Unlocking Interconnection: What Developers Must Disclose

Miss one required disclosure, and your interconnection queue position — potentially worth millions in development value — can evaporate before a single study line gets drawn. That's not hypothetical; it's a recurring reality for developers who underestimate what utilities and regional transmission organizations actually need before they'll open the door to an interconnection study.

The interconnection process is already one of the most congested bottlenecks in energy infrastructure development. Queues at major ISOs stretch three to five years in some regions. Getting bounced back to the starting line because your initial submission was incomplete isn't just frustrating — it's potentially fatal to a project's economics.

Here's what developers need to understand about the disclosure requirements that sit between a promising site and a completed interconnection study.

What an Interconnection Study Actually Is — and Why It's a Gate, Not a Formality

An interconnection study is the formal technical analysis that determines whether and how a new generation or storage project can connect to the electric grid. It evaluates system impact, identifies required network upgrades, and ultimately determines what it will cost the developer to bring their project online.

There are typically three study phases — a Feasibility Study, a System Impact Study (sometimes called Phase I and Phase II), and a Facilities Study — and each one builds on the data established in the one before it. Getting into that queue and staying in it depends entirely on the quality and completeness of what you submit on day one.

This is where most developers make their first mistake: treating the pre-application disclosure as a paperwork exercise rather than a technical foundation. Utilities and ISOs use the information submitted at application to model the project in their grid simulations. Garbage in, garbage out — and in this case, "garbage" means delays, restudies, and cost allocation surprises downstream.

What Developers Are Actually Required to Disclose

Before a developer can formally enter the interconnection queue, they must provide the grid operator or utility with a detailed snapshot of their project and site. The specifics vary by ISO/RTO and by utility for non-RTO territories, but the core disclosure categories are consistent across virtually every jurisdiction.

Site and Property Information

This is the most fundamental layer. Developers must disclose the precise location of the proposed generation facility — typically via GPS coordinates, parcel data, or both — along with documentation demonstrating site control. Site control usually means a signed lease, purchase agreement, or option to purchase the land. You don't have to own the land, but you have to prove you control it.

Grid operators need this to confirm the project is a real, viable proposal — not a placeholder position in the queue. FERC's Order 2023, finalized in 2023 and representing the most significant overhaul of interconnection rules in two decades, tightened site control requirements specifically to reduce speculative queue clogging.

Project Technical Specifications

The interconnection applicant must disclose detailed technical parameters of the project, including:

• Installed capacity (MW AC and DC for solar) — not a rough estimate, but the specific nameplate capacity
• Technology type — solar PV, wind, battery storage, hybrid configurations, etc.
• Point of Interconnection (POI) — the specific location on the transmission or distribution system where the project intends to connect
• Expected annual energy output — used for system impact modeling
• Reactive power capability — relevant for voltage stability studies

For hybrid projects — say, a solar-plus-storage facility — the disclosure requirements multiply. Each resource component needs its own technical characterization, and the operational relationship between them (how they charge, dispatch, and interact with the grid) must be clearly defined upfront.

Electrical Equipment and Infrastructure Details

Beyond the project specs, developers must disclose what physical infrastructure will be used to connect the project to the grid. This includes transformer specifications, planned substation configurations, and any collector system design that's been completed. The more complete your electrical design at the disclosure stage, the less likely you are to face a fundamental restudy when equipment specs change later.

This is an area where developers frequently under-invest at the application stage — and pay for it during the Facilities Study, when discrepancies between what was modeled and what's actually being built trigger expensive re-analysis.

What Happens When Disclosures Are Incomplete

Incomplete or inaccurate disclosures don't just slow things down — they can trigger a full withdrawal from the queue, requiring the developer to reapply and lose their position relative to other projects. In a queue where position determines what network upgrade costs you're assigned, losing your place can mean inheriting millions in additional upgrade costs that earlier-queue projects would have shared.

There are also direct financial penalties in some jurisdictions. FERC's interconnection rules allow for forfeiture of application deposits when projects are withdrawn or when material changes to project scope require re-entry. Deposits at the transmission level can range from tens of thousands to over a million dollars depending on project size and the applicable tariff.

Beyond the direct costs, there's a compounding timeline problem. Every month lost to a deficient application is a month pushed deeper into a financing cycle, a month closer to an expiring land option, and a month further from a PPA counterparty's commercial operation deadline. In development, time isn't just money — it's optionality, and incomplete disclosures destroy it.

How to Prepare Disclosures That Actually Hold Up

The developers who consistently move through the interconnection process efficiently share a few common practices.

Start with a pre-application meeting. Most utilities and ISOs offer pre-application consultations before a formal queue submission. These sessions let developers identify site-specific issues, confirm the preferred POI, and understand any local grid conditions that could affect the project. Taking this step seriously — and coming prepared with preliminary site and technical data — compresses the timeline between application and study completion.

Lock down site control before you apply. This sounds obvious, but developers routinely submit applications with letters of intent rather than executed agreements, hoping to finalize the paperwork in parallel. Post-Order 2023, that approach carries significantly more risk. The new rules require demonstration of site control at the time of application, not just at the time of a study milestone.

Commission preliminary engineering early. You don't need a complete interconnection design at the application stage, but having a licensed electrical engineer review your POI assumptions, transformer sizing, and reactive power capability will catch mismatches before they become queue-threatening amendments.

Document everything with redundancy. Grid operators often have specific formatting and documentation requirements for disclosure packages. A submission that contains all the right information but doesn't follow the utility's required format can still be rejected as deficient. Build a compliance checklist against the applicable tariff or interconnection procedures, and have someone who wasn't involved in preparing the submission review it before filing.

What Experienced Developers Know That First-Timers Often Don't

Interconnection isn't just a regulatory process — it's a negotiation with the grid. The best developers approach it strategically, not transactionally.

One insight that separates experienced interconnection teams: the point of interconnection you choose is as important as any other development decision you'll make. A POI that looks attractive on a map might sit behind a constrained transmission path that triggers expensive network upgrade allocations. Spending $15,000-$30,000 on a preliminary grid screening analysis before you apply can save multiples of that in study costs and project redesign later.

It's also worth understanding how cluster studies work in the post-Order 2023 environment. FERC's new rules moved ISOs toward studying projects in clusters — groups evaluated together — rather than sequentially. This changes the game for disclosure completeness because inaccurate or incomplete project specifications affect not just your project's study results, but potentially every project in your cluster. ISOs are increasingly empowered to withdraw non-compliant applications that would otherwise distort shared study results.

Developers who've navigated multiple cycles also maintain what might be called a disclosure readiness posture — keeping site control documents, land surveys, geotechnical reports, and equipment specifications in a live data room that can be packaged for submission quickly when site acquisition closes. In a competitive queue environment, the ability to file within days of securing site control, rather than weeks, matters.

The interconnection queue is not forgiving of half-measures. The disclosure requirements that precede the formal study process exist because the grid operators genuinely need that data to do their work accurately. Developers who understand that — and invest accordingly in the quality of their submissions — consistently move faster, spend less on restudies, and build the kind of credibility with grid operators that pays dividends across a project portfolio.

That credibility, ultimately, is its own competitive advantage.

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[INTERNAL LINK: FERC Order 2023]

[INTERNAL LINK: project specifications]