HomeMy WebLinkAboutPC Packet 08.23.18AGENDA
HUGO PLANNING COMMISSION
THURSDAY, AUGUST 23, 2018
HUGO CITY HALL
7:00 p.m.
A. ROLL CALL (Arcand, Derr, Fry, Kleissler, Lessard, Luchsinger, Tjernlund)
B. PLEDGE OF ALLEGIANCE
C. APPROVAL OF MINUTES
1. August 9, 2018
D. PUBLIC HEARING
E. NEW BUSINESS
F. OLD BUSINESS
1. FastSun 4, LLC. — Interim Use Permit (IUP) Application for a Solar Farm
G. ADJOURNMENT
If you need accommodations for the Planning Commission meeting please contact
Rachel Juba at (651) 762-6304 or riuba(&ci.hugo.mn.us, thank you.
Minutes for the Planning Commission Meeting of Thursday, August 9, 2018
Chair Kleissler called the meeting to order at 7:00 p.m.
PRESENT: Arcand, Derr, Kleissler, Lessard, Tjernlund
ABSENT: Luchsinger
STAFF: Rachel Juba, Community Development Director
Pierre Giguere, Community Development Intern
Approval of Minutes for the Planning Commission Meeting of July, 26, 2018
Commissioner Arcand made a motion, seconded by Commissioner Derr, to approve minutes for the meeting of
July 26, 2018.
All Ayes. Motion carried.
Tabling of FastSun 4, LLC. — Interim Use Permit (IUP) Application for a Solar Farm
Juba reviews the tabling of the FastSun 4 LLC Solar Farm IUP application. Juba states that the application was
tabled by the Planning Commission at their July, 26, 2018 meeting. The applicant did not provide the
information requested by the Planning Commission in time for staff to review the application. Staff
recommended that the application be tabled again until the Planning Commission meeting of Thursday, August
23, 2018.
Commissioner Arcand makes a motion, seconded by Commissioner Tjernlund, to table the FastSun 4 LLC
Solar Farm IUP application until the next Planning Commission meeting on Thursday, August 23, 2018.
All Ayes. Motion Carried.
Juba mentions that if the applicant chooses not to submit requested information prior to the Planning
Commission meeting of Thursday, August 23, 2018, it could be tables again. If the application is tabled again,
Juba states that nearby residents and the Planning Commission will be notified.
Conditional Use Permit (CUP) for Scott Kersten at 15587 Forest Boulevard
Juba introduces the CUP of Scott Kersten at 15587 Forest Boulevard. The CUP will be used for an automotive
sale and repair business. The applicant has applied for a CUP in order to perform auto sales, auto body repair,
and outside vehicle storage with the property. These uses are permitted within the General Business District (C-
2) with approval of a CUP. Juba states that the applicant is currently operating their business within Hugo at
two different locations. The applicant would like to consolidate to a single location.
Chair Kleissler gave the applicant the opportunity to address the Planning Commission.
Scott Kersten of 16332 Harrow Avenue North, approached the podium. Kersten states that he is focusing on
bringing his business to one location instead of constantly moving between two different locations.
Commissioner Arcand asks Kersten what he will do with the two properties once his business is relocated.
Kersten states that he is not certain but he will most likely sell the properties.
Planning Commission
August 9, 2018
Page 2
Chair Kleissler opens the public hearing at 7:14 p.m.
Gloria Borowski of 15488 Goodview Trail North approaches the podium. Borowski's states that her property is
in close proximity to the incoming business and is concerned about operating hours of the business and whether
or not there will be fencing around the property, providing a buffer. She states that Juba's presentation answered
her questions.
Commissioner Tjernlund states that although the previous business located at the property performed a lot of
paintwork and sandblasting, the incoming business will not follow the same manufacturing practices.
Chair Kleissler closes the public hearing at 7:16 p.m.
Commissioner Derr states that the 15587 Forest Boulevard has been empty for some time and the new
automotive sale and repair business would be good for the property.
Chair Kleissler agrees with Commissioner Derr.
