New York SIR security-mode requalification

Current commercial state: policy-transition requalification before economics.

The 2025 PSC reform allows standby letters of credit for qualifying distribution-upgrade obligations above $500,000. Public eligibility, issuer, standard-form and SLOC-to-cash rules are deterministic and treated as $0 buyer value.

What changed

The RIC/Rosemawr relationship predates the reform. Current discovery must first establish whether Rosemawr still participates in cash deposits, SLOC collateral/fees, later cash conversion, or a mixed security-state workflow.

Utility form portability

Fresh public-source review retains three public utility form families over one common objective fact schema: National Grid UCP 600, NYSEG/RG&E ISP98/New York law, and Con Edison/O&R ISP98/New York law plus a Security Agreement. Family-specific notice, presentation, expiry and draw controls are not interchangeable. The target utility remains unresolved for Gridi/Rosemawr, so no customer-family conformance claim is made.

Download the synthetic form-family portability proof

Paid hypothesis

Only explicit point-in-time project/facility/security-state binding and measured downstream re-performance can create countable buyer value. Public rule classification and template conformance cannot.

Source boundary

The current New York State SIR effective February 9, 2026 is retained, SHA-bound and admitted as a source-admitted statewide public-rule core. Its five public SLOC scenarios are modeled fail-closed. This proves only bounded statewide public-rule classification: target applicability remains unresolved, utility-specific extensions remain separate, and full NY-SIR target/customer production coverage is not claimed.

The admitted statewide source does not establish that any Gridi/Rosemawr financed project is within the SIR family, what security was actually posted, whether a financing facility funded it, refundability, legal effect, buyer value, payer or willingness to pay.

Download the five-scenario synthetic public-rule proof

Download the earlier three-case synthetic examples