R.U.S.H. Residents United to Save our Hometown
No Massive Solar Power Plant
No Massive Solar Power Plant
The preamble to our local solar law states “The intent is to both encourage the use of renewable energy systems based on sunlight while at the same time protecting the health, safety and general welfare of the residents of the Town of Rush.”
This is about risk assessment when there are possible, highly consequential risks to our soil, water and eventual bioaccumulation in the food chain. This is about risk assessment when PFAS compounds proliferate faster than EPA and state health departments can identify, test, assess toxicity over time and regulate.
It’s possible that solar panels proposed to be installed in Rush will have coatings containing perfluorinated alkylated substances (PFAS) that will contaminate water and soil and threaten the health and safety of Rush residents.
We simply do not know enough to be able to assess this threat because there are so many PFAS compounds; we’ve seen estimates that there may be 4000-5000 compounds classified as PFAS, and the EPA and state departments of health have not investigated most of them. According to the International Association of Environmental Professionals, concerns associated with PFAS include:
- hormone interference and lowering chance of pregnancy
- increased cholesterol
- impacts to thyroid, pancreas and liver
- impacts to growth, development and learning
- impacts to the immune system
We do not know if the solar panels coming into Rush will contain these coatings. We do not know the extent to which such coatings will leach into our air, soil and water; however, cracks, bubbles and mechanical failures in the coatings have been documented.
Little is known about PFAS other than as a class of fluorinated compounds they make slippery coatings. Solar panels coated with slippery surfaces shed water, dust and to a lesser extent snow because of the surface treatments. Therefore, the panels are more efficient and do not need as much labor and/or chemical mechanisms to remain clean. Older panels were coated with inert glass.
Out of an abundance of caution, we ask that you examine the information in the references and pay close attention as the Town of Rush welcomes the Tier 3 solar installations made possible by our local solar law. Of course, the looming threat is the proposed 600,000 solar panels associated with HSS.
What are these PFAS compounds? PFAS containing materials are everywhere; these surface treatment, coating materials have consumer names like Teflon, Scotchguard, GenX, etc. DuPont, 3M, Saint-Gobain and Chemours were or are presently major producers of PFAS materials, if not the ones already EPA-regulated (PFOA, PFOS), then analogs of the regulated ones. Industrial chemical spills have occurred in multiple states, including Hoosick Falls, NY. NYS regulates PFOA and PFOS at the level of less than 10 parts per trillion in water.
DuPont, 3M, Chemours and Saint-Gobain hid the evidence they had collected on the compounds’ production, toxicity, it’s bioaccumulation in soil, water, and thus the food chain and the ultimate uptake in humans. These companies and manufacturers in other countries change the chemical formulation so that the PFOA/PFOS regulations do not block production of new, shorter-chain PFAS compounds; these new analogs circumvent regulations. However, shorter chain PFAS are more soluble, might be more likely to transition to an aqueous phase, and tend to persist in the environment – so they are still of concern. The National Wildlife Federation diagram and the NPR video explain the concerns surrounding PFAS containing materials.
The mid-state California Central Valley Clean Water Association states that solar panels contain PFAS. California is #1 in installed solar. Two members of the dangerous PFAS compounds (PFOA and PFOS) are no longer produced in the U S but are still produced in other countries and are imported into the US.
The EPA announced that solar panels in North Carolina are coated with Gen X, a PFAS material, and produced documentation of PFAS uses in and on solar panels from Chinese and other researchers. NC is #2 in installed solar.
Dr. Annick Anctil from the University of Michigan’s Graham Sustainability Institute states that:
PFAS are not customarily used in solar panels because safer, effective alternatives have already been developed and commercialized. Moreover, no studies have shown the presence or leaching of PFAS from PV panels—either while they are in active use or at the end of their life (e.g., in a landfill).
The EPA is now seeking comments from importers and others about products brought into the US that contain PFAS materials. Solar panels are specifically enumerated.
Among those responding to this EPA request for comments is an April 17, 2020 letter to the EPA from NYS’s Attorney General and 17 other Attorneys General which states:
The Attorneys General are concerned about ALL perfluoroalkyl and polyfluoroalkyl substances (collectively “PFAS”). PFAS are pernicious “forever chemicals” that pose serious adverse risks to health and the environment at extremely low levels-e.g., parts per trillion in drinking water. . . The Attorneys General support EPA’s proposal. . . However. . .the final rule should be broadened to more effectively serve the goals and mandates of the Toxic Substance Control Act to prevent exposure to harmful substances BEFORE they are introduced into the marketplace. [ALL and BEFORE emphasis added]
Given the time for comments and then for study and then for regulation writing, western New York could be covered in solar panels, some of which might have dangerous coatings. What manufacturers’ solar panels will be installed in our town? Will the panels have PFAS coatings and if so, is the particular PFAS coating a dangerous one?
