FERC Order 2023 Effective: January 1, 2024

SPP Interconnection
Site Control Compliance

FERC Order 2023 introduced graduated site control thresholds for SPP's DISIS cluster process across 14 central US states. Here's everything you need to navigate the queue from application through commercial operation — including tribal land, multi-state ag law, and wind competition challenges unique to SPP territory.

SPP Site Control Thresholds by Stage

Under FERC Order 2023, SPP requires increasing site control coverage at each queue milestone per Tariff Attachment V-R Section 3.2. 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-application0%Yes1.0Allow
Application50%Yes1.0Flag
Feasibility Study50%Yes1.0Flag
System Impact Study90%Yes1.0Disqualify
Facilities Study90%Yes1.0Disqualify
IA Execution100%No0.0Disqualify
Commercial Operation100%No0.0Disqualify

Eligible instruments at IA execution: fee simple, executed lease, easement, ROW agreement. Source: SPP Tariff Attachment V-R Section 3.2, FERC Order 2023 compliance filing.

For the full cross-RTO comparison, see FERC Order 2023 Thresholds by RTO and Stage.

What Changed for SPP Under FERC Order 2023

Before: DISIS Without Graduated Thresholds

  • • Single site control demonstration at one milestone
  • • Speculative wind and solar projects congested the queue
  • • No formal graduated coverage requirements
  • • Limited encumbrance screening
  • • Multi-year delays common across 14-state footprint

After: DISIS Cluster with Graduated Thresholds

  • 50% at application — proves baseline commitment per Tariff Attachment V-R
  • 90% at SIS — most acreage must be under control before system studies
  • 100% at IA execution — full control with executed instruments only, no options
  • Encumbrance enforcement — flagged early, disqualified from SIS onward
  • Decision points — withdraw-or-proceed gates to clear speculative projects

SPP DISIS Queue Timeline

Pre-App

Pre-Application Screening

0% site control required. Begin land acquisition and feasibility assessment across target states

Application

DISIS Application Submission

50% site control required + study deposits. Encumbrances flagged but not yet disqualifying

Feasibility

Feasibility Study

50% site control maintained. Continue land acquisition toward 90% target

SIS

System Impact Study

90% site control required. Encumbrances now disqualify coverage. Decision point: proceed or withdraw

Facilities

Facilities Study

90% site control maintained. Network upgrade cost assignments finalized

IA Exec

IA Execution

100% site control with executed instruments only — no options. All leases must be fully executed

COD

Commercial Operation

100% site control maintained through commercial operation date

SPP Site Control Resources

Common SPP Site Control Risks

Tribal Land Complexity

SPP's footprint includes several tribal reservations across Oklahoma, Kansas, Nebraska, and the Dakotas. Tribal land leases require Bureau of Indian Affairs (BIA) approval, which adds 6–18 months to lease execution timelines. Projects with tribal parcels need to begin BIA engagement well before the 90% SIS threshold to avoid coverage gaps.

Multi-State Agricultural ROFR Laws

Agricultural right-of-first-refusal laws vary significantly across SPP's 14-state territory. Oklahoma, Kansas, and Nebraska each have different ROFR rules for agricultural land conversion to energy use. A site control package valid in one state may face unexpected ROFR claims in another, requiring state-by-state legal review for multi-state projects.

Wind and Solar Competition for Land

SPP is the largest wind energy market in the US, and growing solar deployment is now competing for the same transmission-adjacent parcels. Landowners with existing wind options may be reluctant to negotiate solar leases, and overlapping project boundaries create encumbrance risks. Developers need clear title searches across both wind and solar lease registries.

Option Expiration in Long Queue Cycles

SPP's DISIS cluster process can take multiple years from application to IA execution. Options negotiated early in development frequently expire before the 100% IA execution milestone. Since options are excluded entirely at IA execution, land teams need to negotiate lease conversions 12+ months ahead or risk losing coverage on critical parcels.

Automate SPP Site Control Compliance

Zonevex parses your lease PDFs, matches parcels to the project boundary, applies SPP's stage-specific thresholds, and tells you exactly where your coverage stands — across all 14 states in SPP territory.

50%

Application threshold

90%

SIS threshold

100%

IA execution

5

Audit filters

Official SPP Resources