,253 MW from 12 new-build projects.

The technology mix is heavier on thermal and nuclear than the typical PJM queue. Of the 12 new-build projects, six are gas combined cycle, five are battery storage, and one is nuclear. The 39 uprates apply to existing natural gas, nuclear, coal, and onshore wind assets. Roughly 90% of the portfolio is targeted for commercial operation by 2030, with the remainder by 2031.

RRI was created under FERC Docket No. ER25-712-000, filed December 14, 2024, and accepted by FERC on February 11, 2025. The implementing rules sit in Tariff Part VII, Subpart C, Sections 305 and 306, with site control governed by the standard Tariff Part VII, Subpart A, Section 302 and Manual 14H Section 7.

Why this guide is for the next 60 days

The site control evidence each RRI applicant submitted on or before March 14, 2025 had to demonstrate exclusivity for a minimum term of one year from the Application Deadline. That minimum term expired on or around March 14, 2026 — about six weeks ago. RRI projects in TC2 are now operating either on extended/refreshed instruments or on instruments that have lapsed below the Section 302 standard.

Decision Point I is the first place that gap becomes visible to PJM. At DP1, RRI projects must submit a refreshed Site Control Review Spreadsheet, with the Document Details and Decision Point 1 tabs both completed. Site control evidence is compared against the initial Site established at application. Anything missing, expired, or non-conforming converts into a deficiency under the Application Review Phase procedure in Tariff Part VII, Subpart C, Section 306(B) — the same 10-business-day cure clock that governs Cycle 1 applicants.

How RRI site control evidence works

RRI applicants submitted site control under the standard PJM evidentiary framework. There is no separate RRI-only evidence pathway. The accepted instruments at application were:

Deed — for owned property
Lease — fully executed, not a memorandum
Option to lease or option to purchase — with a minimum one-year term from the Application Deadline
Site control in any form the entity issues — for sites controlled by a government entity

Three categories of evidence were explicitly disqualified, and remain disqualified going into DP1:

A memorandum of any underlying instrument
Evidence of intent to purchase
Site control on a parcel that is the subject of an interconnection request in an adjacent RTO/ISO

Evidence had to demonstrate exclusivity, term (minimum one year from the Application Deadline), and conveyance. This is the same triad applied to all PJM new service requests under Section 302.

RRI density rules and the PE-stamped layout

Manual 14H Section 7.1.6 sets minimum acreage per technology, applied identically to RRI applicants and Cycle 1 applicants. The figures below were the controlling standard at the March 14, 2025 RRI Application Deadline and remain the standard at TC2 DP1.

Technology	Required Acreage
Solar	5 acres/MW
Wind	30 acres/MW
Battery Storage	1 acre per 100 MWh
Synchronous Generator (gas, nuclear, coal, etc.)	10 acres per facility

Where actual project density exceeded what Manual 14H allows, the applicant had to provide a Site Plan stamped by a Professional Engineer licensed in the state of the facility location. The PE-stamped drawing must specify the proposed generation arrangement and the Maximum Facility Output. The same rule controls at DP1: any density change between application and DP1 requires a refreshed PE-stamped layout.

The RRI Officer Certification — same form, sharper consequences

Every RRI application required a Site Control Officer Certification executed by an officer of the Project Developer entity, not the parent. The certification serves as the Section 302 attestation and as the verification of the Critical Path Construction Schedule. PJM's published instruction is unambiguous: any application without the attestation is considered incomplete.

For RRI projects, the consequences of a defective Officer Certification are sharper than in Cycle 1 because of the upstream commitments built into Sections 305 and 306. An RRI Project that obtains a GIA or WMPA must be offered into the Reliability Pricing Model auction or committed to a Fixed Resource Requirement plan for ten consecutive delivery years. The categorical capacity must-offer exemptions in Tariff Attachment DD, Section 6.6A do not apply. A flawed certification at DP1 that triggers withdrawal forfeits the RRI Deposit and unwinds those downstream commitments.

Parcel modifications between Application, DP1, and DP3

The Site submitted at the RRI Application Deadline established the initial Site — the spatial baseline against which DP1 and DP3 submissions are compared. Manual 14H Section 7.2 defines a precise modification grammar at each Decision Point, updated in PJM's July 23, 2025 Manual 14H update (FERC Docket EL25-22-000 and ER25-1544-000, accepted June 10, 2025).

Stage	Site Control Demonstration	Allowed Modifications
Application Phase	Required — establishes initial Site	n/a
Decision Point I	Required — compared to Application	Add adjacent parcels OR parcels with recorded easement to initial Site; remove any parcels without demonstration
Decision Point II	Not required	Changes evaluated against DP3 modification rules
Decision Point III	Required — compared to DP1	Same as DP1; modifications to interconnection facilities or switchyard parcels do not affect issued System Impact Studies
Post-WMPA/GIA	Required — per Schedule A	Attestation that change does not impact milestones, OR Necessary Studies Agreement required

The two operational rules to internalize for RRI projects approaching DP1 are: (1) any parcel addition must be adjacent or have recorded easement evidence back to the initial Site, and (2) the Generating Facility, including the high side of the Main Power Transformer, must continue to be covered at 100% under the density rules.

