Sample memo · real public data · prepared as a demonstration of the founding-customer audit
§1Verdict
D
Queue Risk Grade
(A–F scale)
This project's published status ("Pending Review, position 46") materially understates its risk. Its dependency chain is 45 projects deep — deeper than 83% of all active projects in the territory — and contains three live disputes, in the second-most dispute-dense queue area in Ameren Illinois.
Absent intervention, the realistic review-completion horizon extends beyond the project's ITC placed-in-service deadline of December 31, 2027, putting an estimated $2.10M federal tax credit at material risk.
45
projects ahead in dependency chain (territory median: 14)
3
live disputes upstream of this project
244.8 MW
capacity queued ahead in this chain
$2.10M
est. ITC value at stake (30% × $1.4M/MW)
§2Where the project actually stands
The public queue reports DER-78569 at position 46 in area WRN-8 with status Pending Review. Position alone is not the operative number. Following the utility's own "Waiting On Project" references, the project sits at the end of a 45-link dependency chain — each link a project whose review must progress before this one's completes. The chain ahead carries 244.8 MW, terminating at DG22034 (a 40 MW project now in Construction).
CHAIN (you → front): DER-78569 ◀ YOU → DER-79104 → DER-79036 → DER-78584 → DER-77833 → DER-77201 → DER-77505 → DER-76648 (10 MW) → DER-76304 → ··· 28 more ··· → DER-44572 ⚠ DISPUTE → ··· → DER-42060 ⚠ DISPUTE → DER-39585 ⚠ DISPUTE → ··· → DG22034 (40 MW · CONSTRUCTION · front)
| Chain composition | Projects | Meaning for DER-78569 |
|---|
| Pending Review | 36 | Each must clear before your review completes |
| In Dispute | 3 | Hard blockers — disputes have no statutory resolution clock |
| Under Review | 2 | Moving, but ahead of you |
| Construction / cleared | 4 | Resolved links — will fall out of the chain as they energize |
§3Dispute exposure
The first dispute sits 37 hops upstream — far enough that the project's own status page gives no hint of it, close enough to gate completion. All three disputed ancestors are in this project's own queue area:
| Disputed ancestor | Size | Area | Exposure type |
|---|
| DER-44572 | 5.00 MW | WRN-8 | INHERITED BLOCK |
| DER-42060 | 4.95 MW | WRN-8 | INHERITED BLOCK |
| DER-39585 | 3.85 MW | WRN-8 | INHERITED BLOCK |
Area context — WRN-8 WRN-8 is the 6th most congested of 70 active queue areas (99 active projects, 433 MW) and is tied for the highest live-dispute count in the territory (14). Territory-wide, 51% of all active capacity now sits transitively behind a dispute; this project is squarely in that blocked half.
§4ITC deadline math
Assuming the project did not start construction by July 4, 2026 under IRS Notice 2025-42's physical-work standard, it must be placed in service by December 31, 2027 to retain the federal ITC. Working backward from energization: interconnection-agreement execution, construction, witness testing, and PTO realistically require 12–18 months after review completes — meaning review needs to complete by mid-2026 to mid-2027.
Against a 45-deep chain with 3 unclocked disputes, that window is not supported by the current data. At ~$1.4M/MW capex, the credit at risk is approximately $2.10M — about 30% of total project economics.
Risk tier: SEVERE (D) Drivers: depth percentile (83rd) + multiple inherited disputes + dispute-dense area + standard community-solar economics with no excess margin to absorb credit loss. A grade of F is reserved for projects whose chain contains a direct dependency on a disputed project within 5 hops.
§5What we would do this month
- Confirm safe-harbor posture immediately. If any 2026 physical work or 5%-cost position exists for this project, document it now with counsel — it converts the 2027 cliff into a 2030 horizon and changes this memo's grade to C+. This is the single highest-leverage action available.
- File a status inquiry referencing the three disputed ancestors by ID. Ameren's process allows queue-status inquiries; naming DER-44572 / DER-42060 / DER-39585 forces a written position on their resolution path — intelligence no dashboard provides.
- Model the withdrawal cascade. 28 of the 36 pending-review ancestors are ≥4.5 MW community-solar-class projects facing the same ITC math; historical analogs suggest a wave of withdrawals post-July 4. Each withdrawal shortens this chain. We re-run this analysis on each new snapshot — the included re-run next month will quantify the post-deadline shake-out.
- Price the alternative-POI option now, not later. Five queue areas currently show ≥5 active projects with zero disputes (ER-TX-2, NRS-TX-2, NRS-TX-7, NRP-TX-6, NRS-TX-6 — subtransmission corridors). If site control permits a feeder alternative, a re-file may beat the wait even with lost queue tenure. We can run the comparison per candidate parcel.
- Set the watchlist. This project + its 3 disputed ancestors + area WRN-8 go on daily monitoring; any status change, position move, or new upstream dispute triggers a same-day alert. (Included with the audit for 30 days.)
Methodology & limitations. Built from the Ameren Illinois public interconnection queue (snapshot 06/09/2026, 3,334 records), via deterministic dependency-graph analysis of the utility's published "Waiting On Project" references. Queue data is published by the utility on a lag and may not reflect undisclosed study progress; chain depth measures structural position, not a guaranteed timeline. ITC figures are estimates on stated assumptions ($1.4M/MW capex, 30% credit) — qualification determinations belong to your tax counsel. This memo is data analysis, not legal, tax, engineering, or investment advice. QueueSight is independent and unaffiliated with Ameren Illinois, the IPA, the ICC, or any utility. Sample memo note: prepared on a real, unaffiliated project selected from public data to demonstrate the deliverable; no client relationship exists with this project's owner.