June 30, 2021
The path to creating a solar recycling program in Minnesota
In 2020, Minnesota generated 29% of its electricity from renewable sources, and 3.1% from solar. With all these solar panels, questions have arisen about how those projects will be treated at the end of their life. How do you create a good program to recycle solar panels?
In addition to its positive impacts on energy security and climate change, PV technology is also among the most environmentally friendly technologies of all energy and electricity generation technologies, particularly when evaluated from a life-cycle viewpoint, including end-of-life management. This means that proper end-of-life management is an indispensable issue for “clean” energy technologies. – International Renewable Energy Agency
The Minnesota Pollution Control Agency (MPCA) is seeking to answer that question through a stakeholder process. This all started about 5 years ago, when Amanda Cotton, the MPCA’s Electronic Waste Program Coordinator, started to get questions about solar panels. Recognizing that this would be a larger issue in the future, the MPCA decided to get in front of it by starting a stakeholder process to determine the best recycling option.
MPCA conducts stakeholder meetings
The MPCA conducted a series of stakeholder meetings over the past few years, educating key stakeholders on the available recycling program models and learning what criteria are most important to each group. These stakeholders included solar developers, the Minnesota and national Solar Electric Industry Association, local governments, the Association of Minnesota Counties, the MN Department of Commerce, solar manufacturers and recyclers, and residents.
Stakeholders learned about solar panel recycling models operating around the world. The European Union has a panel takeback and recycling requirement under the Waste Electronics Directive, with programs administered by PV Cycle in each country. In the United States, there is only one example: Washington enacted the only solar panel recycling product stewardship law in 2018, with implementation now delayed to 2025. Two states passed laws requiring studies of the issues; North Carolina deferred decisions for 10 years, and New Jersey has not completed their study. Minnesota has an opportunity to be a leader by developing a stakeholder-approved solar recycling program.
Consensus from stakeholders is that Minnesota needs a statewide collection and recycling program for solar panels. Currently there are some e-waste recyclers who will take solar panels, such as Cascade Eco Materials in Missouri, but Minnesota does not have a program designed to help residents and companies know what to do with the panels. Minnesota already has more than 1.3 GW of solar installed, so there will be a large amount of material when these panels reach the end-of-life. Not only is it important to keep the material out of landfills, but there are valuable materials within solar panels that can be recovered, such as the metals and silicon.
Managing end-of-life PV modules to recover valuable materials that can displace virgin ones is an important step toward meeting the challenge of sustainability. – International Energy Agency
Four program models emerge
In December, stakeholders voted on four program models:
1. Expanding the utility-scale decommissioning program, currently run through the MN Department of Commerce, to all non-residential solar installations. Each developer would be individually responsible for planning and financing the decommissioning of their facilities at the end of the permit term, properly removing and managing all of the solar equipment that was on the site and restoring the site to its original condition.
2. Establishing a manufacturer product stewardship or extended producer responsibility framework in Minnesota state law. Under this policy option, solar panel manufacturers would be responsible for the end-of-life collection and management of panels installed in Minnesota, including panels in residential installations. Manufacturers typically create or contract with a stewardship organization that administers and operates the program. The program costs can be included in the initial price of the panels, or the program can be financed through a stewardship fee paid at the time the panel is purchased for installation in Minnesota. This program could be structured to include all panels currently installed in Minnesota or only panels installed after the program goes into effect.
Minnesota requires other manufacturers to operate and/or finance a variety of product stewardship programs to recycle other materials and keep them out of landfills, for products like e-waste, paint, and rechargeable batteries. A program for PV panels could differ from these current programs, due to the long life of solar panels and facility permits, which can be up to 30 years.
3 & 4. Establishing a state-wide program model, either paid by electric utility ratepayers or solar developers. In these model options, the State would administer one central program to collect and manage solar panels. One option would be financed by all electric utility ratepayers as part of their electric bill paid each month; this option could easily cover the recycling of residential solar installations as well as commercial. The other statewide program option would be financed by commercial solar installation “permittees”, either the solar developer or the business owning the solar array.
The funding of the program remains a big and important question. Stakeholders want to ensure that the program is designed in a way to ensure an equitable distribution of costs across participants in the industry. Local governments in particular want to ensure that taxpayers are not responsible to pay to recycle local solar projects at their end-of-life. The least-preferred option among stakeholders was the ratepayer-funded model, though there was not a clear consensus among the other three options. The program also needs to be designed to cover all types of solar installations, whether utility-scale or small-scale. Of Minnesota’s 1.3 GW of solar, 70 MW are residential installations and 60 MW are small-scale commercial installations. The structure of the funding will determine how easily each type of installation could be recycled.
The MPCA is currently sharing the results of their survey with key stakeholders to determine the best model option and develop a detailed proposal and rationale. They are also looking to gain stakeholder support for legislation to create the solar panel recycling program. The draft proposal will be ready this summer, with the goal of introducing a bill in the next Legislative session.
This blog was written in collaboration with the Minnesota Pollution Contol Agency.