FERC Order 2023 introduced graduated site control thresholds for ISO New England's interconnection queue. Here's everything you need to navigate compliance across six states, the Forward Capacity Market, and unique New England land encumbrances — from application through commercial operation.
Under FERC Order 2023, ISO-NE requires increasing site control coverage at each queue milestone. Options count at full weight (1.0) through Feasibility Study, are discounted to 0.75 at System Impact Study, and are excluded entirely from Facilities Study onward.
| Queue Stage | Coverage Threshold | Options Allowed | Option Weight | Encumbrance Policy |
|---|---|---|---|---|
| Pre-application | 0% | Yes | 1.0 | Allow |
| Application | 90% | Yes | 1.0 | Flag |
| Feasibility Study | 90% | Yes | 1.0 | Flag |
| System Impact Study | 90% | Yes | 0.75 | Disqualify |
| Facilities Study | 90% | No | 0.0 | Disqualify |
| IA Execution | 100% | No | 0.0 | Disqualify |
| Commercial Operation | 100% | No | 0.0 | Disqualify |
Eligible instruments at IA execution: fee simple, executed lease, easement, ROW agreement. Source: ISO-NE Tariff Schedule 22/23, FERC Order 2023 compliance filing.
For the full cross-RTO comparison, see FERC Order 2023 Thresholds by RTO and Stage.
Queue Entry — 90% Site Control Required
Deposits due, 90% coverage with options at full weight (1.0). Encumbrances flagged but not disqualified
Feasibility Study
90% coverage maintained. Options still count at 1.0 weight. Encumbrances flagged
System Impact Study — Option Weight Drops to 0.75
90% coverage required. Options now discounted to 0.75 weight. Encumbrances disqualified from this stage onward
Facilities Study — Options Excluded
90% coverage required with executed instruments only. All options must be converted by this stage
Interconnection Agreement — 100% Required
100% site control with executed instruments only — no options. Must also satisfy FCM obligation date
Commercial Operation
100% site control with fully executed instruments through operational life
Per-stage thresholds, eligible instruments, option weights, and encumbrance policies for all 7 RTOs under FERC Order 2023.
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How option expirations drop coverage below ISO-NE thresholds and the conversion timeline your land team needs — especially critical with the 0.75 SIS discount.
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Questions covering FERC Order 2023, the 5-filter audit, SNDA requirements, conservation restrictions, and New England-specific encumbrances.
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The most legally consequential encumbrance in New England. When land enrolled in Chapter 61, 61A (agricultural), or 61B (recreational) is converted to a new use, the municipality has 120 days to purchase the parcel at the conversion price. If exercised, the developer loses the parcel entirely. Land teams must verify Chapter 61 status on every Massachusetts parcel before closing site control.
New England land trusts hold conservation restrictions on a significant share of rural parcels across all six states. These restrictions typically prohibit commercial development and cannot be overridden by lease agreements. Unlike mortgages that can be cured with SNDAs, conservation restrictions are permanent and disqualify the parcel from site control coverage.
Six New England states means six different regulatory and siting regimes. Vermont's Act 248 process through the Public Utility Commission can take 36+ months for utility-scale projects. A site control package that passes ISO-NE review can still stall if state permits aren't aligned with queue milestones. No BLM land exists in New England to simplify siting.
ISO-NE's option weight degrades from 1.0 at Application to 0.75 at SIS, then to 0.0 at Facilities Study. Options must be converted to executed leases well before Facilities Study — not just before IA. Land teams relying on option-heavy portfolios need to begin conversions at Application to avoid coverage gaps when options are excluded.
ISO-NE's Forward Capacity Market (FCM) requires capacity resources to maintain site control through the FCM obligation date, which may extend beyond the interconnection agreement execution. Instruments that expire between IA and the FCM obligation date create a compliance gap that can jeopardize capacity supply obligations and trigger financial penalties.
ISO-NE flags encumbrances at Application and Feasibility but disqualifies them from System Impact Study onward. Mortgages, liens, and conservation easements on leased parcels can silently drop coverage below 90%. SNDA agreements cure mortgages, but conservation restrictions cannot be cured and require parcel substitution.
Zonevex parses your lease PDFs, matches parcels to the project boundary, applies ISO-NE's stage-specific thresholds and option weight rules, and tells you exactly where your coverage stands — across all six New England states.
90%
Application threshold
90%
SIS threshold
100%
IA execution
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