Order No. 2023: the interconnection reform that made clustering the default

Order No. 2023 is FERC''s final rule reforming the pro forma Large Generator Interconnection Procedures and Large Generator Interconnection Agreement. It responded to a record of queue backlogs, repeated restudies and study timelines that the Commission found were not being met.

Its principal elements are the shift from serial first-come, first-served processing to a first-ready, first-served cluster study process; stronger commercial readiness requirements, including site control and escalating deposits, to filter speculative requests; penalties payable by transmission providers that miss study deadlines; and a requirement to evaluate alternative transmission technologies in the study process.

The order operates through compliance. Each transmission provider must file tariff revisions implementing the pro forma, and a region may retain a variation only on a showing that it is consistent with or superior to the pro forma. Those filings, and the rehearing order that followed, form the body of interconnection reform litigation now proceeding docket by docket.