The Steering Committee of Residents United to Save our Hometown recommends that the Town of Rush require installers of Tier 3 and HSS to provide full documentation as to panel components. No PFAS materials should be permitted in/on panels installed in Rush unless the EPA or the NYSDofH has researched the material and its use. Further, installers should pay for baseline soil and water studies before panel installation and regular studies thereafter. The Town would select the laboratory and supervise the study protocols.
Please attend Town Board meetings to stay informed about our welcomed Tier 3 installations. And remember, that Horseshoe Solar seeks to install solar panels on residentially zoned, prime agricultural land including the culturally significant Golah site if their incursion into Rush is permitted by the Siting Board.
HSS has asked the Siting Board to waive major portions of our local solar law.
Please send your questions to information@RUSH-solar.com. We will attempt to answer them.
Bone remains discovered during cultural resource management investigations of the Golah Road site in Rush, NY are those of an adult human being.
"Anthropological analysis of the bone from the Golah Road site concludes that the bone is a proximal human foot phalanx due to the lack of diagnostic features of bear phalanges and anatomical similarities to modern human anatomical specimens of foot phalanges . . ."
Bone images adapted from the Wakefield Report - Photo A is Human; Photo B is Bear; Photo G found at Golah.
The Wakefield-Murphy report, “Bone remains at the Golah Road Site, Rush NY: an analysis of species identification and pathology,” can be downloaded from the New York State Public Service Commission:
The Livingston County News reported on the sequence of events leading to this discovery and determination in its article: “Seneca Nation calls on solar developer to ‘cease and desist’ following bone discovery,” available here:
Impacts of the proposed industrial-scale, Horseshoe Solar facility are presented and discussed by Dr. Joe Stahlman of the Seneca Nation Tribal
Historic Preservation Office in the video:
Protecting Our Ancestors: Saving Native Burial Grounds available here:
The Seneca Nation has produced a video entitled “Protecting Our Ancestors: Saving Native Burial Grounds.” It is available on the YouTube link below and on the Seneca Nation Facebook page. In the video, Seneca Nation President Rickey L. Armstrong, Sr. of Salamanca, NY (716 945 1790) speaks of a bone discovery.
Residents United to Save our Hometown (R.U.S.H.) is a community group located in Rush, New York that is concerned about the future of our region and its rural character. We are opposed to industrial-scale solar energy production on thousands of acres of prime agricultural land that corporations like Invenergy are trying to develop.
While, this is a good start, it is not enough – We need your support and help!
Thousands of years ago, the Seneca’s were the first residents of what we now call the Town of Rush. Our histories have been inextricably linked ever since.
The Haudenosaunee People, People of the Long House, are the original five tribes of the Confederacy or League: the Mohawk, the Oneida, the Onondaga, the Cayuga and the Seneca. The Seneca’s are sometimes called the “Keepers of the Western Door” because they are the western-most tribe of the Confederation.
The oral history suggests that the Five Nation Confederacy was formed sometime between 1450 and 1660 as a way to unite these western NY tribes with the common goal of living in peace and harmony yet recognizing the separate tribes with distinct customs and language. The Tuscarora’s joined the League when they were driven from the Carolinas by the British, 1714-1722, making up what is now referred to as the Six Nations.
The New York State Office of Parks, Recreation and Historical Preservation (NYSOPRHP) classifies land in Rush as “the most archeologically significant area in western NY” according to Josalyn Ferguson, a staff member for Monroe County when contacted in March, 2020.
Gravesite materials and artifacts now preserved at the RMSC collected from the Golah area attest to the Seneca presence. In fact, arrowheads of a certain description are termed Meadowood arrowheads. The homes of Meadowood are on the western-most length of Stull Road.
A 1932 State Education Department historical marker on the west side of East River Road just as you enter the Town of Rush denotes a Tuscarora Settlement. Scant hundreds of feet away is Elm Place, featured in Rush’s Bicentennial House Tour in 2018. Colonel William Markham III came to the Genesee Valley in 1789, built the first brick house in the Valley and became Rush’s first Supervisor in 1818. Rush’s Town Council met in the front parlor of Elm Place, on the Tuscarora Settlement land.
