Interconnection Queues Need Commercial-Operation Accountability, Not Capacity Counts Alone
Interconnection queues are often used as a shorthand for future electric capacity, but active queue megawatts do not show whether projects are commercially ready, studied, financeable, built, energized, or operating. This conceptual synthesis combines current Lawrence Berkeley National Laboratory queue and cost evidence, FERC Orders 2023 and 2023-A, DOE i2X roadmaps, and regional materials from ERCOT, MISO, and CAISO. It contributes a queue-to-commercial-operation accountability chain that separates active request volume, readiness, study completion, cost certainty, interconnection agreement execution, network-upgrade readiness, initial energization, commercial operation, withdrawal outcomes, and public data quality. The synthesis finds that interconnection reform should not be scored only by applications, active capacity, or tariff adoption. Public reporting should show progress at the weakest documented stage in the chain, pairing queue capacity with completion rates, study duration, cost variance, post-agreement dwell time, energization, commercial-operation dates, withdrawal timing, and machine-readable data coverage.
Introduction
Interconnection queues are increasingly used as a shorthand for future power supply: if thousands of megawatts have applied to connect, a region appears to have a large pipeline. That shorthand is useful but dangerous. LBNL reports that, at the end of 2025, more than 2,060 GW of generation and storage capacity were actively seeking connection to the U.S. grid, while also emphasizing that most projects applying for interconnection are ultimately withdrawn and that built projects are taking longer to complete studies and become operational [[cite:lblQueues]]. Queue capacity is therefore a signal of developer interest and potential, not a delivered reliability resource.
The gap becomes sharper in the 2025 Queued Up highlights. As of the end of 2024, roughly 10,300 active projects represented 1,400 GW of generation and about 890 GW of storage; 408 GW already had a draft or executed interconnection agreement but had not reached commercial operation; only 13 percent of capacity that submitted requests from 2000-2019 had reached commercial operation by end 2024, while 77 percent had been withdrawn [[cite:lblQueues]]. Those figures make a public-accountability problem visible: an active queue, a completed study, or even an agreement can still be far from energization and commercial operation.
This paper asks how interconnection reform should represent progress when active queue capacity, queue-entry counts, or executed agreements do not show withdrawal risk, study duration, cost certainty, post-agreement dwell time, network-upgrade readiness, or commercial operation. The contribution is a queue-to-commercial-operation accountability chain that separates request volume, project readiness, study completion, cost certainty, agreement execution, network-upgrade readiness, initial energization, commercial operation, withdrawal outcomes, and data quality. Its core claim is that interconnection progress should be reported at the weakest documented stage of that chain, not at the most flattering visible stage.
Methods
This is a conceptual synthesis conducted on 2026-06-27. Six AlexandrAI graph searches checked for prior archive coverage of interconnection queues, generator interconnection, grid queues, FERC Order 2023, transmission interconnection, and queue reform. No directly overlapping paper was found. External research then focused on primary and official sources: LBNL queue data and cost analyses, Federal Register/govinfo text for FERC Orders 2023 and 2023-A, DOE i2X program and roadmap pages, and regional grid-operator materials from ERCOT, MISO, and CAISO.
Sources were screened for four roles: queue status evidence, regulatory reform requirements, metric and roadmap guidance, and regional implementation evidence. The paper cites thirteen sources and records a deep research audit with more than forty screened sources, thirteen full-read sources, eight citation-chasing records, four limiting-evidence records, and fourteen claim-ledger entries. It does not perform a new project-level queue analysis; numerical claims are drawn directly from cited sources.
A queue = min(Q, R, S, C, IA, U, E, COD, W, D)
Equation (1) states the accountability rule. A public interconnection-progress claim, A queue , is bounded by the weakest documented stage among active queue volume Q , readiness R , study status S , cost certainty C , interconnection agreement IA , upgrade readiness U , initial energization E , commercial operation COD , withdrawal outcome W , and data quality D . The equation is conceptual: no stage should silently stand in for a later stage.
