Open access is the cornerstone of competitive wholesale electricity markets, a principle enshrined in the Energy Policy Act of 1992 and reinforced in the Federal Energy Regulatory Commission (FERC) Orders No. 888 and No. 2003. These orders require utilities to provide non‑discriminatory, comparable transmission and interconnection services. By remaining technology-neutral, they opened markets to all generation types and continue to serve as the benchmark for today’s interconnection processes. In the industry’s effort to accelerate interconnection, after years of slow adaptation to queue backlogs, some reforms have introduced limits on project intake, either at the outset or during later stages of the process. While priority processing can be designed to be consistent with long-standing open-access principles, in many cases, core tenets of fairness and competition are being compromised. Discriminatory queue processing undermines fair competition among technologies and interconnection customers, introducing regulatory uncertainty that ultimately harms consumers.
Prior to the implementation of recent discriminatory practices, reforms aimed at improving standard interconnection processes appeared to be making an impact across regions. According to the latest data from Lawrence Berkeley National Laboratory, interconnection queue volume has declined by approximately 12% over the past year. Smaller queues enhance grid operators’ ability to process project proposals and streamline interconnection. This report published by ACORE explores the growing trend of interconnection queue rationing across four major regional transmission organizations (RTOs) and independent system operators (ISOs)—PJM Interconnection LLC (PJM), the Midcontinent Independent System Operator (MISO), Southwest Power Pool (SPP), and the California Independent System Operator (CAISO). Each has adopted distinct approaches to prioritize projects and manage limited transmission capacity, ranging from temporary fast-track programs to permanent structural changes.
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