While PV modules are not identified as hazardous waste at the federal level, they are regulated as hazardous waste in California—largely due to concentrations of cadmium and other toxic materials, and the potential that those materials might leach into the soil or water if not disposed of properly, according to Rick Braush, division chief for policy and program support with the CDTSC.
The problem with California’s stricter enforcement is that complex cradle-to-grave protocols and manifests must be completed by the end user of the PV module. At the residential level, as the current hazardous waste management scheme for PV modules stands, that means the homeowner must complete all the paperwork as the end user. To streamline the process, the CDTSC is in the process of adopting a new regulation that would relieve some of the bureaucratic burden and make it easier for the average homeowner to recycle PV modules.
“Our concern is that the complexity of the process will encourage clandestine and illegal dumping,” says Braush. “We are not so much concerned with the owners of large arrays, like utilities and large businesses, because they have the resources to handle these matters. We are more concerned with homeowners and smaller system owners. If they cannot dispose of the PV modules with ease, then we’re worried people will abandon them on the roadside or wherever, or they’ll end up tossing them in normal landfills where the materials could leach into our water and soil.”
In the absence of consistent state regulations to monitor solar manufacturing and end-of-life waste, SVTC created its Solar Scorecard to encourage greater accountability. According to Davis, survey response through the years has been lower than what would be expected of a green industry.
In August, the SVTC released its 2013 Solar Scorecard. Ten companies, representing 34.6% of the PV module market share, responded to the 2013 survey—a decline from 51.1% in 2012, due largely to the bankruptcy of several former participants and declining market shares of the remaining participants.
For the second year in a row, Trina Solar captured the scorecard’s top spot for its environmental and social performance (see “Solar Scorecard Highlights”). Trina bumped SolarWorld from its No. 1 spot in 2012—the two have been vocal adversaries in the U.S.-China trade dispute in recent years. “The fact that two Chinese firms topped the list this year may motivate U.S. manufacturers to do better,” Davis says.
Davis does, however, point out that Trina and Yingli are the exception among Chinese companies. “We’re glad that they’re participating and exhibiting a strong commitment to their environmental and labor practices, but most of their Chinese counterparts are at the bottom of the list because they did not respond to the survey and do not publicly share information about what they’re doing,” Davis says. “Moving forward, we want to push the bottom-dwellers to respond to the survey and take responsibility for their practices. At this point, every solar manufacturer should have a chemical reduction plan and a take-back program in place.
“Overall, the industry seems to be making strides in the right direction, and taking a different path than the microcomputer and electronics industries, which did not put enough thought into the manufacturing and disposal of their products, and ultimately created a global e-waste problem,” says Davis, who fears that solar companies are becoming so pressed by competition that they are going to start cutting corners. “It could become a competitive disadvantage to be green,” she says.
Additionally, Davis would like to see more support from the Solar Energy Industries Association in pushing its members to be more transparent. “This industry needs strong leadership to stay on the right course. Too many solar manufacturers are still unwilling to share their practices publicly, and that’s not okay for any company in any industry,” she says. “If they’re truly as green as they claim to be, then a solar company should have no problem reporting their health, safety, and sustainability metrics on their websites and within annual reports.”
How Does PV Compare to Fossil Fuels?
According to the U.S. Energy Information Administration, nuclear, hydro, wind, and solar sources met 18% of total U.S. energy consumption, yet produced none of the country’s energy-production-related carbon dioxide emissions. Conversely, coal accounted for 20% of the energy consumption, with 34% of the emissions; petroleum provided 36% of the energy consumption, with 42% of the emissions; and natural gas provided 26% of the energy consumed, with 24% of the emissions.
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