Tjernlund makes a motion, seconded by Lessard, to approve the CUP.
All Ayes. Motion Carried.
Juba states that the application will be moved to the City Council meeting of Monday, August 20, and will be
placed on the consent agenda.
New Business
Juba provided a description of the recent interviews for a new Planning Commissioner. David Fry has been
selected as the newest member of the Hugo Planning Commission. Juba also states that the City Council
authorized staff to review and possibly revise ordnances and bylaws for each commission to allow an alternate
commission member to fill in for absent commission members.
Adiournment
Commissioner Arcand made a motion, Commissioner Tjernlund seconded, to adjourn at 7:19 p.m.
All Ayes. Motion carried.
Respectfully Submitted,
Pierre Giguere
Agenda Number F.1
CITY OF HUGO COMMUNITY DEVELOPMENT
DEPARTMENT
PLANNING AND ZONING APPLICATION
STAFF REPORT
TO: Planning Commission
FROM: Rachel Juba, Community Development Director
SUBJECT: FastSun 4, LLC. Interim Use Permit for a Solar Farm located north of
165th Street North and west of Henna Avenue North.
DATE: August 17, 2018 for the Planning Commission Meeting of August 23,
2018
ZONING: Future Urban Service (FUS)
LAND USE: Low Density Residential (LD)
REVIEW DEADLINE: October 4, 2018 (120 -days)
1. PLANNING COMMISSION MEETING THURSDAY, JULY 26,2018:
At its meeting on Thursday, July 26, 2018, the Planning Commission held a public hearing and
considered the applicants request. There were nine people that spoke during the public hearing,
including the applicants representative.
There were comments and concerns that were made from several of the residents. Following
describes the comments and concerns:
1. Concerns from a resident about wind ratings of the solar panels and them blowing on to
other properties during a severe storm event.
a. The applicant stated that the panels would be designed and installed per building
code requirements.
2. Concerns that the property would become a dumping ground and a suggestion of a gate at
the main entrance was stated.
a. The applicant stated that the plans would be revised to include a gate.
3. Statements were made that solar farm would depreciate the value of the surrounding
property.
a. The applicant stated that in another City they conducted a study that found that the
solar farm did not impact the surrounding property values, either up or down.
4. One resident stated they had concern about the wildlife in the area.
a. The applicant stated that they will seed with native plants within the solar areas and
that the panels will not harm birds or other wildlife.
5. Concerns that the solar farm did not fit in with the character of the area.
FastSun 4, LLC. Solar Farm IUP
Page 2
6. Many residents stated they did not want to see the solar farm.
7. Many residents stated that the landscaping should surround the solar farm for screening
purposes. The tress should be in a mature state, not small trees.
8. Concerns that there were hazardous material within the panels that would harm the ground
water.
The Planning Commission wanted to see revisions to the plans and also wanted to review
additional information regarding the solar farm. The Planning Commission tabled the request. The
Planning Commission requested the following revisions and information:
1. Revise plans to show landscaping on all sides of the solar farm and the landscaping shall
consist of coniferous (evergreen) trees.
2. A maintenance agreement shall be provided for the landscaping to ensure if it dies it will
be replaced by the applicant.
3. Revise the plan to include a gate on 165th Street at the driveway entrance.
4. Revise the NP to review the permit every 5 years.
5. An insurance policy shall be in place for the solar farm.
6. Provide the design of the panels (specifications)
7. Provide information that the panels are not hazardous.
8. Provide information on the stormwater management for the site.
The applicant has provided a revised landscape plan with 6 to 8 feet tall Black Hills Spruce and
Red Cedar trees. It is not recommended that the applicant put landscaping within the wetland areas.
Staff recommends that the plan be revised to add trees along the entire south property line, where
the wetlands are not shows. Staff recommends that the applicant show staggered, two row,
landscaping with a combination of the Black Hills Spruce and Red Cedar. Staff will continue to
work with the applicant on the landscape plan. The applicant added a gate to 165th Street at the
entrance into the site.
The applicant provided additional information on the solar panels and a report on health and safety
impacts of solar panels. Further, a solar farm does not require a hazardous waste generators license.
