Frequently Asked Questions

FERC Order 2023 is a federal regulation issued in July 2023 that reformed the interconnection queue process across all U.S. RTOs. It replaced serial, first-come-first-served queues with a clustered study process that requires developers to demonstrate commercial readiness — including site control — at every queue milestone.

Projects that cannot prove compliant site control at each stage are withdrawn automatically. The rule applies to PJM, MISO, CAISO, ISO-NE, NYISO, SPP, and indirectly influences ERCOT.

Source: FERC Explainer

Each RTO sets its own stage-specific coverage thresholds:

*CAISO excludes options at cluster study entry.

Read the full breakdown: FERC Order 2023 Coverage Thresholds by RTO and Stage

Eligible site control instruments include:

• Fee ownership — outright purchase of the land
• Leases — long-term land lease for development
• Options to purchase or lease — right but not obligation to acquire (excluded at some stages by CAISO)
• Easements — right to use land for a specific purpose

The instrument must be active (not expired), cover the project footprint, and be signed by all required owners. Each RTO may treat instruments differently at each stage.

If an option-to-lease expires before a queue milestone (such as IA execution), the underlying acreage is excluded from the coverage calculation. This can drop total site control below the RTO's required threshold, potentially causing the interconnection request to be rejected.

Most options have 1-3 year terms, while interconnection studies can take 3-5 years. Developers must actively track option expiration dates against milestone timelines and convert options to full leases before critical deadlines.

Read more: Option-to-Lease Expiration and Interconnection Milestones

1. Active status — the instrument has not expired or been terminated
2. Eligible instrument type — the RTO accepts the instrument at the current stage
3. Encumbrance policy — mortgages, liens, or conservation easements do not block coverage
4. Owner signature verification — all required owners have signed
5. BLM ROW status — for federal land, the right-of-way meets minimum status

Failing any single filter on a parcel excludes that parcel from the coverage calculation. A single missing signature can drop coverage below threshold.

A Subordination, Non-Disturbance, and Attornment (SNDA) agreement makes a mortgage junior to a lease, protecting the developer's site control through foreclosure.

Without an SNDA, an existing mortgage has senior priority — if the lender forecloses, the lease is extinguished. While no RTO currently disqualifies sites based on subordination status, project lenders and tax equity investors will not finance without subordination resolution.

The Williamson Act allows California landowners to receive reduced property tax assessments in exchange for restricting land use to agriculture for a minimum of 10 years. Solar projects on Williamson Act land may face restrictions depending on the county's policies.

Some counties allow solar as a compatible use; others require non-renewal (triggering a 9-year phase-out). CAISO may require documentation that the contract has been non-renewed before counting the parcel toward site control coverage.

Read more: Williamson Act Land and CAISO Interconnection Queue

The application deadline for PJM Cycle 1 is April 27, 2026. There are no extensions.

Applications must include: a completed application form, study deposit ($75,000–$400,000 depending on project size), Readiness Deposit No. 1 ($4,000/MW), evidence of 100% site control, and demonstration of commercial readiness.

Get prepared: Download the free PJM Cycle 1 Toolkit | Calculate your deposits

PJM's reformed process includes three Decision Points (DP1, DP2, DP3) following each study phase. At each, customers must decide whether to continue or withdraw.

• RD1 at application: $4,000/MW
• RD2 at DP1: 10% of allocated network upgrade costs minus RD1
• RD3 at DP2: 20% of allocated costs minus prior deposits

Withdrawal penalties increase at each Decision Point. Use the calculator to model your total exposure.

A Bureau of Land Management (BLM) right-of-way (ROW) is a permit authorizing the use of federal public lands for energy generation. For solar and wind projects on BLM-administered land, the ROW status affects site control coverage — particularly in CAISO.

CAISO requires that parcels on federal land have at least a "granted" BLM ROW status before counting toward coverage at certain study phases. The BLM ROW process can take 2-5 years.

Zonevex automates FERC Order 2023 site control validation for utility-scale solar and wind developers. It works in four steps:

1. Document parsing — AI extracts legal descriptions, instrument types, expiration dates, and owner signatures from lease PDFs
2. Cadastral matching — PostGIS matches parsed descriptions to county parcel boundaries, flagging overlaps, gaps, and encumbrances
3. RTO rule engine — stage-aware 5-filter coverage audit against each RTO's rules at every queue milestone
4. Compliance reports — RTO-specific export packages with full audit trails

Zonevex supports PJM, MISO, CAISO, ISO-NE, NYISO, and SPP. Book a demo to see it in action.