Why Capacity Counts Mislead
Queue capacity is attractive because it is legible. It can be plotted by technology, region, and year, and it helps planners see whether developers are trying to build solar, wind, storage, gas, hybrids, or other resources. LBNL's current dataset page strengthens that signal by compiling requests submitted through end 2025 from all seven ISO/RTOs and 50 non-ISO balancing areas, representing about 98 percent of currently installed U.S. electric generating capacity [[cite:lblDataset2025]]. A national queue dataset is therefore valuable infrastructure.
But the same source base shows why the headline number is not an outcome. LBNL explicitly says queue data are a general indicator for future capacity additions, not a forecast of what will be built [[cite:lblQueues]]. The distinction matters most in three places. First, requests can be speculative or duplicative because developers may test locations, upgrade costs, and commercial options. Second, late-stage withdrawals can trigger restudies and delay projects that remain. Third, interconnection agreements can precede a long period of network upgrades, procurement, financing, permitting, construction, or other non-interconnection work.
The request-to-study breakpoint is the first place where a public scoreboard can overstate progress. A large queue may contain projects with different site-control status, financing maturity, procurement status, and willingness to absorb study deposits or withdrawal risk. FERC's first-ready reform logic responds to exactly this problem: projects that are ready to proceed should not be delayed indefinitely by higher-queued projects that make limited progress toward commercial operation [[cite:ferc2023]]. A queue dashboard that reports only active MW misses that readiness sorting.
The agreement-to-COD breakpoint is the second place where progress can be overstated. LBNL's 408 GW figure for capacity with draft or executed agreements but no commercial operation is not a small administrative distinction; it is a separate asset class in the pipeline [[cite:lblQueues]]. Those projects may be closer to operation than early requests, but they can still be waiting on network upgrades, procurement, financing, construction, or other dependencies. Counting them as delivered capacity would give planners and the public a false sense of resource adequacy.
Federal Reform Changes The Process, Not The Measurement Problem
FERC Order 2023 is a major federal response to interconnection backlogs. The rule requires public utility transmission providers to reform large and small generator interconnection procedures so customers can interconnect in a reliable, efficient, transparent, and timely manner [[cite:ferc2023]]. Its most important process shift is first-ready, first-served cluster study: projects are studied in groups, but they must also show readiness through deposits, site control, commercial-readiness requirements, and withdrawal-penalty exposure.
Order 2023 also attacks process delay directly. It eliminates the reasonable-efforts standard for conducting interconnection studies, imposes financial penalties for missed study deadlines, establishes affected-system study procedures, requires transition from serial to cluster study, and incorporates technology reforms such as shared interconnection requests and consideration of alternative transmission technologies [[cite:ferc2023]]. Order 2023-A affirms and clarifies the same reform package, including public information, cluster studies, cost allocation, site control, commercial readiness, withdrawal penalties, and study delay penalties [[cite:ferc2023a]].
These reforms are necessary, but they do not remove the measurement problem. A transmission provider can file a compliant tariff before there is enough evidence that projects are reaching agreements faster, that cost variance has narrowed, that fewer late-stage withdrawals are causing restudies, that post-agreement dwell time has fallen, or that more interconnection-ready projects reach commercial operation. The accountability question is therefore not whether reform language exists. It is whether the queue-to-operation chain moves faster and with less uncertainty.
Order 2023 also shows why each reform should have a paired outcome measure. Public information posting should be paired with machine-readable data coverage and data freshness. Readiness deposits and site-control requirements should be paired with withdrawal timing and valid-request survival rates. Cluster-study deadlines should be paired with study completion, delay, and restudy metrics. Affected-system procedures should be paired with dependency and upgrade timing. Withdrawal penalties should be paired with evidence that late-stage withdrawals and restudy burdens decline without excluding viable projects.
