The responsibility for ensuring that threatened or endangered animal species will not be harmed by a proposed solar facility rests with the solar developers, not the Virginia Department of Environmental Quality (DEQ). This is because large-scale solar projects (of up to 150 MW) were deemed by the Virginia General Assembly in 2020 to be “in the public interest” and therefore subject to streamlined Permit By Rule (PBR) procedures which allow developers to be the ones who assess the environmental impact of their projects.
However, it is easy to search the U.S. Fish & Wildlife Service’s Environmental Conservation Online System to determine which species are considered endangered or threatened in each of Virginia’s counties.
To do this, go to the Environmental Conservation Online System website. Under Additional Search Tools, begin typing in the name of the county, then click on the full name in the drop-down list.
This will generate a list of species that are endangered, threatened, or of concern. Using Shenandoah County as an example, there are two bat species listed as Endangered: the Virginia big-eared bat and the Indiana bat.
Click on the highlighted Latin scientific name of the species to access the critical habitat map and see the exact area where the species is located. Here’s the critical habitat map for the endangered Indiana bat (green areas are its known locations).
These maps are always worth checking during research into any proposal for an industrial-level solar facility in Virginia.
The Project will coordinate the collection and recycling of the PV modules [i.e., solar panels] and for minimizing the potential for modules to be discarded. If there is no possibility for reuse, PV panels will either be returned to the manufacturer for appropriate recycling/disposal or will be transported to a recycling facility where the glass, metal and semiconductor will be recycled. Best management practices at the time of decommissioning shall be utilized.
Louisa County, Board of Supervisors minutes, oct 2016, belcher solar llc application, packet p 153
The disposal of the actual solar panels (called “PV modules” in solar developer terminology) is the biggest challenge of all in closing a solar plant. Each panel measures roughly 3′ x 5′ and weighs about 40 pounds (see Energy Sage’s Average Solar Panel Size and Weight for more details). The documentation for the solar project in this example says that the panels will be “returned to the manufacturer” or recycled. But what happens if the manufacturers (roughly 90 percent of whom are in China) refuse to accept the return of used and obsolete solar panels? Who pays the cost of returning them to China or other locations? And if the panels cannot be returned and recycling of obsolete panels is not feasible, what happens to the panels? If any of these happen, it is logical to assume that the panels will end up in a landfill. The question is, whose landfill will get them?
Potential questions:
- Given that 90% of all solar panels are manufactured in China, how does the project developer propose to ship them “back to the manufacturer”?
- What will happen if the Chinese company that made them is no longer in operation or if China is no longer accepting old and out-of-date solar panels from other countries?
- How many solar panels are currently recycled in the United States each year, according to the most recent data? What percentage of all solar panels in the country does that constitute?
- Where are the hard numbers showing that recycling of old solar panels is cost effective for recyclers?
- What is the industry’s best estimate of how many solar panels will need to be recycled 20 years from now from Virginia alone?
- What is meant by “best management practices at the time of decommissioning?” Please be specific.
- If there is a glut of old solar panels on the market 20 years from now, with few or no recycling options available, where are the panels in this project likely to end up? Please be specific.
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Decommissioning consists of the removal of above- and below-ground facility components, management of excess wastes and materials, and the restoration of native habitat. (…)
[P]reparatory measures may be required including, but not limited to, (…) as-needed vegetation clearing, fencing and gate repair, and removal and disposal of materials generated from the above-listed activities. (…)
After the facility has been disconnected from the utility power grid and all electrical components have been disconnected within the facility, equipment will be dismantled and removed. (…) All above ground cables will be removed and transported off-site to an approved recycling facility or landfill. Underground cable runs will be cut off and will either remain in place, or be removed and recycled or taken to a landfill. All underground cable left in place will be cut off at a minimum depth of three feet below ground surface. (…)
Should a structure break during excavation, any portion below 3 feet in depth will remain in place with the exception of any concrete foundations. (…)
louisa county, board of supervisors minutes, oct 2016, belcher solar llc, packet pp 152-153
This decommissioning agreement is similar to most others in that it allows the solar developer to leave behind cables and other materials if they are more than 3 feet below the surface (with the exception of concrete foundations). However, earlier in this project’s documentation (packet p. 149), the developer stated that the solar panels are installed on steel racking structures whose posts are “driven 5-6 feet into the ground using a post-driving machine.” In addition, while the removal of materials is delegated to a contractor, no specifications are included about who will supervise and ensure that the removal is completed correctly, with minimal breakage.
Potential questions:
- Will the “excess wastes and materials” be sent to a landfill within the county or will they go somewhere else? Who is responsible for supervising this?
- What percentage of materials, in the estimation of experts, will remain in the ground because they are more than 3 feet below the surface?
- Who is responsible for supervising the decommissioning to ensure that there is as little breakage as possible and that no materials are left underground? Will this be a local government responsibility or the responsibility of the project owner?
- Where are the solar recycling facilities to which the materials will be sent? Are they in Virginia or elsewhere?
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