Another State Ed historical marker is near the West Rush Fire Department by Rush West Rush Road and Creekside Drive. It states that “Three Indian Tribes Fished and Tilled the Soil here for Thousands of Years”
The Nature Conservancy recognizes Rush’s Oak Openings as the eastern-most remaining Oak Opening in the US. Located on Honeoye Falls Five Points Road, a sign denotes Oak Openings as state property. Recent scholarly work by SUNY geographers at Geneseo and U. Buffalo have linked these oak openings or savannahs to Seneca land management in the late 1700s. It is believed that the Seneca’s burned closed canopy forests to create areas more amenable to hunting or easier travel. More information and a video from SUNY Geneseo are available at:
And now, once more, the Seneca’s and Rush are linked by HSS’s inclusion of Rush acreage and the selection of the Point of Interconnection (POI) at Golah. The Point of Interconnection refers to the place where energy produced by solar arrays enter the grid system.
The NYSDPS-DMM 18-02413 website lists the first filing for HSS, completely on the Caledonia side of the Genesee River, on 10/5/18. The 2600 acre, 180MW proposal would use a POI on reclaimed quarry land leased from Hanson Valley Sand and Gravel.
The second filing for HSS that includes the Town of Rush is for a 180MW, 3800 acre proposed installation listed on the website on 2/28/19. The POI at Golah is high value, culturally significant formerly Indigenous land- sacred land in the Seneca tradition.
The Steering Committee of Residents United to Save our Hometown has always had the removal of HSS from Rush land as our primary goal. A secondary goal is providing information on the issues associated with large-scale solar.
We’ve tried to detail some of the Town’s history with respect to our Indigenous first residents.
The sacred ground at Golah is not threatened if HSS moves west, back across the River.
Let us begin with wisdom from what the Onondaga call the WORDS THAT COME BEFORE ALL ELSE (perhaps more popularly known as The Thanksgiving Address).
After admonishing all who listen to recognize the duty to live in balance and harmony with each other and all living things, the WORDS recognize Mother Earth, the waters, the Fish life, the Plant life, the Food Plants, the Medicine Herbs. etc. Then the WORDS speak of trees.
“Standing around us we see all the Trees. The Earth has many families of Trees who each have their own instructions and uses. Some provide shelter and shade, others fruit and beauty and many useful gifts. The Maple is the leader of the trees, to recognize its gift of sugar when the People need it most. Many peoples of the world recognize a Tree as a symbol of peace and strength. With one mind we greet and thank the Tree life. Now our minds are one.” (Braiding Sweetgrass, Robin Wall Kimmerer, Citizen of the Potawatomi Nation and SUNY Distinguished Professor of Environmental Biology and Director of the Center for Native Peoples and the Environment, p.110)
The Town of Rush is fortunate to have state land on Honeoye Falls Five Points Road known as Oak Openings. Newly published research from SUNY Geneseo posit an explanation for such openings dating back thousands of years to our first Rush residents, the Seneca’s.
In a recent article in Annals of the American Association of Geographers, geographers from the State University of New York (SUNY) found that Native American land use—in particular, the use of fire—was critical in shaping the distribution of oak savannas in Western New York at the end of the 1700s.
Assistant Professor Stephen Tulowiecki and Professor David Robertson, both at SUNY Geneseo, along with Associate Professor Chris Larsen from the University at Buffalo, compared information gleaned from historical sources in order to map oak savannas and to better understand how both environmental conditions and Native Americans influenced their distribution around 1795.
Oak savannas are a globally endangered ecosystem. “We have maybe five good remnant locations of oak savannas, also known as oak openings, in New York State,” Tulowiecki said. “And within those ecosystems, there are rare plants. These landscapes are also beneficial for wildlife.”
The following is a link that will explain the NSF sponsored research with a video:
Article 10’s regulations decree that proposed solar installations must document and respect the cultural and archeological assets of any land potentially included in an installation’s footprint. The Town of Rush and the NYS Office of Parks, Recreation and Historic Preservation have long recognized that our first citizens were Indigenous People. The documentation is clear. But it was a recent Guest Essay in the Livingston County News that brought this cultural and archeological history to present dayconsiderations of Horseshoe Solar’s Point of Interconnection (POI). The POI is where the energy generated from solar panels enters the grid apparatus.