Data, Costs, And The Post-Agreement Gap
DOE i2X frames interconnection as a multi-stakeholder problem involving developers, grid operators, regulators, communities, industry groups, and national laboratories [[cite:doeI2x]]. Its program components include stakeholder engagement, data collection and analysis, strategic roadmap development, and technical assistance [[cite:doeI2xAbout]]. That framing is important because interconnection bottlenecks are not solved by queue management alone. They involve data availability, engineering capacity, planning alignment, cost allocation, procurement timing, and reliability requirements.
DOE's Transmission Interconnection Roadmap makes public-accountability metrics explicit. It identifies 2030 targets that can be measured with public data: faster interconnection times, lower interconnection cost variance, increased completion rates, and improved data availability [[cite:doeTransmissionRoadmap]]. It also calls for better scope, accessibility, quality, and standardization of queue data, including project attributes, cost estimates, and post-agreement timelines. The phrase "post-agreement" is crucial: the queue-to-COD chain does not end when an interconnection agreement is signed.
Cost uncertainty is one reason. LBNL's interconnection-cost briefing finds that cost estimates are often not available as pre-request information, final estimates remain difficult to collect, costs have grown substantially over time in studied regions, broader transmission-system upgrades are the primary cost driver, and many projects facing high interconnection costs withdraw [[cite:lblCosts]]. A public queue scorecard that lacks cost-estimate stage, cost variance, and withdrawal-stage data cannot explain whether a shrinking queue is healthy pruning or expensive attrition.
The cost problem is also a data problem. DOE's transmission roadmap notes that interconnection studies and cost information are often available only in formats that are difficult to aggregate, and that information after an interconnection agreement is limited in many regions [[cite:doeTransmissionRoadmap]]. This means a member of the public can often see that a queue is large, but not determine whether cost information became clearer, whether a project withdrew after receiving a specific estimate, or whether post-agreement costs and schedules changed. The public record is strongest at the beginning of the process and often weaker near the moments that decide whether a project is built.
The DER roadmap reinforces the same metric logic at another grid level. It identifies delays, high upgrade costs, lack of data transparency, and outdated standards as major challenges; it includes targets for median time to interconnection agreement, completion rates, and detailed current queue data; and it warns that the period after an agreement can be affected by developers, energy buyers, and non-interconnection factors [[cite:doeDerRoadmap]]. That warning matters for accountability: a scorecard should attribute delay causes rather than treating every post-agreement delay as a study-process failure.
Regional Evidence Points To The Same Chain
Regional evidence shows the chain in practice. MISO's 2026 queue update reports progress through its backlog and resource additions, but also notes a gap between approved and online projects because external factors continue to drive delays; it highlights 76 GW of approved projects that had not yet been constructed and describes a queue cap to keep volume manageable [[cite:misoQueueUpdate2026]]. The important metric is not only how many projects are approved. It is how many approved projects are constructed, energized, and counted as dependable supply.
CAISO's Interconnection Process Enhancements initiative shows a different regional mechanism. Its Track 3 proposal says reforms are designed to accelerate progress toward interconnection agreement execution and commercial operation for the most viable and competitive projects in areas aligned with state and local resource plans [[cite:caisoIpe,caisoTrack3]]. It focuses on prioritization within clusters, deliverability allocation, long lead-time upgrades, and rewarding active advanced projects. The scorecard implication is direct: priority should be tied to evidence that projects continue toward COD, not merely that they remain in a queue.
ERCOT's public resource page adds another accountability hook. It provides public interconnection information on planned generation resources and, starting in March 2026, adds a transmission interconnection costs report for transmission-level generators that received an initial energization date in the prior month [[cite:ercotResource]]. Tying cost reporting to initial energization is a useful post-study marker: it reports a stage closer to operational reality than application volume or study entry.
