Order No. 2023 compliance filings are on record; reported study timelines vary by region
Compliance filings record procedural conformity. Operator reports state study durations by cycle, with dates.
Order No. 2023 was issued in July 2023. Compliance filings followed, rehearing was addressed in Order No. 2023-A, and every organised market now operates some form of cluster study with commercial readiness requirements and study deadlines.
That is a substantial administrative achievement and a limited commercial one. Time to power is a function of study duration, upgrade construction, equipment delivery and host utility scheduling. Reform addressed the first directly, the second indirectly through cost allocation, and the last two not at all.
The honest position at this point is that the reform's effect is unproven rather than absent. The evidence will come from the first cohort of projects to pass entirely through a new-process cluster to energisation, and that cohort has not arrived.
Readers underwriting projects on the assumption that reform has shortened schedules should note that no published dataset supports that assumption yet.
What to watch: the first completed new-process cluster in any region, and the interval from cluster close to first energisation within it.
Sources
- 01
Order No. 2023, Improvements to Generator Interconnection Procedures and Agreements
FERC · RM22-14-000 · filed 2023-07-28 · retrieved 2026-08-08
- 02
Preliminary monthly electric generator inventory
U.S. Energy Information Administration · EIA-860M · retrieved 2026-08-08
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