“It’s happening all over again. An outsider (Chicago-based Invenergy) is taking your land (residentially zoned Rush land) with the aid of the government (Cuomo’s Article 10 and 54-C) for the private profit of investors! You thought you were protected (local zoning law) but you’re not! You cannot trust the government where big money is concerned. The government does not respect the treaties they agreed to! They didn’t with us, they won’t with you!”
So began a poignant conversation with a gentleman who belongs to the Tonawanda Seneca Nation on Friday, June 26th. He had seen the Guest Essay by Michael Leroy Oberg, (Distinguished Professor of History and Director of the Geneseo Center for Local and Municipal History at SUNY Geneseo) available onthe Res United’s website.
The Oberg Essay, Horseshoe Solar array would ‘destroy’ site of Seneca village, notes that the study commissioned by HSS “diminishes Seneca attachment to the region and the historical reality that the site has a history going back further than that of London in England. . . The report’s authors spoke to no Seneca people, nor did they do any research in the archives”.
Continued conversations led to a meeting with other Native Americans, an invitation to the Reservation near Buffalo to meeting with the Tonawandan Historical Society and finally to a Tobacco Burning Ceremony at Golah.
On August 11, 2020, 205 years and one day after the death of Handsome Lake, almost 30 Indigenous people of the Tonawanda and Tuscarora tribes gathered at 260 Golah Road for the Tobacco Burning Ceremony to Honor the Ancestors who lived on this land.
Golah is at the junction of Honeoye Creek and the Genesee River- rich, alluvial soil and transport via canoe made possible by these waters. This site is sacred land to Indigenous Americans. Although many gravesites have been excavated and artifacts removed, the indigenous spirits reside in the land, not in boxes in museums and private collections.
Mr. Jacobs is a Tonawandan Faithkeeper, a man who keeps the rituals and ceremonies of the tribe. He conducted the sacred ceremony in the native Seneca language; he explained it afterwards to those assembled including Assemblywoman Byrnes, Supervisor Kusse, Mr. Stokie (who gave permission for the Ceremony on his land) and a few others of European descent.
Around 10:30, a small fire was lit on the plowed field to create the smoke to, in the words of Faithkeeper Jacobs, “pierce the sky, be driven by the wind, to travel to wherever our ancestors may be”.
The ceremony began when Levi Winnie, Tonawanda Seneca, gave three sharp calls, much like those of crows, to draw attention and gather all spirits to pay attention to the entreaty and lesson that was to come.
The smoke from the burning tobacco goes first to the Great Maker who gives all resources and is ever present. The smoke gathers all souls, each will add power and speak through one voice, Mr. Jacobs’, in the ceremony. By all speakers, The Haudenosaunee include all things who came first- the wind, the water, the moon, the sun, the plants, the animals, etc. We people are the “younger brothers of Creation”. We came second. We, therefore, have the most to learn.
Nicotiana rustica, the tobacco used in the ceremony is not the current commercial tobacco used for cigarettes or cigars. Rather it was originally cultivated by Indigenous people in the eastern U.S. and later modified and altered to become the tobaccos we associate with pipes, cigars and cigarettes. Throughout the ceremony, the tobacco was thrown on the fire so that the smoke continued to gather all souls, their power and their voices together.
Handsome Lake, a Seneca spiritual leader and prophet, instructed the people of Canawaugus and those living at Golahto be wary of non-native brothers and sisters, the Europeans. The warning prophecy was because these people, the Europeans, thought they could control the Earth, and all the things that came first. But Handsome Lake foretold that one day, the non-natives would learn they did not have dominion. Something would arise to teach them. Handsome Lake warned the native people to not get caught up in the foolishness of the Europeans colonizing the land as if to own and control it. One day, the lesson would be learned. Was he warning of climate change? Of Covid-19?
On this day, in the midst of the tobacco smoke, Mr. Jacobs entreated the spirits to gather and to use their force to move, to push, this off their sacred land. For like the time so long ago, the non-native brothers believe they can control the forces of the earth. Once again, Mr. Jacobs said, it is as if they (the Europeans) have their hands around our throats, holding our heads down and we cannot breathe. We must elevate the discussion of the continuous denigration of Indigenous Peoples to something beyond pulling down statues of Christopher Columbus and celebrating Columbus Day as a national holiday.
To the spirit forces, Mr. Jacobs said, “You are resting here. You are speaking through me. We ask you for the power to push thissomewhere else- push it off to the side, to a different land!”
