Solidigm Chip Plant Plan for Marcy Hinges on China Export Waiver

A second memory giant tries to move into Upstate New York

The proposal to put a second big memory-chip complex in Central New York did not start with last week's headlines. Oneida County Executive Anthony Picente says local, state and federal officials have been meeting privately about it since spring. He describes the effort as several months of weekly work, not a sudden development.1 The company involved is Solidigm, a chipmaker based in California whose production happens in China. It is owned by SK Hynix of South Korea, one of Micron Technology's largest global competitors. Solidigm wants to build a pair of fabrication plants at the Marcy Nanocenter, just north of Utica.1

Picente has described a $45 billion investment covering two fabs and as many as 5,000 jobs within a few years. He has not confirmed that Solidigm is the company.23 State economic development officials call the proposal "Project Nova."1 Gov. Kathy Hochul has confirmed she is part of the talks without naming the company. She says the deal depends on federal approvals that may still be weeks off, and that it is not imminent.2

The main question is not whether Upstate New York wants the plant. It plainly does. The question is whether Washington will accept the trade Solidigm appears to be offering: a U.S. factory in return for looser export controls on its plant in China.

The China trade at the center of the deal

Reuters first reported that SK Hynix has linked the new U.S. NAND factory to approval for shipping more American chipmaking equipment to its site in Dalian, China.26 The focus is a building called Mod B, finished in 2023. Equipment installation there stopped during a memory-market slump, and the building still has a lot of empty space.2628 The Dalian site uses tools from Lam Research, Applied Materials and KLA.27

Accounts of how big the request is do not agree, and the gap is important. According to Reuters' sources, Solidigm wants to fill the unused space to raise NAND output. The extra revenue would help pay for the U.S. plant and serve as a bridge to production in America.2126 Bloomberg's later reporting describes upgrading Dalian with newer manufacturing processes, with technology developed in China possibly moving to the U.S. site later.30 SK Hynix, for its part, says it is not trying to expand capacity at Mod B and that installation is going ahead in close consultation with Washington and under its authorization.2224

The company's denial and the reported request can both be true in a narrow sense. Filling space in an existing building is not the same as building a new one. Still, the Commerce Department's current policy is to license only equipment needed to keep existing Chinese plants running, and in principle not to license tools that add capacity or upgrade technology.28 That makes the wording of SK Hynix's denial look less like a side detail and more like an argument made with regulators in mind. The rules have already been tightened once. In September 2025 the Trump administration revoked the special exemptions that let SK Hynix, Samsung and Intel facilities in China receive U.S. tools without separate licenses, and replaced them with annual licenses.22 One source told Reuters that Commerce has not yet issued a license for more U.S. equipment in 2027.26

Solidigm has also hired help in Washington. It disclosed paying $50,000 to Ballard Partners to lobby on "domestic memory chip manufacturing policy and outbound investment compliance."3

Money, timing and conflicting reports

The financing has changed noticeably in just a few weeks. In mid-October, reports said Solidigm was preparing a U.S. IPO in 2027 that could raise around $10 billion at a valuation of up to $100 billion.22 On Oct. 23, SK Hynix dropped that plan, citing capital-market conditions and chip share prices, and said it would look at other ways to pay for future investment.23 Another account says the IPO was abandoned after opposition from regulators and shareholders.30 Either way, one obvious source of funding is gone, which puts more weight on Dalian's cash flow and on government incentives.

The size of the project also varies by source. Bloomberg reports that Solidigm has told U.S. officials its investment could begin around $45 billion and eventually approach $100 billion.2330 The $45 billion figure matches what Picente has said about Marcy.3

The schedule is the biggest source of tension. Bloomberg's sources say construction could start in 2027.23 But the most valuable subsidy available, the CHIPS Act's 35% federal tax credit on construction and equipment, requires construction to begin by Dec. 31, with some exceptions.3 Hochul has admitted the deadline is tight. She suggested the company would need to meet certain milestones, possibly material deliveries, rather than full construction, before the end of the year.1 Picente said the original plan was a September announcement, which slipped because federal approvals took longer than expected.1 If the 2027 timeline is accurate, the company either has to find a way to qualify for the credit through early milestones or give up a large share of its subsidy. In my view, that pressure helps explain why the process has moved so fast and why Marcy town officials say they heard about it from news reports.1

Can Marcy handle a two-fab complex?

Marcy is one of only three "shovel-ready" chip sites in Upstate New York identified in Micron's environmental report. Micron ruled out all three as too small for its four fabs.3 The Nanocenter covers more than 400 acres, but only about 150 are still open, which is small for two fabs. Micron's two fabs in Clay sit on about 800 acres.1 The site has hosted chipmakers before. Danfoss Silicon Power opened there in 2017, and Wolfspeed opened a $1 billion plant in 2022 that now employs about 500 people.1

Water is the other physical constraint. Marcy would draw on the Mohawk Valley Water Authority's 121-year-old Hinckley Reservoir, which serves about 130,000 customers. Micron, by contrast, plans to take up to 48 million gallons a day from Lake Ontario at full buildout.1 Picente says the authority has enough supply.1 The permitting history is a reminder of what lies ahead: Micron's environmental review ran to 20,000 pages and took more than two years.1 The town of Marcy would lead the state environmental review.1

How Micron's region is reacting

The Marcy site is about 60 miles east of Micron's complex in Clay and about 100 miles west of GlobalFoundries' expanding plant in Saratoga County.1 Micron poured first concrete in Clay in July, ahead of schedule, and raised its planned U.S. spending to more than $250 billion through 2035.13 Bechtel, which is building the first Clay fab, expects thousands of construction workers on site by next summer.7

The reaction around Micron has been cautious. Picente says Onondaga County Executive Ryan McMahon "expressed his concerns" about Marcy. McMahon did not respond to requests for comment, and Micron declined to comment.1 Rob Simpson of CenterState CEO said adding a second megaproject would strain the supply of construction labor and talent, though he believes training efforts can meet the need.1 Hochul has tried to reassure Micron, saying it "will always be the first child," and says the building trades have told her they can staff two projects.2

The two companies' products differ more than the word "competitor" suggests. About 75% of Micron's sales come from DRAM. Solidigm makes NAND flash, which competes with Micron's smaller NAND business, the remaining 25% of its revenue.1 Worries about trade secrets have been raised. A University of Florida security researcher argued that distance between plants has little to do with that risk, since engineers move between countries as easily as between towns.1

The likely outcome

The industrial argument is strong. NAND prices have risen sharply on demand from AI data centers. TrendForce expects another 15% to 20% increase this quarter.22 Commerce Secretary Howard Lutnick has publicly pushed SK Hynix and Samsung to build plants in the U.S.22 Hochul's remark about waiting "two weeks" suggests the election in early November is shaping the timing.2

My reading is that Project Nova will depend less on Marcy's acreage or water than on whether the administration is willing to give a Korean firm more room for its Chinese operations in exchange for a U.S. plant. The company's insistence that it is not adding capacity is aimed at making that trade easier to defend. A firm conditioned on Dalian, combined with a Dec. 31 subsidy deadline and a canceled IPO, leaves little room to maneuver. If Washington approves the request in the coming weeks, Upstate New York's chip corridor would gain a significant new link. If it does not, the Marcy site would most likely stay open for the next company that considers it.