The applicant has stated that there will not be any batteries for the solar panels or components.
Staff updated the IUP to include the following:
1. Review every five years.
2. The applicant shall provide:
a. An issurance policy.
b. A stormwater management plan to be reviewed and approved by City staff.
c. A landscape maintenance agreement shall be reviewed and approved by staff.
d. A cash escrow per the grand total amount for decommissioning and site restoration
estimate.
It is in staff's opinion that the applicant has provided the items requested by the Planning
Commission.
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FastSun 4, LLC. Solar Farm IUP
Page 3
2. DESCRIPTION OF REQUEST:
The applicant is requesting approval of an interim use permit for a solar farm located north of 165a'
Street North and west of Henna Avenue North.
3. BACKGROUND:
On January 4, 2016 the City Council adopted an ordinance regulating the use of solar energy
systems. This ordinance was created through the City's Ordinance Review Committee and went
through the process of approval for an ordinance, including publication/notice, a public hearing at
the Planning Commission, and City Council approval.
The vacant property is 30 acres and is located within the Future Urban Service zoning district. The
applicant has stated that they will be leasing the western 19.8 acres of the property. The applicant
is proposing to install a solar farm consisting of approximately 5 acres of used land in the northwest
corner for the use of a solar energy system and installation of solar panels. This request requires
approval of an interim use permit (IUP).
The applicant has indicated that this solar farm will produce approximately one (1) megawatt
(MW) of power. Although solar capacity is dependent on average sunshine, average household
electricity consumption, and temperature and wind; one megawatt of solar capacity can power
approximately 164 homes on average. The applicant has stated that Xcel Energy will be
purchasing the power generated by the panels to assist them in meeting the State's mandate for use
of renewable energy. The applicant has also indicated that Xcel customers may be able to
subscribe to a share of the electrical output from the project, as well. Because Xcel is the only
utility currently offering incentives for solar energy systems, the project will only be within Xcel's
territory. The line between Xcel and Conexus territory intersects this property, which is why the
applicant is renting only the western 19.8 acres of the 30 acre property.
4. LEVEL OF CITY DISCRETION IN DECISION-MAKING:
The City's discretion in approving or denying an Interim Use Permit use permit is limited to
whether or not the permit meets the standards outlined in the Comprehensive Land Use
Regulations. If it meets these standards, the City must approve the interim use permit.
5. CONTEXT:
A. Surrounding Land Use and Zoning
The property is currently zoned Future Urban Service (FUS) and guided for Low Density
Residential (LD) in the 2030 Land Use Plan. Currently, the surrounding properties are generally
large acreages occupied by single family homes with agricultural uses occurring on the remaining
land. This property is within the Municipal Sewer Service Area (MUSA), however is right on the
border with the properties to the south guided as Agricultural (outside of the service area) and
properties to the north guided as Low Density Residential (inside of the service area).
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FastSun 4, LLC. Solar Farm IUP
Page 4
B. Natural Characteristics of Site
The property is approximately 30 acres, however the applicant has indicated they will be leasing
the western 19.8 acres of the property and are proposing to install a solar farm on 5 acres in the
northwest corner of the property. The property is relatively flat and has been historically used for
row crops.
Wetlands make up a large majority of this property and occupy 13.3 acres of the 19.8 acre leased
area. There are 16.3 acres of wetlands on the entire 30 acre property. The applicant has completed
and received approval of a wetland delineation of the entire 30 acre site from the Technical
Evaluation Panel (TEP). They are currently in the process of receiving approval on their wetland
replacement application. It shall be a condition of approval that the applicant receives all approvals
necessary from the TEP as well as abides by any conditions the TEP recommends in their Notice
of Decision (NOD).
