A generation project is not built the moment it is announced; it is built after it clears the interconnection queue. The queue is the formal study process, run by the transmission provider under FERC-jurisdiction tariffs, that every proposed generator or storage facility must complete to connect to the grid. The studies identify the network upgrades the new resource requires, assign the cost of those upgrades, and set the terms of the interconnection agreement. Queued is not built — a megawatt sitting in a queue is a study application, not an operating asset, and the gap between the two has become the binding constraint on solar, wind, and storage deployment.

The Federal Energy Regulatory Commission addressed that constraint directly in Order No. 2023, issued in July 2023. The Commission described the problem the reform targets in its own words:

The Federal Energy Regulatory Commission (Commission or FERC) is adopting reforms to its pro forma Large Generator Interconnection Procedures, pro forma Small Generator Interconnection Procedures, pro forma Large Generator Interconnection Agreement, and pro forma Small Generator Interconnection Agreement to address interconnection queue backlogs, improve certainty, and prevent undue discrimination for new technologies.— Improvements to Generator Interconnection Procedures and Agreements (Order No. 2023), source

From first-come to first-ready cluster study

The core mechanical change is in how projects are studied. Under the prior framework, projects were generally studied one at a time, in the order they applied — a serial, first-come process in which a single early-queue project that later withdrew could force restudies of everything behind it, propagating delay down the line. Order No. 2023 replaces that with a grouped approach. The final rule states that the Commission adopts reforms to, among other things, "implement a first-ready, first-served cluster study process" and to "increase the speed of interconnection queue processing." Cluster study evaluates a group of projects together rather than sequentially, and the first-ready, first-served principle prioritizes projects that have demonstrated readiness — through site control and deposits — over those that are merely early in line.

The shift matters because the old process let speculative applications clog the queue. A project could file early to hold a place without having secured land, financing, or offtake, and its presence shaped the studies and cost allocations for every later applicant. By conditioning queue position on readiness and increasing the deposits and site-control requirements, the order is structured to push unready projects out and let buildable ones advance. The order also adds financial penalties for transmission providers that miss study deadlines, putting time pressure on both sides of the process.

A cluster study works by analyzing all the projects in a defined group against the grid as it would exist with those projects added, then allocating the cost of the network upgrades that the group collectively triggers among its members. This is different from the serial method, where each project was studied against a grid that already assumed every earlier project in line, so that a single withdrawal upstream could change the results for everyone downstream and force restudies. Grouping the analysis reduces that cascade of restudies and gives applicants a clearer, more stable picture of the upgrades and costs they face. To enter and advance through the cluster process, Order No. 2023 raises commercial-readiness requirements — larger study deposits and demonstrated site control — and those deposits are increasingly at risk if a project drops out, which is the financial mechanism for discouraging placeholder applications.

What it does and does not fix

The order also moves to "incorporate technological advancements into the interconnection process," the third element the Commission lists, which is the hook for treating storage and hybrid resources, and for using more advanced modeling in the studies. That reflects a queue whose composition has shifted heavily toward solar, wind, and battery storage — the inverter-based resources that now dominate new applications. A standalone battery, a solar-plus-storage hybrid, and a project that charges from the grid behave differently in an interconnection study than a conventional generator, and the order's provisions for these resources — including options to interconnect at less than full nameplate capacity in exchange for operating limits — are aimed at letting them enter the queue without each requiring the maximal set of upgrades.

It is worth being precise about what the queue is and is not. The interconnection study does not decide whether a project is economically viable, whether it has a buyer for its power, or whether it will ever be financed; those are the developer's problems. The study decides a narrower question: what does it take, physically and financially, to connect this resource to the transmission system without harming reliability, and who pays for it. The output is an interconnection agreement specifying the required network upgrades, their cost responsibility, and the project's operating terms. A project can clear every study and still not be built if its economics do not close — which is the other half of the gap between queued and built that the order does not address.

What the reform does not do is eliminate the studies or the upgrade costs. A project must still complete the cluster study, accept its share of identified network upgrades, and sign an interconnection agreement before it can be built. The reform changes the order and pace of the queue and raises the bar for entry; it does not remove the queue. For anyone reading a project pipeline, the practical lesson is that an interconnection application is the beginning of a multi-stage, cost-allocating process, and that the realistic schedule from queue entry to operation is governed by these procedures rather than by the announcement date. The order is the document that defines that process, and it is the reason the phrase 'first-ready, first-served cluster study' now describes how new power reaches the grid.