On September 29, 2026, the New York State Senate Minority Conference’s Energy Roundtable focused on Solar, Wind and ORES was held at the Onondaga Town Hall. One of the speakers, Janet Glocker, talked about the Horseshoe Solar project and graciously agreed to share her presentation with me. Horseshoe Solar is another example of a project that I think has unacceptable environmental impacts.
I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks coupled with the cumulative environmental impacts of those resources. These comments are based on those concerns. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with; these comments are mine alone. I acknowledge the use of Perplexity AI to research and organize the material summarized in this article. The numbers, calculations, and sources behind this post are documented in a Supporting Details attachment.
Horseshoe Solar was originally proposed under Article 10, so documents are available in the Article 10 permit docket. When the Office of Renewable Energy Siting (ORES) option became available, Invenergy switched, so additional documents are in the ORES permit docket.
According to Invenergy, the Horseshoe Solar Energy Center (accessed on 9/30/2026) is “a proposed 180-megawatt solar power generation facility in Livingston and Monroe Counties” that will deliver “reliable, affordable energy.” Of course, the developer’s description is optimistic. The Public Involvement Program plan claims that the project will produce enough electricity for 50,000 New York households. That is an annual-energy comparison, not a claim that the facility can power 50,000 homes around the clock. It also assumes a 23.4% capacity factor, which is higher than the 18%–19% NYISO reported for New York’s solar fleet in 2024 and 2025. At those observed rates, the household equivalent drops to about 39,000–42,000, and none of those homes would be served at night.
To its credit, Horseshoe Solar has made a permit-backed commitment to agricultural co-use, principally sheep grazing. I believe agrivoltaics commitments like this are appropriate, but I am not sure this one will ever come true. New York has about 83,000 sheep, and grazing every solar project in the interconnection queue would need about 127,000. The 2050 buildout would need about 1 million.
Janet Glocker lives in the Town of Rush, where part of Horseshoe Solar is being built. Her full presentation is worth reading. Her refrain throughout was “All this for less than 2 MW?” I expand on five of her points below.
Prime Farmland Conversion
Glocker described her town:
We are primarily rural and agricultural- 19,600 acres of which 50% is farmed. Soils in Rush are characterized as 60% prime farmland, 7.8% prime if drained, 12.5% soils of statewide importance; only 19.6% is not prime farmland.
The Department of Agriculture and Markets has had a goal for solar projects: limit the conversion of agricultural areas within the Project Area to no more than 10% of the soils it classifies as prime farmland that has never been made a requirement. The Department described this goal in testimony in the Trelina Solar case. Horseshoe Solar does not meet that goal. The project area is 3,748 acres, and 552 acres of prime farmland, or about 15%, will be converted to industrial solar use. To be fair, the developer removed arrays from some prime farmland during permitting. Even so, ORES approved a project that exceeds the State’s own agricultural guideline by half. My Solar Development Prime Farmland Scorecard found that most approved projects exceed it. That is a cumulative impact the Climate Act implementation process ignores.
The Genesee River Crossing
The second point is that the project is on both sides of the Genesee River, and the risks of the river crossing exceed the value of the added solar capacity. Glocker explains:
Horseshoe plans to build 8.4MW (name plate) in Rush. We all know that with Great Lakes cloud coverage and the earth’s curvature, we’re lucky if 20%, or 1.68 MW will be produced. Please remember this number- less than 2MW!
Glocker mixes capacity and energy here. Nameplate capacity is the panels’ maximum output under ideal conditions. Her 1.68 MW is the average output over a year, which is really a measure of energy. Using the capacity factors discussed above, the Rush panels would average 1.5 to 2.0 MW, so “less than 2 MW” is a fair description.
For reliability, what matters is effective capacity: how much the resource can be counted on when the system needs it. NYISO’s capacity accreditation factors credit upstate solar at only 13.85% to 15.33% of nameplate. By that measure, the Rush panels are worth about 1.2 to 1.3 MW of reliable capacity, and the entire 180 MW project is worth about 25 to 28 MW. Glocker’s “less than 2 MW” actually overstates the reliability value.
Glocker goes on:
During the Article 10 process… engineers from DPS warned Invenergy about horizontal directional drilling, karst soil, the “swiss cheese, limestone material” that underlies much of Rush. We use springs and wells in the part of Rush near Horseshoe…
The plan was to drill 7 holes under the Genesee. After hitting an aquifer in early February and having holes fill with water, new holes had to be drilled- a 42.8% failure rate. Six residences, immediately across the river from the drilling site had their springs and well water affected…
Six homes, damaged springs and wells, water totes still visible. Not knowing what is happening underground, now or in the future, would you buy one of these houses? All this for less than 2MW.
