By Phillips Lytle attorneys David P. Flynn and Zachary Hirschfeld
On October 22, 2025, New York State’s Office of Renewable Energy Siting (ORES) released revisions to the proposed regulations to implement the Renewable Action Through Project Interconnection and Deployment Act (RAPID Act). The RAPID Act was enacted to accelerate the siting of both major renewable energy facilities (25 MW+) and major electric transmission facilities (125 kV+). Under the RAPID Act, ORES now administers the environmental review, permitting and siting of these facilities in NYS under the new Article VIII process.
After proposing initial regulations in December 2024, ORES received more than 2,000 public comments. In response to these comments, ORES has issued revisions to its proposed regulations. There is now a 45-day public comment period on these revisions, with comments due by December 8, 2025.
The revisions focus on the following seven key areas:
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