FERC Order No. 2023 Every deadline, deposit, and withdrawal penalty — tracked, not assumed

The most rigorous interconnection deadline-defense desk a developer can deploy.

QueueGuard assembles a compliance-complete portfolio — every milestone, deposit escalation, RFI window, and site-control renewal — checked against the fragmented FERC/ISO/utility rulebook before a specialist releases it.

Every deadline under FERC Order No. 2023Five milestone categories, gate-checkedCAISO · ERCOT · PJM · MISO · SPP · NYISO · ISO-NE · utility tariffsSpecialist release on every file5-business-day SLA
Why portfolios fail

A single missed deadline can forfeit years of queue position and millions in deposits.

A developer's interconnection queue position is only as strong as the compliance behind it. Miss a deposit-escalation deadline, an RFI response window, a restudy submission, or a site-control renewal — and the project can be withdrawn, triggering a graduated penalty tied to commercial-readiness deposits that escalate into millions of dollars.

Most developers run this by hand, across spreadsheets, for 5-50 projects in multiple ISO/utility regions. The rulebook is fragmented: FERC Order No. 2023's firm deadlines layered onto PJM's transition cycle, MISO's DPP-2025, ERCOT's low-fee structure, and each utility's own tariff. That is exactly where compliance gaps hide.

QueueGuard exists to close that gap with a single, exhaustive standard applied identically to every project.

1 of 5
missed milestones is enough to trigger a withdrawal penalty
The benchmark

Measured against the letter of FERC Order No. 2023 and each ISO/utility tariff — subsection by subsection.

We do not summarize the rules and hope. Every project is scored against a versioned rule pack tied to the exact text of FERC Order No. 2023 and the applicable ISO/utility interconnection tariff. These are the provisions each portfolio is held to.

FERC Order No. 2023 §35.28(f)(2)

Five milestone categories

Deposit escalations, restudy deadlines, RFI response windows, site-control renewals, and commercial-readiness deposits — all tracked, or the file does not release.

FERC Order No. 2023 §35.28(f)(3)

Graduated withdrawal penalties

Penalty exposure is calculated deterministically from the project's deposit schedule and queue stage — never estimated.

FERC Order No. 2023 §35.28(f)(1)

Every required recipient

ISO/utility, transmission owner, and any affected system operators — established by tariff, not assumption.

PJM OATT §36.2

Transition cycle compliance

For PJM projects, the transition cycle deadlines and restudy triggers are verified against the July 2025 FERC compliance order.

MISO DPP-2025 §8.3

Cluster study deadlines

For MISO projects, the DPP-2025 cycle milestones and deposit schedules are tracked and evidenced.

FERC Order No. 2023 §35.28(f)(4)

Advertisement, surplus, title

The 2-week publication rule, surplus-proceeds handling, and the bill-of-sale title path — sequenced on the calendar so nothing is missed.

How a portfolio is built

Intake to specialist release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human specialist signs every release. That order is never reversed.

01

Portfolio Gap Scan

Upload your project list and key documents (LGIAs, study reports, correspondence). We return a free compliance read: which milestones, deposits, and deadlines you already have tracked, and which are missing.

02

Evidence & tariff searches

As your authorized clerical agent, we order the applicable ISO/utility tariff extracts, queue-status reports, and deposit schedules, and build the milestone matrix, corroborated across sources.

03

Grounded drafting

The five milestone categories are drafted from your validated data and the rule pack into field-locked templates — no legal opinions, no invented facts.

04

Deterministic compliance gates

Deposit amounts reconcile to the tariff to the penny; the deadline window is verified; the search checklist is resolved; SCRA is screened. Any failure blocks release.

05

Specialist release

A compliance specialist reviews the exception queue and signs the release. High-value or complex projects route to a licensed Professional Engineer or senior interconnection specialist review first.

06

Delivery

You receive the portfolio: milestone calendar, deposit schedule, evidence log, RFI response drafts, and the 60-day ICS calendar — ready for your team to submit under its own name.

The bar we hold

Rigor you can measure.

100%
Specialist-released
No file ships without a human signature.
5 days
Standard SLA
From complete intake to released portfolio.
<1%
Critical-defect target
Tracked against a gold-standard portfolio library.
8
ISO/utility tariff sources
CAISO · ERCOT · PJM · MISO · SPP · NYISO · ISO-NE · utility tariffs, every applicable file.
Why QueueGuard

Built to be the most thorough option a developer has.

Compliance-complete, by design

The deliverable is completeness itself — every milestone, deposit, and deadline accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a tariff requirement.

In its lane, on purpose

We prepare documentation and run searches as your clerical agent. We never contact the ISO/utility, give legal advice, or conduct the interconnection process.

Engagement

Flat fee, per project per month. No hourly billing, ever.

Simple, predictable, and aligned with a compliance standard — not a cut of any deposit or penalty recovery.

  • A free Portfolio Gap Scan before you commit — see exactly what is missing.
  • One flat fee per project per month; disclosed pass-through tariff search fees.
  • Optional fixed-fee Professional Engineer or senior specialist review for high-value or complex projects.
  • Optional Milestone Success Fee tied to executed interconnection agreements.
FAQ

Questions, answered precisely.

Is QueueGuard a law firm?
No. QueueGuard, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Professional Engineer or senior interconnection specialist review is available and recommended for high-value or complex projects.
Do you contact the ISO/utility or negotiate on our behalf?
Never. QueueGuard is not a consultant and does not contact ISOs, utilities, or transmission owners. The developer remains the interconnection customer and the party responsible for all submissions and communications.
What makes a portfolio 'complete'?
Completeness is defined by the applicable tariff and FERC Order No. 2023: the five milestone categories tracked, the graduated withdrawal penalty calculated, the deposit schedule verified, and all deadlines and recipients identified. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a specialist-released portfolio. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per project per month, plus disclosed pass-through tariff search costs. No hourly billing and no percentage of any deposit or penalty recovery. Milestone success fees are optional and tied to executed interconnection agreements.

See what's missing before it costs you a queue position.

Start with a free Portfolio Gap Scan. Send your project list and key documents and we'll return a compliance read against every applicable tariff and FERC Order No. 2023.

Documentation-completeness service · not legal advice · the developer submits every notice.