The dominant explanation for North American interconnection delays is regulatory. The story goes that FERC, ISOs, and state regulators have constructed a process — clustered studies, deposit requirements, transmission cost allocation — so complex and slow that even well-funded developers wait five to eight years for a queue position to clear. Reform the process, the argument runs, and interconnections clear.
The argument is not wrong. It is incomplete.
The regulatory framework is, in fact, a real source of delay. But sitting underneath the regulatory layer is a structural problem that no amount of process reform will address: the engineering work required to execute an interconnection study, design the upgrades, specify the equipment, and clear protection coordination cannot be done at the volume that the queue requires, because the engineering capacity does not exist.
The supply-side picture
In any given year, the volume of new generation interconnection studies submitted across MISO, PJM, ERCOT, CAISO, SPP, NYISO, and ISO-NE exceeds 250,000 megawatts. The number of senior power engineers in North America licensed and experienced to execute the underlying studies — system impact, facilities, network upgrade — is on the order of a few thousand. The math does not work.
This shortfall manifests in three operational realities.
Utility engineering teams are overwhelmed. Transmission owners are required to perform substantial engineering review on every interconnection request in their territory. The teams responsible for that review are sized for steady-state grid maintenance, not for the volume of generation interconnection now in the queue. The result is multi-year backlog before a study even begins.
Consultant capacity has not scaled. The independent consulting engineering firms — the firms that utilities, developers, and IPPs rely on for queue-clearance work — have grown linearly while demand has grown exponentially. Senior engineers are not made on demand. Lead times for top firms are now 12 to 24 months for project initiation.
Design quality is degrading. As capacity tightens, the work that does get executed is being done under time pressure, by junior staff, with insufficient peer review. We are seeing studies returned for revision at rates we would not have seen a decade ago. The downstream cost of that — re-studied projects, withdrawn applications, queue restarts — is now a material driver of total delay.
The implication
Regulatory reform will help. FERC Order 2023 and the various ISO process reforms are real improvements. But they are improvements to the process by which engineering work is requested, scheduled, and reviewed. They do not increase the supply of engineers capable of doing the underlying work.
The constraint is engineering throughput. The reforms do not relax it.
This is why developers and sponsors who have been counting on process reform to clear their projects are encountering a second wave of frustration — the regulatory clock is running, but the engineering work is not getting done any faster. The bottleneck has migrated, not disappeared.
What solves it
The operators that will capture value in this environment are those that internalize engineering capacity rather than contract for it. A developer with an in-house engineering bench that can execute its own interconnection studies — and bring them to the ISO at submission quality — moves through the queue at a fundamentally different velocity than one that is waiting on third-party studies.
The same logic applies to utilities. The utilities that integrate generation interconnection engineering with their transmission planning function — rather than outsourcing it to a queue of consultants — clear backlog faster, reduce re-study rates, and improve their relationship with the IPP community.
The same logic applies to platforms. A vertically integrated industrial platform that builds engineering depth into the same operating company that owns the generation, real estate, and decommissioning practices — rather than buying engineering as a service — captures the timeline arbitrage that the constraint creates.
The decade ahead
Over the next ten years, North America will execute more interconnection work than it has in the prior thirty. The supply of engineering capacity will not scale to meet that demand. The platforms that solve it — that build, retain, and deploy engineering depth as a strategic capability — will define the energy infrastructure landscape on the other side.
The platforms that wait for the queue to clear will not.