Cycle 1 vs RRI vs Transition Cycle #2: site control compared

The single most useful comparison for an RRI applicant evaluating where they sit relative to peers in the PJM queue is across the three concurrent application paths. The site control evidentiary standard is identical across all three. The financial and commercial consequences of a deficiency are not.

Dimension	Cycle 1	RRI	TC2 (legacy)
Application Deadline	April 27, 2026	March 14, 2025	December 17, 2024
Site Control standard	Section 302 / M-14H §7	Section 302 / M-14H §7	Section 302 / M-14H §7
Coverage at application	100% Generating Facility + MPT high side	100% Generating Facility + MPT high side	Per legacy queue rules at original submission
Term minimum	1 year from Application Deadline	1 year from March 14, 2025	Per original submission
Officer Certification	Cycle 1 template	RRI template	Pre-existing attestation
Deposit at risk	Study + Readiness	Study + Readiness + RRI Deposit	Existing deposits
Capacity must-offer commitment	Standard	RPM/FRR for 10 consecutive delivery years	Standard
One-year milestone extension	Available under §6.5 of GIA	Waived — not available	Available under §6.5 of GIA

The deposit math behind the urgency

Each selected RRI project posted three deposits at the March 14, 2025 Application Deadline. Two are standard for any TC2 applicant; the third is RRI-specific.

Study Deposit — tiered by project size from $75,000 (0–20 MW) to $400,000 (>750 MW). Ten percent is non-refundable.
Readiness Deposit — $4,000/MW of the larger of MW energy or MW capacity. Refundable if not selected; otherwise at risk through Phase II per Section 306(A)(5).
RRI Deposit — an additional $4,000/MW. Fully refundable to non-selected applicants. For selected projects, 50% becomes at-risk at the start of TC2 Phase II, and 100% becomes at-risk on FERC acceptance of the GIA or WMPA. Forfeited if the project withdraws or the GIA/WMPA is terminated. Refunded in full at commercial operation.

For a 250 MW selected RRI project, the RRI Deposit alone is $1 million. Combined with the Readiness Deposit and Study Deposit, the total at-risk financial exposure at FERC acceptance of the GIA can exceed $2.3 million. Site control problems at DP1 are the single most preventable trigger for that exposure to become a forfeiture.

What RRI projects should be doing in the next 60 days

For the 51 selected projects working toward TC2 DP1, three actions matter more than any others in the second quarter of 2026.

Refresh expired or expiring instruments. Anything with a one-year term keyed to the March 14, 2025 Application Deadline has lapsed below the Section 302 minimum. Execute extensions or replacements that carry a clear term of at least 12 months from the projected DP1 submission date.
Reconcile entity names across instruments. If site control was assembled in a development LLC and the project has since been assigned to an SPV, a recorded assignment or joinder is required — not just an internal corporate resolution. PJM's review staff verifies the chain on its face, not on representation.
Update the Site Control Review Spreadsheet. Both the Document Details tab and the Decision Point 1 tab need to be current. The spreadsheet is the document PJM uses to drive its DP1 deficiency review — if the spreadsheet has not been updated, the application is treated as not having been refreshed.

Glossary

RRI — Reliability Resource Initiative. PJM's one-time acceleration of shovel-ready high-reliability projects, established under FERC Docket ER25-712-000.
UCAP — Unforced Capacity. The capacity rating used by PJM in the RPM auction and the basis for the RRI weighted scoring criteria.
ELCC — Effective Load Carrying Capability. A class-based capacity accreditation method used in RRI's market impact scoring (worth up to 20 points).
TC2 — Transition Cycle #2. The second of two transition cycles bridging the legacy serial queue and the new cycle-based process. RRI projects join TC2 after selection.
ASA — Application and Studies Agreement. The executed agreement governing the RRI applicant's participation in TC2.
WMPA — Wholesale Market Participation Agreement. The agreement under which a generation project sells output into PJM markets.
GIA — Generator Interconnection Agreement. Tariff Part IX, Subpart B form agreement, governing physical interconnection.
MFO / CIR — Maximum Facility Output / Capacity Interconnection Rights. The two MW values used to size deposits, modeling, and capacity offers. RRI projects are barred from changing either before GIA execution.
MPT high side — The high-voltage side of the Main Power Transformer. Manual 14H requires 100% site control for the Generating Facility including the MPT high side.
RPM — Reliability Pricing Model. PJM's capacity market auction. RRI projects are required to offer for 10 consecutive delivery years.
FRR — Fixed Resource Requirement. The alternative to RPM for capacity commitments, used by load-serving entities that opt out of RPM.