New York and Pennsylvania both require a utility interconnection application before a solar array may export. They do not share a form, a kW cutoff, or a portal. New York’s rulebook is the Standardized Interconnection Requirements (SIR) from the Public Service Commission, currently the version effective February 9, 2026, for DG and storage 5 MW or less. Pennsylvania’s rulebook is 52 Pa. Code Chapter 75, Levels 1 through 4, administered by each EDC.
If you run crews in both states, keep two checklists. Copy-pasting a Con Edison small-DG packet onto a PECO Level 1 job wastes a week.
New York SIR, in installer terms
The SIR is statewide. Con Edison, National Grid (Niagara Mohawk), NYSEG, RG&E, Orange & Rockland, and Central Hudson all implement it, with their own portals and construction standards.
The split you will use daily is 50 kW AC.
Con Edison’s interconnection page:
- ≤50 kW: SIR, small-DG PowerClerk, no application fee
- >50 kW to 5 MW: SIR, pre-application / large-DG PowerClerk, $750 application fee, CESIR and utility construction if triggered
- Above SIR or wholesale: different jurisdiction (NYISO / FERC). Do not force that into small-DG PowerClerk.
The SIR itself says no application fee for systems 50 kW or less. Above 50 kW, the $750 pre-application interacts with the later application fee as the SIR text describes (credit in defined cases). Read the current PDF rather than a 2022 Con Edison solar guide if they conflict. Con Edison’s own PV guide warns that the SIR takes precedence.
Underground network areas and non-inverter machines have extra SIR notes. A Brooklyn network job is not a Binghamton radial job.
NY-Sun is NYSERDA. It does not issue permission to operate. PTO still comes from the utility after SIR steps, inspection, and any verification testing. As-builts show up on larger closeouts. PPO and permit to operate are the same written authorization.
Long Island adds PSEG Long Island process on top of the usual New York mess. Confirm the LIPA/PSEG path before you tell a Suffolk customer you “filed SIR like Con Ed.”
Pennsylvania Chapter 75
Section 75.34 sets the tracks:
- Level 1: inverter-based, certified equipment, electric nameplate 10 kW or less
- Level 2: inverter, certified, 2 MW or less, radial (or spot network serving one customer), including jobs that failed Level 1
- Level 3: 2 MW or less that do not qualify or did not pass Level 1/2
- Level 4: non-export jobs that do not qualify for Level 1/2, potentially expedited
Section 75.35: technical standards are IEEE 1547 and UL 1741 unless the chapter says otherwise.
Section 75.37 Level 1: the EDC has a completeness window (10 business days in the section) then additional business days to run Level 1 screens. If Level 1 fails, the customer may submit for Level 2, 3, or 4 without sacrificing the original queue position, per that section.
That 10 kW Level 1 cap is smaller than New York’s 50 kW no-fee SIR band. A 12 kW Pennsylvania residential roof is not Level 1. File the correct level on the first interconnection application.
PECO’s MyGeneration portal and interconnection brochure translate this into PECO language: submit the application, wait for review (they describe 10 to 20 days as typical for the residential-scale discussion in the brochure), install after approval, possible PECO inspection, then a signed Permission to Operate letter and new meters. FirstEnergy operating companies (Met-Ed, Penelec, Penn Power, West Penn) and PPL and Duquesne Light each have their own intake. Chapter 75 is the floor. The portal is local.
Pennsylvania net metering and SRECs are adjacent. They are not PTO. See our Pennsylvania net metering and SREC guide.
Side-by-side, without fake precision
- Cutoff for the “easy” track: NY SIR 50 kW vs PA Level 1 10 kW
- Application fee on easy track: Con Edison none at ≤50 kW; PA fees are set under section 75.33 / PUC and posted by each EDC. Look at the EDC site. Do not invent a number here.
- Study language: CESIR in New York vs Level 3 in Pennsylvania
- Closeout name: SIR PTO / letter of acceptance vs PECO Permission to Operate
- Incentive overlay: NY-Sun vs PA AEPS / SRECs
Moving either application forward
Incomplete files stall both states. Match the one-line to the AHJ permit design. Use a PE stamp when the utility or the town requires an engineer in responsible charge. File as-builts if the roof changed before PTO.
Athol Energy prepares interconnection packets for both rulebooks. New York design: solar design services New York. Pennsylvania: solar design services Pennsylvania. City pages if you need them: NYC, Philadelphia.
Sources: NY SIR effective February 9, 2026, Con Edison applying for interconnection, 52 Pa. Code Chapter 75, PECO MyGeneration.