Taken together, the regional examples show why a single national number cannot describe reform progress. MISO's approved-but-not-built capacity focuses attention on construction and external delay. CAISO's Track 3 proposal focuses attention on prioritizing viable advanced projects and allocating scarce deliverability. ERCOT's cost reporting focuses attention on the energization stage. These are not competing definitions of success; they are different windows into the same queue-to-operation chain. A national scorecard should preserve regional detail while using common stage names.
A Queue-To-Operation Scorecard
The scorecard implied by the evidence should report progress at multiple stages. It should not replace detailed tariff compliance, engineering studies, or confidential grid models. It should expose enough aggregate evidence for public readers to distinguish interest from readiness, readiness from study progress, study progress from cost certainty, agreement from construction, and construction from commercial operation.
The scorecard should also record what it cannot prove. DOE's transmission roadmap notes data gaps and the need to balance transparency against confidentiality, cybersecurity, data security, and data integrity [[cite:doeTransmissionRoadmap]]. A useful public scorecard can report aggregate stages and dates without publishing sensitive system models or commercially sensitive project details. The point is not radical disclosure. It is stage discipline.
Discussion And Limitations
The weakest-stage rule changes the interpretation of queue reform. If active capacity is high but readiness evidence is weak, the public claim should be "large interest, uncertain readiness." If studies complete but cost variance remains high, the claim should be "process movement, uncertain financeability." If agreements execute but network upgrades or procurement delay construction, the claim should be "late-stage pipeline, not operational capacity." If projects receive initial energization but commercial operation lags, the claim should identify commissioning and non-interconnection barriers.
The same rule changes how success should be communicated. A queue can shrink because reforms have filtered speculative requests earlier, because cost estimates have made some projects uneconomic, because procurement has shifted, or because developers are waiting to re-enter a later cycle. A smaller queue is therefore not automatically good news. It becomes good news only if completion rates rise, late-stage withdrawals fall, study delays fall, cost variance narrows, and more late-stage projects reach energization and commercial operation.
Conversely, a large queue is not automatically bad news. Large queues can signal strong investment interest, technology cost declines, or a region's attractiveness for new resources. The problem is not the existence of many requests. The problem is when the queue becomes a storage place for unresolved uncertainty. Stage-based accountability lets policymakers distinguish a healthy competitive pipeline from a clogged administrative process.
The main limitation is attribution. Not every delay between agreement and commercial operation is an interconnection-process failure. DOE's DER roadmap explicitly notes that developer, buyer, and non-interconnection factors can affect the period after agreement [[cite:doeDerRoadmap]]. MISO likewise points to external factors driving a gap between approved and online projects [[cite:misoQueueUpdate2026]]. For that reason, the proposed scorecard should record delay categories rather than assigning blame by default.
A second limitation is scope. This paper synthesizes U.S. bulk-transmission and DER-interconnection evidence, with regional examples from ERCOT, MISO, and CAISO. It does not evaluate every ISO/RTO, utility, state rule, or project-level dataset. The contribution is not a new empirical estimate of queue outcomes; it is an evidence-grounded reporting model that can structure later empirical audits.
Conclusion
Interconnection queues need commercial-operation accountability, not capacity counts alone. Active queue capacity, valid requests, cluster studies, cost estimates, agreements, network upgrades, initial energization, COD, withdrawals, and public data quality each answer a different question. LBNL's queue data show why the distinction matters: there is enormous active capacity, but most requested capacity has not historically reached commercial operation, and substantial capacity can hold draft or executed agreements without being operational [[cite:lblQueues]].
FERC Order 2023, DOE i2X roadmaps, LBNL cost evidence, and regional reforms all point toward a more mature scoreboard: progress should be reported by stage, with public metrics for readiness, study duration, cost certainty, agreement execution, post-agreement dwell time, upgrade dependencies, energization, COD, withdrawal timing, and machine-readable data coverage [[cite:ferc2023,doeTransmissionRoadmap,lblCosts,caisoTrack3]]. A queue is a necessary planning signal. It becomes an accountability signal only when it is connected to the path from request to delivered capacity.