The record supports her account. 13WHAM reported that groundwater began surfacing on February 3, 2026 at 50 to 100 gallons per minute. The company told News10NBC that five homes had low water levels and that it supplied drinking water. The seepage required two rounds of chemical grouting. On August 26, 2026, ORES asked Invenergy for a plan to monitor the bore area for at least 12 more months. Nearly eight months after the aquifer was punctured, nobody can say for sure that the problem is fixed.
In fairness, the crossing is not just for the Rush panels. According to ORES, the project connects to the grid at National Grid’s Golah Substation in Rush, so power from the Caledonia arrays must also cross the river. Nonetheless, Glocker’s point stands. Rush residents bear the risks of the crossing, but their town hosts panels that are credited with only about 1.2 MW of reliable capacity. That is not a reasonable trade-off for people who depend on springs and wells.
Subsidies and Local Costs
The third point compares the subsidies from COMIDA, the Monroe County Industrial Development Agency, to the supposed benefits. Glocker explains:
IDAs are supposed to grant subsidies to promote job creation. Monroe County’s IDA, COMIDA, gave Invenergy $19 million in subsidies. In the COMIDA application, Invenergy wrote “Large scale renewable energy systems are not financially viable absent financial assistance from IDAs…”
I checked her number. The COMIDA application lists a “Total value of incentives” of $19,354,096 for the Monroe County portion of the project. However, the cost-benefit analysis in the same application puts the total cost of the exemptions at $4.9 million. The difference comes from two very different sales tax figures that I cannot reconcile. Either way, the economic benefits are small. The Horseshoe Solar website claims only $3 million in total economic investment, 300+ construction jobs, and 3 full-time jobs for the entire project. That works out to between $1.6 million and $6.5 million in tax breaks for each permanent job. The point is clear: large subsidies and little economic gain.
Glocker went on to explain that because Invenergy pays less, her county, school, and town taxes may go up. Over the 25-year payment-in-lieu-of-taxes agreement, Horseshoe will pay about $471,000 instead of $3.8 million in full taxes. Local taxes are set by budgets, so the abatement does not automatically raise anyone’s bill. However, it does mean that the new industrial facility will not carry its full share of local costs, and residents carry that burden instead. Residents also pay some of the highest electricity prices in the country. The Empire Center found that New York’s residential price was 29.93 cents per kilowatt-hour in May 2026, third highest in the nation.
Archaeological Impacts
The fourth point is archaeological impacts. Glocker states:
Honeoye Creek intersects the Genesee River at a place called Golah. The State Office of Historical Preservation (SHPO) identified the rich, alluvial soils along the Genesee and particularly at Golah as one of western NY’s most culturally rich areas. It is quite simply sacred land.
Indeed, a bone found there in 2020 during the archaeological evaluation was described by Seneca experts as human; Invenergy’s expert identified it as either a bear or a heron bone… Thousands of steel beams will be pounded into the ground to support the solar panels- what will they destroy?
The sensitivity of this area is not in dispute. A bone analysis report filed in the docket concluded that the bone was a human foot bone from an adult, not a heron or bear bone. The Seneca Nation was cited as identifying 46 known archaeological sites within 500 feet of the project and asked for further investigation using ground penetrating radar. Instead, ORES required a plan to monitor construction and deal with unanticipated discoveries. In other words, the plan is to find out whether there are graves when the construction crews hit them. I agree with Glocker that this is not an acceptable way to treat land the Seneca consider sacred.
Different Rules for Utilities and Developers
The fifth point is the difference in requirements for the utility, Niagara Mohawk Power Corporation d/b/a National Grid, and the developer. Glocker explains:
A new substation is potentially to be built at Golah by Niagara Mohawk. But utilities must undergo careful cultural investigations…
We do this for substations, but not for solar panels? All this for less than 2MW?
National Grid’s Article VII case includes a New Golah Substation in Rush. I could not find the specific Staff request Glocker quoted, but the record shows the difference she describes. National Grid’s project has gone through four phases of archaeological work, including a Phase III Data Recovery Work Plan. That plan was required after SHPO found an Indigenous site eligible for the State and National Registers. The Horseshoe arrays on the same culturally sensitive land were approved after only the first two phases. If utilities must do this for a substation, why don’t solar developers have to do it for roughly 1,260 acres of panels?
I think Horseshoe Solar is another solar project with unacceptable impacts. It converts more prime farmland than the State’s agricultural goal allows. The river crossing punctured an aquifer and left Rush residents on delivered water. The local subsidies are large relative to three permanent jobs. The project was permitted on land the Seneca consider sacred without the archaeological investigation required of the utility next door. All of this is for panels in Rush that NYISO credits with only about 1.2 MW of reliable capacity.
The Horseshoe Solar story is a microcosm of what is wrong with Climate Act implementation. The State is so focused on meeting arbitrary targets that it does not consider the cumulative environmental impacts on host communities. Until the State develops responsible siting requirements that protect prime farmland, water supplies, and cultural resources, I expect we will hear more stories like the one Janet Glocker told at the roundtable.
Thanks again to Janet for sending me her notes.
