ARCADIAN ALLIANCE
Position Paper on Hecate Energy’s 2024 Permit Application to NYS for Shepherd’s Run Solar Facility
Position 1: Stop a Solar Permit Precedent that allows the Developer to place unjust economic, environmental and social-cultural burdens on rural communities including risk to historic resources.
The proposed Shepherd’s Run solar project in rural Craryville, NY threatens five National Register eligible resources and their related landscapes: 1) c.1850 Niver Farmhouse; 2) c.1860 Sir William Farm; 3) c.1870 Craryville Depot Complex; 4) c.1818 North Copake Cemetery; and 5) c.1890 Vernacular Farmhouse. If approved, it would establish a precedent for a solar siting and permitting process that undervalues rural historic resources and community involvement, and relieves the Developer of any burden to compromise. The process holds no accountability for the social/cultural, environmental, and economic burdens unfairly placed on rural communities. Hecate consultant, TRC, prepared the 2021 “Historic Architectural Resources Survey and Effects Report” with inadequacies that include:
a. Poor Siting Poses Risks. The 42MW Project is proposed for the heart of the hamlet of Craryville, targeted for its proximity to open farmland and an existing electrical substation. Sited on the NYS DEC protected Taghkanic Creek headwaters, it poses a risk to the water supply for the City of Hudson, and the environment, fire safety, and quality of life for site-adjacent residents, businesses, and K-12 students at the Taconic Hills Central School.
b. Uninformed Historic Context Statement. An understanding of historic context is essential for identifying the significance of rural properties. Yet, TRC never sought input or knowledge from the local historic preservation community. As a result, they failed to recognize the link between natural features, rural settlement patterns, and land use by which the full significance of rural historic resources and their settings must be evaluated.
c. Disingenuous Evaluation of Historic Integrity. It was OPRHP’s opinion that “setting is an important feature of the [Sir William Farm]”. Notably as well, the 1859 Niver Farmhouse occupation by Mohicans was an event to reclaim their ancestral homeland. By not recognizing the significance of setting, location, and feeling, TRC is failing to protect “the cultural values that centuries of land use and occupation have embodied in rural America.” (NRB, 1999).
d. Unfounded Project Effects Analysis. The TRC Report concludes: “If a historic property’s setting is less important to its significance that its architectural merit or historic qualities, then changes to setting may not adversely diminish the qualities or character-defining features… that support a historic property’s NRHP eligibility. Therefore, the undertaking would have no adverse effect on a historic property.” (p.21) The report methodology is unfounded and we strongly disagree with this statement.
Position 2: Hecate’s 5/20/2025 response to the ORES Notice of Incomplete Application(NOIA)in Exhibit 9 Cultural Resource v2 continues to ignore the terms of SHPO’s recommended Mitigation Plan detailed in their 5/15/2024 letter to ORES (specifically referenced in the NOIA by ORES. The Shepherd’s Run application should be deemed incomplete unless Hecate shows proof that they have consulted in good faith with local history-based groups to resolve adverse impacts and mitigation measures in accordance with SHPO’s terms.
In summary, SHPO’s letter outlines the proposed terms of acceptable Mitigation Measures: "In order to move the Project forward", they recommend that Hecate Energy develop a Mitigation Plan for the Project that "contains meaningful mitigation measures" to "offset what the office believes will be significant visual impact associated with this undertaking". SHPO proposes Hecate's outreach to "a variety of history-based organizations within the impacted communities. The plan should establish specific preservation/history projects and/or funding" and "once developed and agreed upon, include it in the final Cultural Resource Avoidance, Minimization, and Mitigation Plan (CRAMMP) submitted to the Office of Renewable Energy for review and approval...."
Hecate’s compliance with promised mitigation should be a condition of any Permit.
updated June 18, 2025