Site Control Requirements for Interconnection: What PJM, MISO and SPP Accept

Site control for an interconnection request means signed, exclusive rights to the land your project sits on. That can be a deed, a lease, or an option to lease or buy, with a term long enough for the stage you're at. A letter of intent doesn't count in any of the grid operators below.

FERC Order 2023 set the federal floor. You show 90% site control when you file the request, and 100% when you sign the facilities study agreement and the interconnection agreement. Several grid operators ask for more, and sooner. PJM wants 100% of the generating facility site on the application deadline. MISO wants proof for the full required acreage 90 days before its study cycle starts, and withdraws a request with no cure period if the documents aren't in.

Cash instead of signatures is allowed only in narrow cases, covered below. For most developers, site control is now a count of signed parcels against a fixed date.

What counts as site control

The instruments are close to identical across the big operators. The details that trip people up aren't.

PJM's manual spells out three things every document has to show. Conveyance: the document gives you the land, or the right to it at your sole discretion. Term: long enough for that stage. Exclusivity: written acknowledgement from the landowner that nobody else can lease or buy the site for a use that interferes with yours.

One line in PJM's manual deserves a second read. An option with a short initial term plus extensions doesn't meet a longer term requirement unless the extensions have actually been exercised and any payments made. An option that looked fine at signing can fall short at a later decision point.

PJM can also ask for landowner attestations or county recordings to check what you certified. The document has to come from the person who can actually convey the land.

How much, and by when

Under FERC Order 2023

The national minimum is 90% at the interconnection request and 100% at the facilities study agreement and again at the interconnection agreement. Each operator's compliance filing sets its own version on top of that.

PJM

• Application: 100% of the generating facility site, with a term of one year from the application deadline. For Cycle 1, that deadline was April 27, 2026, so the term had to run to April 27, 2027.
• Decision Point I: 100% of the generating facility again, for another year from the end of Phase I. Plus 50% of the gen-tie route to the point of interconnection, and 50% of any new switchyard.
• Decision Point II: no site control showing required.
• Decision Point III: 100% of the generating facility, the gen-tie and the switchyard, for three more years from the end of Phase III under the new cycle process.

You can swap parcels at Decision Points I and III, as long as the site still covers the full acreage. The catch: any parcel you add has to be adjacent to the site you already filed, or connected to it by an easement.

PJM also takes a readiness deposit of $4,000 per MW at application. That's money posted against a site you have to keep signed through every stage.

MISO

• 90 calendar days before Definitive Planning Phase I kicks off: proof that you control the full acreage MISO requires for your technology, exclusive to this project. Plus at least 50% of the gen-tie mileage. Miss the deadline and the request is deemed withdrawn as of that date, with no cure period.
• Decision Point II: proof you still hold that site control.
• Interconnection agreement: continued control of the generating facility site plus 100% of your interconnection facilities.

SPP

SPP's posted Site Control Criteria (last revised December 2022) ask for generating facility site control at the request, with an expiry at or beyond commercial operation. On the gen-tie, you need 50% of the mileage at submission and 75% before the end of Decision Point 2. You also need 100% of any new substation needed at the point of interconnection. Check the current Attachment V before you file, since SPP has filed Order 2023 compliance changes since.

The acreage they measure you against

Each operator publishes a minimum land requirement per MW. Your signed acreage has to meet it, or you justify a tighter layout.

So a 100 MW solar request in PJM needs 500 acres of signed, exclusive land on the application deadline. The same project in SPP needs 600. If your layout is denser, PJM wants a stamped site plan from an engineer licensed in that state, and MISO wants a written justification of the reduced footprint.

Paying instead of signing

Order 2023 allows a deposit in lieu of site control only where a regulatory limitation stands in the way. That generally means a federal, state, Tribal or local law that makes it practically infeasible to get site control in time. It isn't a way around an owner who hasn't answered.

MISO's version is $10,000 per MW, at least $500,000 and at most $2,000,000, refunded only once you show site control or leave the queue.

The gen-tie is different. MISO and SPP both let you post $80,000 per line mile instead of showing the required share of the route. SPP's own example is a 6-mile line: $480,000. MISO refunds it once you meet the requirement. SPP warns the money can be forfeited if you withdraw.

PJM's manual offers no cash option for a generating facility on private land. For a site owned by a government agency, it accepts whatever authorization that agency issues.

What the rules mean for your land team

Read those tables as a land manager and the same thing shows up everywhere. The operator doesn't grade your effort. It counts signed parcels on a date.

That changes which owners matter.

The signer, not the name on the tax bill. Exclusivity and conveyance have to come from whoever can actually grant the land. When the deed is in a dead parent's name, that might be several heirs, and one unsigned heir can leave a parcel you can't count. We covered who signs when the landowner has died. When the owner is an LLC, the mail often goes to a registered agent who may never pass it on. Finding the person behind the LLC is its own job.

Your backup parcels are the neighbors. In PJM, a replacement parcel has to touch the site you filed, or connect by easement. When an owner backs out before a decision point, the only owners who can fill the gap are the ones next door. If they never heard from you, there's no backup.

The gen-tie is a second list. The route to the substation crosses owners who have nothing to do with your solar site. Often they hold narrow strips, sometimes they live elsewhere. Every mile you can't get signed is $80,000 posted in MISO or SPP.

Option terms need checking before each stage. Say a 12-month option has to be extended to cover the next term. The extension has to be exercised and paid before you file. That's a call to the same owner, at a set time.

The owners you haven't reached yet

Most land teams start with a list and a mail drop. The owners who answer get worked. The ones who don't are logged as no response. Under the old serial queues, they could wait.

Under cycle rules they can't, because the dates are fixed. The silent owners on your list are often the exact ones the rules care about. The heirs. The LLCs. The owner whose address went stale ten years ago. The neighbor on your boundary, and the strip on your gen-tie route. If your list has already been mailed, many of them never saw a word you sent.

That's the part we run. We find who can actually sign each parcel and email every owner on the list. We follow up with the quiet ones, and tell your team within seconds when an owner wants to talk. Your team takes the call and signs the option. We've facilitated 740 MW of site control that way, on lists developers already owned.

Is a filing date coming, with too many parcels still marked no response? Send us the list and we'll tell you how many of those owners you haven't actually reached.