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.
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-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: 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.
Pre-Application Screening
0% site control required. Begin land acquisition and feasibility assessment across target states
DISIS Application Submission
50% site control required + study deposits. Encumbrances flagged but not yet disqualifying
Feasibility Study
50% site control maintained. Continue land acquisition toward 90% target
System Impact Study
90% site control required. Encumbrances now disqualify coverage. Decision point: proceed or withdraw
Facilities Study
90% site control maintained. Network upgrade cost assignments finalized
IA Execution
100% site control with executed instruments only — no options. All leases must be fully executed
Commercial Operation
100% site control maintained through commercial operation date
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 SPP thresholds and the conversion timeline your land team needs across wind-heavy territories.
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Common questions covering FERC Order 2023, the 5-filter audit, SNDA requirements, tribal land considerations, and multi-state compliance.
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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.
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.
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.
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.
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
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