6. ANALYSIS OF A SOLAR FARM INTERIM USE PERMIT:
The zoning code outlines a number of general standards for the operation of all solar energy
systems, whether it's a solar farm or accessory solar energy system. These include the requirement
for a building permit, evidence of an agreement with the local utility, responsibility of the applicant
to secure any solar energy easements, all solar energy components labeled in accordance with City
code, all exterior electrical or service lines be buried, and all solar energy systems be in compliance
with adopted city and state building codes. In addition to the general standards for all solar energy
systems, there are performance standards for solar farms, which are described below:
(a) Solar farms shall be located on a minimum lot size of ten acres within the Long Term
Agricultural (LA), Agricultural (AG), Rural Residential (RR), and Future Urban Service (FUS)
zoning districts. Solar farms may also be located in any other zoning district only in the
floodplain, as long as all other conditions are met.
The applicant is proposing to lease 19.8 acres of a 30 acre parcel located in the Future Urban
Service zoning district.
(b) Solar farms shall be 50 feet from all property lines and public road rights-of-way.
The applicant has proposed a fence surrounding the solar farm to be located on the 50 foot setback
line from the north and west property line. The fence is approximately 650 feet from the east
property line and 350 feet from the right-of-way on 165th Street to the south. The actual solar
panels would be setback approximately 15 feet from the fenced area.
(c) Ground mounted solar energy systems shall not exceed 15 feet in height at any point when
oriented at maximum tilt.
The applicant has indicated that the solar energy system will be approximately 12 feet tall. The
applicant has stated that the solar energy panels will be one of two systems: A single -axis tracker,
that tilts up and down to follow the sun during the year, but not during the day or a fixed tilt system
4
FastSun 4, LLC. Solar Farm IUP
Page 5
that faces south and does not move. The panels will be mounted on a steel and aluminum racking
structure and installed with pilings that are driven approximately 6-8 feet in the ground. The
applicant has indicated that the panels will visually look to be at the same height, therefore, may
be driven into the ground at different depths. The TEP has also recommended that the system
should be as close to the City's 15 foot maximum height allowance as possible to allow for more
natural conditions (sunlight, rain, wind) for vegetative growth within the wetland areas. Because
of this condition, the City would expect the height of the system to be approximately 15 feet from
the grade of the ground.
(d) Solar farms shall be enclosed by approved perimeter fencing or adequate vegetative buffer for
screening. Exception may be granted if the natural landscape provides screening from all public
right of ways and neighboring properties.
The applicant has indicated that they will be installing a 6 -foot galvanized chain link perimeter
fence for safety and security. This type of fence will not provide any screening, therefore, the
applicant has submitted a landscape plan.
The intent of the landscaping portion of the solar energy system section of the code is to provide
a buffer between surrounding properties and a solar farm. The applicant has shown the installation
of 134 Black Hills Spruce and Red Cedar trees along most property lines. The applicant has stated
that there are existing trees that screen the solar farm to the north and the existing vegetation and
large setback from the east property line meet the intent of the ordinance. City staff agrees that
some of the areas have an adequate buffer with the existing landscape and setback. The TEP has
also made it a requirement that plantings selected for installation within the wetlands must be
native in Minnesota. Staff will continue to work with the applicant on the landscape plan.
All landscaping will be required to meet section 90-181 — Landscaping. in regards to sizes of
plantings and minimum installation requirements.
(e) The owner/ operator of the solar farm shall provide the city with evidence that the solar energy
system is functioning properly. This shall be provided at any time deemed necessary by the city.
The applicant has provided the City with an operation and maintenance plan. This plan states that
the system will have real-time monitoring using the facility's meteorological station, energy meter,
and SCADA system. Within this plan it also indicates that there will be routine maintenance of
the facility including road maintenance, fence and gate inspection, and lighting system checks. It
shall be noted within the IUP that the owner/operator of the solar farm shall provide the City with
evidence that the system is functioning properly at any time deemed necessary by the City.
()9 The owner/operator shall submit a decommissioning plan for the solar farm to ensure that the
owner/operator properly removes the equipment and facilities upon the end of the project life,
abandonment, expiration, or termination of the interim use permit. This decommissioning plan
must meet requirements outlined in the City code.