Mr. Jacobs was speaking of Horseshoe Solar. Push Horseshoe Solar off to the west side of the Genesee River using reclaimed quarry land as originally planned for the additional substation, the 5200 square foot Operations and Maintenance Building, the 5 acre lay down yard. Remove it from Golah!
Let the Ancestors and their spirits rest undisturbed where they lived so many years ago.
No pictures or recordings were permitted during the Tobacco Burning Ceremony. This description was written after the fact. To be assured of its accuracy, Mr. Jacobs received a copy for evaluation. In the Haudenosaunee oral tradition, FaithkeeperJacobs passed along word that the chronicling and interpretation are accurate and correct. Perhaps of additional interest, Mr. Winnie camped with the Standing Rock Sioux on three separate trips to protest the Dakota Access Pipeline.
Several members of Residents United to Save our Hometown were invited to attend the August 2nd meeting of the Tonawanda Historical Society at their Reservation in Buffalo to discuss HSS and its proposed use of land at Golah- land sacred to the Seneca Nation. At that meeting, many attendees asked to join our membership list to receive HSS updates. An announcement of a presentation on HSS by Invenergy at a future Rush Town Board meeting sparked their interest.
At the August 12th meeting of the Rush Town Board available on You Tube, you can see and listen to some of the Tonawanda and Tuscarora Seneca who attended and asked questions of Ms. Millar, the current HSS Project Developer, Renewable Development.
Among the queries of Ms. Millar were several about HSS and trees. During the first public comment period, a caller reported that he had seen girdled trees while driving through lands proposed to be part of HSS. After her presentation, Ms. Millar was asked about “old growth trees”, huge trees that might be infields. Ms. Millar responded that HSS has no plan to touch them in any way, that HSS understands they may have cultural significance. Ms. Millar specifically referenced these large, old growth trees, some called Geneseo Oaks.
Trees in the middle of fields covered in solar panels or along borders of solar installations cast shade and diminish the already poor efficacy of solar panels in the Rochester region’s very cloudy environment.
Tree girdling is the practice of cutting through the bark (or cambium layer) around the entire circumference of the tree thus preventing the phloem tissue layer from carrying food produced in the leaves by photosynthesis to the roots. When the roots die, they stop sending water and minerals to the leaves; then theydie. Of course, trees die for all sorts of reasons- insect and animal infestation, lightening strikes, etc. However, oak trees, as a species, have also lived for centuries; certainly these Geneseo Oaks are centuries old.
The pictured tree is dying, perhaps from other causes but now certainly because it has been girdled, the bark deliberately sliced around the entire circumference. Notice the sawed ring girdling the tree close to the ground. This tree, in an open field on River Road in Caledonia will never reach the awe-inspiring size of the beautiful trees we frequently see in meadows and tilled fields here in Rush and Caledonia.
Trees in open fields, or oak openings, can reach enormous size because their growth is unfettered by the lack of sunlight and nutrients in closed canopy forests. (Please see the information on oak openings on this website in material titled Trees and the Seneca’s.) To fully appreciate the size these trees can reach, you can visit the Livingston County Historical Museum in Geneseo where a portion of a mammoth oak tree trunk is now protected.The oak’s trunk is displayed in a room surrounded by descriptive information about Jo’nehsi:yo:h , the Beautiful Valley of the Seneca’s. A video on the Museum’s website demonstrates the reassembling of this enormous oak’s trunk.
How ironic that in order to turn sunlight into energy with solar panels, one might girdle trees to prevent photosynthesis from doing the very same thing.
Table of Contents
Cuomo’s goal is for New York State to produce 6,000 megawatts of solar power. The Town of Rush solar law permits up to 150 acres of large-scale (Tier 3) solar installations, which would produce 30 megawatts of power. That’s almost five times Cuomo’s goal per town in the state, nine times Cuomo’s goal per square mile and twenty-eight times Cuomo’s goal per resident.
Instructions for emailing our NYS legislators to express our concerns regarding the proposed new Accelerated Renewable Energy Growth & Community Benefit Act and the Major Renewable Energy Development Program with respect to New York State’s Home-Rule Authority and Protection of Agricultural Land.
Instructions for emailing our NYS legislators asking for their support to develop and implement sensible siting strategies for large-scale solar energy generation installation facilities in our state. Please join us in making our voices heard.
Instructions for sending these messages are included below.