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

FERC's Order No. 2023, issued in July 2023, is now moving from rulebook to practice. Transmission providers had until 3 April 2024 to file compliance plans, extended to 16 May 2024 for the rehearing changes in Order No. 2023-A, and the Commission has been acting on those filings through the year. By the fall, the first cluster studies under the new rules are being set up across the regions FERC regulates. Under the old rules, transmission providers studied requests one at a time, first come, first served, and were held only to a "reasonable efforts" standard on deadlines.

The rule also requires providers to publish heatmaps of available transmission capacity, to allow several resources such as solar and storage to share one interconnection request, and to evaluate advanced transmission technologies such as advanced conductors and power flow control in cluster studies. We expect the first effect of Order No. 2023 to be a sharp fall in queue volume, as speculative projects withdraw rather than post deposits. The right measure of the rule's success is the time from request to commercial operation for projects that are actually built.