The applicant has provided the City with a decommissioning plan for the solar farm. The City's
ordinance states that the owner/operator of the solar farm shall provide a current -day
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FastSun 4, LLC. Solar Farm IUP
Page 6
decommissioning cost estimate and shall post financial security in a form acceptable by the city.
The City is requiring the owner operator to submit this required information as well as a cash
escrow prior to the issuance of a building permit. The applicant's decommissioning plan meets
City requirements outlined in the code, including the removal of all equipment and structures
within 90 days after the system has been inoperative for 12 months as well as the restoration of the
site. The decommissioning plan requirements will be noted in the applicant's IUP.
7. CRITERIA FOR APPROVAL OF A SOLAR FARM INTERIM USE PERMIT:
An application for a home occupation interim use permit may only be granted upon a finding that
all the following criteria have been met:
(a) The applicant owns the property or has secured a proper lease agreement on the property,
unless the city council determines that unique conditions or circumstances warrant special
arrangement.
The applicant has a lease agreement with the property owner of the property in question.
(b) The proposed solar farm is allowed as a principle use in the respective zoning district and
conforms to this chapter.
The proposed solar farm is an allowed permitted use within the Future Urban Service (FUS) zoning
district.
(c) The proposed solar farm is keeping with the spirit and intent of this chapter.
The spirit and intent of the ordinance is to allow for the generation of renewable energy within the
City of Hugo. Promoting the safe, effective, and efficient use of solar energy, may reduce the
onsite consumption of fossil fuels and utility -supplied electric energy while avoiding adverse
impacts on the community at large. The applicant's proposed solar farm meets the purpose,
permitted uses, and performance standards outlined in the City code.
It's in staff's opinion that the request for an IUP for a solar farm meets the spirit and intent of the
ordinance.
(d) The construction of a solar farm shall not impede the city's ability to implement its
comprehensive plan.
The intent of the FUS zoning district is to promote the preservation of large parcels that are eligible
for city services/utilities. In this particular area, it is unlikely that city services will be extended in
the near future. At the time of development, it is likely that this property will be developed along
with the surrounding area and the City's Comprehensive Plan will be evaluated with the request
at that time.
(e) The proposed solar farm is compatible with the present character of the surrounding area.
C1
FastSun 4, LLC. Solar Farm IUP
Page 7
As stated previously, the intent of the FUS zoning district is to promote the preservation of large
parcels that are eligible for city services. Because of this, this area is generally treated as a
rural/agricultural area of the City. Many of the uses in this zoning district are single family homes
with the remaining land used for agricultural activities. These uses generally translate into having
a low impact on adjacent properties with limited noise, traffic, etc. The applicant has indicated
that there will be routine maintenance on the property, which will generally consist of a truck using
the access drive at various times and will not be intrusive. The applicant has also indicated that
the solar farm will not generate any carbon or other harmful emissions and will not create any
noise, dust, fumes, or glare.
It's in staff's opinion that the request for an IUP for a solar farm will not adversely affect the
surrounding area and is compatible with the character of the surrounding area.
()9 The proposed solar farm shall have a set date in which the permit shall be reviewed or
terminated.
The applicant has requested the permit to be approved for a period of 25 years, which is the life of
the applicant's agreement with Xcel Energy in purchasing the power generated by the solar farm.
City staff is comfortable with approving the IUP for a 25 year period from the date of the issuance
of the final building permit with the allowance, required by City code, that the owner/operator of
the solar farm provide the City with evidence that the solar energy system is functioning properly
at any time deemed necessary by the City. The solar farm shall be reviewed every five (5) years.
(g) The proposed solar farm shall be subject to any conditions that the city council deems
appropriate for the permission of the use.
City staff have reviewed the application for a solar farm interim use permit and have outlined
conditions of the permit within the ICTP document. City staff can update the permit with any
conditions deemed necessary for this use.
8. CONCLUSION/RECOMMENDATION:
In conclusion, staff have discussed the solar farm at length with the applicant and believes the
applicant has generally done a good job planning the site and has abided by all City standards for
a solar energy system outlined in the City code. It is in staff's opinion that the requested for a solar
farm IUP is reasonable.
