Cluster Studies Take Hold: What Order No. 2023 Means on the Ground in Late 2024

By September 2024, United States transmission providers are deep into compliance with FERC Order No. 2023 and the March 2024 rehearing order, Order No. 2023-A. The headline reform is familiar: replace serial first-come studies with first-ready, first-served clusters; demand financial readiness and site control; penalise late studies; and modernise modelling for inverter-based resources. The ground-level question is whether those tariff words are shortening time-to-interconnection for projects that can actually build. FERC reported that at the end of 2022 more than 2,000 gigawatts of generation and storage sat in interconnection queues, with average waits of up to five years.

A smaller headline queue is success only if viable projects move faster. EIA's February 2024 survey planned 5.2 gigawatts of 2024 retirements against 62.8 gigawatts of planned additions. Order No. 2023 updated modelling and performance expectations for inverter-based resources and required evaluation of certain grid-enhancing technologies in studies, while leaving deployment decisions with transmission providers responsible for reliability. Lenders should confirm which cluster window governs a project, whether readiness security is posted in acceptable form, withdrawal penalty exposure, how network upgrade costs are allocated inside the cluster, and whether the project's electrical models meet updated inverter-based requirements.