Which States Make It Hardest to Build Solar and Battery Projects? The 2026 Answer
Ask where it's hardest to build utility-scale solar in America and you get a different answer than you would for battery storage — and both answers have changed in the past eighteen months. For solar, no state hands opponents more formal power than Ohio, where state law gives county commissioners an outright veto over utility-scale projects. For batteries, it's New York, where nearly a hundred towns have passed moratoriums that the state's own fast-track siting office has no authority to override. And in Michigan, the entire question is before the state Supreme Court right now.
This ranking comes from two things: the county-by-county record in our Opposition Tracker — more than 125 source-linked restrictive actions across 34 states, updated weekly — and each state's siting law, which determines whether local opposition can actually stop a project or merely delay it. Volume of fights alone doesn't make a state hard to build in; power does. That distinction drives everything below.
The Quick Answer
- Hardest for solar: Ohio. Senate Bill 52 (2021) lets county commissioners block utility-scale solar and wind outright and designate "restricted areas" where projects can't even apply. More than two dozen counties have used it.
- Hardest for battery storage: New York. The state's siting office can override local rules for big generation projects — but not standalone batteries. Result: 98 municipal battery moratoriums, roughly two-thirds of the national total, each one binding.
- Most contested right now: Michigan. A 2023 law (PA 233) moved final siting authority to the state; the Court of Appeals largely upheld it in May 2026, and 79 townships and counties appealed to the Michigan Supreme Court on June 18. Until that resolves, both sides are building their cases township by township.
- Structurally easiest: Texas — counties generally lack zoning power over unincorporated land, so projects face market and political fights, not permit vetoes.
- Nationally, a USA TODAY analysis counted 755 counties — about a quarter of the country — with some impediment to new utility-scale wind or solar by the end of 2025.
How We Ranked This
Two inputs. First, structural power: what each state's law lets a county or town actually do — from Ohio's statutory veto at one pole to Texas's near-absence of county zoning at the other. That's verifiable public law, cited throughout. Second, tracked activity: the moratoriums, bans, rejections, and restrictions in our tracker, which logs actions from local news reports and government records, verified weekly, with records back to 2014 and systematic weekly coverage since early 2026. The tracker reflects what gets reported — a state absent from it isn't proven friendly, and raw counts alone don't decide this ranking. Where our counts sit against bigger one-time surveys — USA TODAY's 755-county analysis, the Moratorium Nation dataset's 222 moratoria across 30 states (through April 2026) — we say so. Current counts, updated weekly, live on our moratoriums-by-state page.
Tier 1: The County Veto — Ohio
Ohio is the only major solar market where a county board can simply say no. Senate Bill 52 gives commissioners the power to reject any utility-scale solar or wind application before state review begins, and to pre-emptively designate restricted areas where applications can't be filed at all. More than two dozen of Ohio's 88 counties have adopted restrictions, and the state power siting board has rejected projects — including an eighth utility-scale solar denial this summer — with county opposition cited as a deciding factor.
Our tracker records 13 restrictive actions across nine Ohio counties, the widest county spread of any state — mostly solar, exactly what SB 52's design predicts. The full record: Ohio tracker page.
Tier 2: Local Control That Bites — New York (Batteries), Kansas, Kentucky
New York looks like a paradox: an aggressive clean energy mandate, a state office built to fast-track projects — and the most restrictive actions in our tracker (16, more than half aimed at battery storage). The explanation is a gap in the law. The Office of Renewable Energy Siting can override local rules for renewable generation of 25 MW and up, and the 2024 RAPID Act extended its reach — but standalone battery storage remains outside its jurisdiction. A town moratorium on batteries is therefore binding, and towns have noticed: 98 New York municipalities had battery moratoriums by mid-2026 — about 65% of the national total — concentrated in the Hudson Valley, Capital Region, and Long Island, many following high-profile battery fires. Bills to close the gap (S5506/A8378) remain in committee.
Kansas and Kentucky follow the classic pattern: no state override, so county-by-county fights decide everything. Our tracker shows 7 actions across 5 Kansas counties and 5 across 3 Kentucky counties, with wind drawing the sharpest opposition in Kentucky.
Tier 3: The Pendulum States — Michigan, Illinois
Michigan passed PA 233 in 2023 to do what New York did for generation: give the state final say when local governments block projects. The backlash has been the fiercest in the country — our tracker's 14 Michigan actions are second only to New York — and the legal fight is live: the Court of Appeals largely upheld the law in May 2026 (striking two pieces of the implementing order), and 79 townships and counties appealed to the Michigan Supreme Court on June 18, 2026. If the law survives intact, Michigan becomes one of the easier states to site in; if it falls, one of the hardest overnight. No state's difficulty ranking is more contingent.
Illinois settled the same question in 2023 by capping how far county restrictions can go beyond state standards — counties still hold hearings and impose conditions (6 tracked actions across 5 counties), but outright bans are off the table.
Tier 4: Structurally Open — Texas
Texas counties generally cannot zone unincorporated land, which is where utility-scale projects go. There is no permit for a county to deny, so opposition works through other channels — tax-abatement fights, legislative proposals, and pressure on landowners — and projects keep getting built at national-record pace. The lesson Texas teaches is the inverse of Ohio's: siting difficulty is a legal artifact, not a measure of local sentiment. The sentiment exists everywhere; only some states arm it.
The Tracker Table: Most Restrictive Activity, 2026
| State | Tracked actions | Moratoriums/bans | Rejections | Counties | Main target |
|---|---|---|---|---|---|
| New York | 16 | 9 | 0 | 8 | Battery storage |
| Michigan | 14 | 3 | 3 | 6 | Solar |
| Ohio | 13 | 5 | 4 | 9 | Solar |
| Massachusetts | 8 | 0 | 2 | 3 | Battery storage |
| Kansas | 7 | 2 | 0 | 5 | Mixed |
| Illinois | 6 | 1 | 2 | 5 | Solar |
| Kentucky | 5 | 1 | 1 | 3 | Wind |
Counts as of late July 2026; the live table updates every Friday. Every underlying action links to its source on the state tracker pages.
Frequently Asked Questions
Which state is hardest to build utility-scale solar in?
Ohio, by structure: SB 52 gives county commissioners a formal veto over utility-scale solar and wind, and more than two dozen counties have adopted restrictions. Other states see as much opposition, but almost nowhere else does local government hold that much formal power over large solar projects.
Can a county or town legally ban solar farms or battery storage?
It depends entirely on the state. Ohio counties can ban utility-scale solar outright. New York towns can't stop large generation projects (the state can override them) but can block standalone battery storage. Michigan's state-override law is being tested at the state Supreme Court. Texas counties generally can't zone the land these projects use at all.
Which states can override local clean energy bans?
New York (for generation of 25 MW and up, via ORES under the RAPID Act), Michigan (under PA 233, upheld on appeal in May 2026 and now before the state Supreme Court), Illinois (which caps county restrictions at state standards), and California are the leading examples. In most other states, siting authority remains local, which is why county moratoriums concentrate there.
Sources: Ohio SB 52 (134th General Assembly); NY Office of Renewable Energy Siting and the RAPID Act; Michigan Court of Appeals, Almer Charter Township v. MPSC (May 2026) via Columbia Climate Law Blog and Foster Swift; Environment+Energy Leader (NY battery moratorium count); USA TODAY county analysis (2025); Moratorium Nation dataset (April 2026); CleanPowerDaily Opposition Tracker. Facts verified July 30, 2026. Free to cite with attribution and a link. Related: Do solar farms lower property values? · What is a moratorium?