[Massplanners] FW: Sharing NREL link for BEST PRACTICES Solar Decommissioning BONDS

[Tim Czerwienski]

See below from the former chair of Charlton’s Solar Committee



Tim Czerwienski, AICP
Director of Planning & Community Development
Town of Milton | 525 Canton Avenue | Milton, Mass. 02186 | 617-898-4847


From: pldegnan at charter.net<mailto:pldegnan at charter.net> <pldegnan at charter.net<mailto:pldegnan at charter.net>>
Sent: Tuesday, March 21, 2023 12:29 PM
To: 'massplanners at masscptc.org' <massplanners at masscptc.org<mailto:massplanners at masscptc.org>>; 'PlDegnan at charter.net' <PlDegnan at charter.net<mailto:PlDegnan at charter.net>>
Subject: Sharing NREL link for BEST PRACTICES Solar Decommissioning BONDS
To Who It May Concern,
I am a volunteer and former chairperson for the Town of Charlton's Solar Committee who has been working with boards and members of other Massachusetts towns navigating large scale solar and battery storage parks. We have been sharing our information and experiences and fact checking the vast amount of "green" information provided by the developers.
Towns have been lacking guidance on coexisting and regulating this new industry. Mass Laws have been vague and towns need to be proactive in establishing proper solar projects decommissioning bonds.
I urge all Planning Boards to read this "BEST PRACTICES AT END OF PHOTOVOLTAIC SYSTEM PERFORMANCE PERIOD" written by the National Renewable Energy Lab on behalf of the Environmental Protection Agency. https://www.nrel.gov/docs/fy21osti/78678.pdf
The reason consulting engineers have continuously approved the low decommissioning bonds is that the state if Massachusetts lacks any firm guidance as to the handling solar panel waste. The DEP does not list solar panels on its 2030 or 2050 Solid Waste Master Plan. It is politically a hands off topic hence anyone be seen as anti- green. There are changing hazardous chemicals like cadmium and gallium arsenide contained in the glass sandwiches of the solar panels as well as lead (racking) and PFAS (on glass coatings). Waste Management Company has stated they consider panels hazardous and local transfer stations refuse panels in trash. Recycling is costly and many countries are refusing used panel imports fearing they will be the next electronic waste problem of the world!
The state does allow towns to set reasonable regulations when it comes to living with this relatively new industry. Setting bond amounts in part cash and part line of credit, will provide financial security to protect the landowner, residents and towns health and safety. These companies change ownership frequently and create difficulty for town employees to validate protection. Bankruptcy, oversights and technological advancements pose risks towns need to prepare for.
I urge everyone to follow $400,000 per MW DC formula (with no scrap or recycling credits allowed due to fluctuating commodity metal markets) with 25% cash up front in an escrow account following the parcel (to hire legal representation and to enforce bond) and the remaining 75% in a line of credit from an FDIC lending institution. This is only to be used in the event that the project neglects to follow its own decommissioning plan.
Sincerely,
H. Laurie Degnan
Former chairperson solar committee of Town of Charlton

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