FERC Order 2023 Effective: June 12, 2024

NYISO Interconnection
Site Control Compliance

New York developers face a dual regulatory track: NYISO interconnection under FERC Order 2023 plus ORES Article 17 state siting for projects ≥25 MW. Here's everything you need to navigate both tracks and maintain site control compliance through IA execution.

NYISO Site Control Thresholds by Stage

Under FERC Order 2023, NYISO requires increasing site control coverage at each Class Year milestone. Options count at full weight (1.0) through Class Year Study, reduced weight at Facilities Study, and are excluded at IA execution.

Queue Stage Coverage Threshold Options Allowed Option Weight Encumbrance Policy
Pre-application0%Yes1.0Allow
Class Year Study90%Yes1.0Flag
Facilities Study90%Yes0.75Disqualify
IA Execution100%No0.0Disqualify
Commercial Operation100%No0.0Disqualify

Eligible instruments at IA execution: fee simple, executed lease, easement, ROW agreement. Source: NYISO OATT Attachment S, FERC Order 2023 compliance filing.

For the full cross-RTO comparison, see FERC Order 2023 Thresholds by RTO and Stage.

What Changed for NYISO Under FERC Order 2023

Before: Serial Queue

  • • One threshold at one milestone
  • • Class Year studies already batched, but site control loosely enforced
  • • No formal graduated coverage requirements
  • • Speculative projects in queue for years
  • • ORES siting process operated independently of queue timing

After: FERC Order 2023 + ORES Dual Track

  • Graduated thresholds — 90% at Class Year, 90% at Facilities, 100% at IA
  • Class Year batching — projects studied together in annual cohorts
  • ORES PSS requires site control — sometimes before NYISO queue application
  • Options downweighted at Facilities — 0.75 weight, excluded at IA
  • Dual-track coordination — NYISO queue milestones must align with ORES Article 17 timeline

NYISO Class Year Key Milestones

Class Year

Class Year Application Window

Annual batching window. Projects accepted into cohort for joint study

CY Study

Class Year Study — 90% Coverage Required

Deliverability and system reliability studies. Options count at full weight (1.0). Encumbrances flagged

Facilities

Facilities Study — 90% Coverage Required

Network upgrade cost allocation. Options downweighted to 0.75. Encumbrances disqualify

IA Exec

IA Execution — 100% Coverage Required

100% site control with executed instruments only — no options

COD

Commercial Operation

100% coverage maintained through operation. ORES permit conditions must also be satisfied

NYISO Site Control Resources

Common NYISO Site Control Risks

Agricultural District §305-a Notification

Converting agricultural land triggers a mandatory 30-day notification to the county agricultural board and NYSDAM under Agriculture & Markets Law §305-a. Missing this step can delay both ORES and NYISO timelines. Land teams must identify ag district parcels early and initiate the notification process well before queue application.

Adirondack Park Agency (APA) Jurisdiction

Utility-scale generation is essentially prohibited on most Adirondack Park Agency land. Projects that unknowingly include APA-jurisdictional parcels face complete site control disqualification on those areas. Parcel-level APA boundary verification is critical before signing any lease or option agreement in northern New York.

Conservation Restrictions from Land Trusts

Organizations like the Open Space Institute and Scenic Hudson hold conservation easements across large swaths of upstate New York. These restrictions can silently encumber leased parcels and disqualify coverage from Facilities Study onward. Title searches must specifically check for land trust conservation restrictions.

ORES PSS Timing vs. NYISO Queue

The ORES Preliminary Scoping Statement (PSS) requires site control documentation and may need to be filed before the NYISO queue application. Misaligning these two timelines can force developers into a costly sequencing problem: ORES needs site control proof that NYISO hasn't yet required. Coordinate both tracks from day one.

Automate NYISO Site Control Compliance

Zonevex parses your lease PDFs, matches parcels to the project boundary, applies NYISO's stage-specific thresholds, and tells you exactly where your coverage stands — across both the NYISO queue and ORES siting tracks.

90%

Class Year threshold

90%

Facilities threshold

100%

IA execution

5

Audit filters

Official NYISO & ORES Resources