Order No. 2023 sets study delay penalties for transmission providers

Order No. 2023 attached penalties to transmission providers that miss interconnection study deadlines. The intent was to make delay expensive for the party that controls the schedule.

The predictable second-order effect is on study content rather than study timing. A provider facing a deadline penalty has an incentive to complete the study on time with conservative assumptions, producing larger identified upgrade sets, rather than to spend additional time refining assumptions that would reduce them.

Whether that effect is material is an empirical question that will be answered by comparing upgrade cost estimates before and after the penalty regime took effect in each region. The comparison is possible because study reports are available to the customers who commissioned them, though not always publicly.

Order No. 2023-A clarified aspects of the penalty structure on rehearing.

For an interconnection customer, the practical response is to engage on assumptions during the study rather than to dispute results after it.

What to watch: whether any provider seeks waiver or modification of deadline penalties on the basis of study complexity.