FERC Order 2023 introduced graduated site control thresholds for PJM's new cycle-based queue. Here's everything you need to submit a deficiency-free Cycle 1 application and maintain compliance through GIA execution.
Under FERC Order 2023, PJM requires increasing site control coverage at each queue milestone. Options count at full weight (1.0) through Facilities Study but are excluded at IA execution.
| Queue Stage | Coverage Threshold | Options Allowed | Option Weight | Encumbrance Policy |
|---|---|---|---|---|
| Pre-application | 0% | Yes | 1.0 | Allow |
| Application | 50% | Yes | 1.0 | Flag |
| Feasibility Study | 50% | Yes | 1.0 | Flag |
| System Impact Study | 90% | Yes | 1.0 | Disqualify |
| Facilities Study | 90% | Yes | 1.0 | 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: PJM Manual M-3.1S, FERC Order 2023 compliance filing.
For the full cross-RTO comparison, see FERC Order 2023 Thresholds by RTO and Stage.
Application Window Closes
Study deposit + readiness deposit + 50% site control required
Cluster Study Begins
Feasibility + System Impact studies run in parallel for the cluster
Decision Point 1
Proceed or withdraw. 90% site control required for SIS phase
Decision Point 2
Facilities study allocation. Network upgrade cost assignments begin
IA Execution
100% site control with executed instruments only — no options
35-page playbook, 49-item checklist, financial calculator, POI workbook, readiness scorecard, deficiency cure playbook, and more.
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Model study deposits, readiness deposits, withdrawal penalties, and total capital exposure across three network upgrade cost scenarios.
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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 PJM thresholds and the conversion timeline your land team needs.
12 questions covering FERC Order 2023, the 5-filter audit, SNDA requirements, Williamson Act, and PJM Cycle 1 deadlines.
Pre-Order 2023 options are running into post-Order 2023 milestones. If your option expires before IA execution, you lose coverage on those parcels — and options are excluded entirely at 100% threshold. Land teams need 12+ months lead time to negotiate lease conversions.
PJM flags encumbrances at application but disqualifies them from System Impact Study onward. Mortgages, liens, and conservation easements on leased parcels can silently drop your coverage from 90% to below threshold. SNDA agreements are the standard cure.
Post-Decision Point 1, withdrawing means forfeiting your entire study deposit plus a share of assigned network upgrade costs. For a 200 MW project with $50M in upgrades, that's $500K+ in study deposits plus potentially millions in upgrade cost allocation.
PJM spans 13 states plus DC. State permitting timelines range from 75 days (Illinois county-level) to 388 days (Maryland PSC). A site control package that passes PJM review can still stall if state permits aren't aligned with queue milestones.
Zonevex parses your lease PDFs, matches parcels to the project boundary, applies PJM's stage-specific thresholds, and tells you exactly where your coverage stands — before you file.
50%
Application threshold
90%
SIS threshold
100%
IA execution
5
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