Summary
Details
- The United States of America (USA)
Mandatory for FERC-jurisdictional transmission providers and, indirectly, for interconnection customers that submit requests. Some regions and entities have variations, but Order 2023 establishes the baseline compliance expectations.
Deep dive
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What’s Required
Order 2023 is implemented through jurisdictional tariffs and pro forma interconnection procedures. Compliance obligations are binding on transmission providers, and developers are indirectly bound through interconnection agreements and queue rules.
1) Tariff compliance filings and enforceable procedures
Transmission providers must file tariff revisions to implement Order 2023 requirements. Once accepted, these become enforceable tariff obligations and the operational rulebook for interconnection customers. FERC’s explainer emphasizes compliance timing and the interconnection reform goal of streamlining processes.
2) Queue discipline and “readiness” obligations for interconnection customers
A core compliance feature is raising the bar for queue entry and retention: stricter site control, milestone requirements, and withdrawal penalties. Developers must plan capital and contracting around these readiness requirements because failure to meet milestones can lead to removal from the queue or significant penalties, affecting project bankability.
3) Cluster study process and study transparency
Order 2023 reinforces cluster studies and standardized study methodologies. Developers must provide technical data on time, respond to study requests, and manage scope changes. A frequent compliance failure mode is inconsistent project data or late updates that trigger restudies, cost increases, and schedule delays.
4) Public interconnection information tools and compliance enforcement
FERC’s compliance oversight increasingly focuses on transparency tools and how queue information is published and updated. Secondary reporting indicates compliance proceedings have required additional filings for RTOs/ISOs to meet public interconnection information expectations.
5) Governance across regions and partial compliance findings
Because Order 2023 is implemented region-by-region, compliance risk is fragmented. Developers in multiple markets must track differences in accepted tariffs and compliance orders. A practical compliance requirement is maintaining a jurisdictional playbook: queue entry standards, study timelines, cost allocation conventions, and dispute mechanisms.
Important Deadlines
Compliance deadlines for Order 2023-A referenced by FERC (including extensions tied to Federal Register publication).
Ongoing compliance proceedings and orders in 2025–2026 reflect continued implementation oversight.
Current Status
In force with ongoing compliance implementation through tariff proceedings, including partial compliance findings and required additional filings in certain regions. The operational impact is immediate for interconnection customers because queue rules and milestone requirements affect project timelines and costs.
Penalties for Non-Compliance
For transmission providers: FERC enforcement for tariff non-compliance, refunds, and remedial orders.
For developers: queue withdrawal penalties, loss of queue position, forfeiture of deposits, and inability to reach commercial operation on schedule.
Contractual defaults under financing and offtake agreements if interconnection milestones are missed.
Examples of Known Violations
Common failure modes include:
Developers are entering queues without sufficient site control or data maturity.
Missed milestone deadlines leading to removal or penalties.
Late technical changes triggering restudies and cost reallocations.
Transmission providers are failing to implement transparency tools or required procedural steps consistently, leading to compliance orders.
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