Staff recommends approval of the solar farm interim use permit application with the conditions
listed in the attached resolution.
ATTACHMENTS:
1. Site Map
2. Applicant's Narrative
3. Site Plan/Landscape Plan
4. Applicant's Decommissioning Plan and Cost Estimate
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FastSun 4, LLC. Solar Farm IUP
Page 8
5. Resolution
6. Solar Farm Interim Use Permit (red -lined with revisions)
7. Applicants stormwater management memo dated August 16,2018
8. City Engineers memo dated August 17, 2018
9. Solar Panel Specifications
10. Health and Safety Impact Report Provided by Applicant
--=
NI
FastSun
June 8, 2018
City Council
City of Hugo
Re: Interim Use Permit Application to Develop a Community Solar Garden
Dear Members of the Staff, Planning Commission and City Council:
FastSun, LLC, is pleased to present this application to the City of Hugo to develop and
operate a community solar garden.
This 1 megawatt array of photovoltaic panels will generate electricity that will be
purchased by Xcel Energy under a 25 -year contract.
The solar garden will not generate any carbon or other harmful emissions, will be created
from an inexhaustible source, the sun, will help Xcel Energy meet the State's mandate for
use of renewable energy sources, and will align with the City's goals for sustainability. In
addition, Xcel customers may subscribe to a share of the electrical output from the project,
thus supporting this clean source of energy.
It is important to us to be a good corporate citizen and work cooperatively with each local
community. This helps us respond to any concerns with conditions that create a
successful energy development while supporting the City's community development
objectives.
Please give our application your approval so that we can all benefit from this wise new
source of electricity for our homes and businesses.
Sincerely,
�Z
Dean Leischow
Chief Executive Officer
315 Manitoba Avenue, Suite 200, Wayzata, MN 55391
Project Description
Site Location
The community solar garden is proposed to be located on a parcel along the north side of 165'h
Street northeast of the intersection of 165th and Harrow Harrow Avenue, as shown by
Figure 1.
Property Description
The property identification number is 100-3121-23-0003. Figure 1 shows the parcel
boundaries according to Washington County.
The property owners are Henry J. and Linda M. Gregoire.
The property legal description is:
PT Si/2-NWI/4 BEING THE W 30 A OF SDI/2 1/4 SECTION 10 TOWNSHIP 031 RANGE 021
165th Ave.
Figure 1:
Location and Parcel Map
315 Manitoba Avenue, Suite 200, Wayzata, MN 55391
Site Zoning
The site is zoned Long -Term Agriculture.
Lang -Term
-1Aoriculture
Figure 2: Site Zoning
On -Site and Nearby Land Use
The site is presently used for row crops. Nearby land use include agriculture and large -lot
semi -rural housing.
Vegetation
The existing vegetation consists of row crops and wetland vegetation.
Floodplain
There is no floodplain mapped on the site by the Federal Emergency Management
Administration.
Site Plan
The site development plan for the community solar garden is shown by Figure 5.
315 Manitoba Avenue, Suite 200, Wayzata, MN 55391
Setbacks
The site development, including the security fence, will conform to the City's setback
requirements for the zoning district. Front: 40 feet. Side: 20 feet. Rear: 50 feet.
Connection to the Xcel System
The proposed community solar garden will connect to the local utility grid at an existing
distribution line that runs along 165th Avenue. Two diagrams of this interconnection are
included on the Site Development Plan, above. A signed agreement with the local utility
company will be submitted with the application for a Building Permit.
Site Access
Access to the site of the community solar garden will be from 1651 Avenue. The internal
service drive will be grass -covered.
Wetland Delineation
Emmons and Olivier Resources, Inc., will conduct a "desktop" review of hydrology, soils,
topography and historic aerial photography of the site and submit it to the Rice Creek
Watershed District for review. The Watershed District will provide a written opinion whether
any apparent wetlands exist in the cultivated fields, and that will be verified by field
investigation and reviewed by the Watershed District.
Prior to the start of construction, the Watershed District will issue a Wetland Conservation Act
Notice of Decision on behalf of itself acting as the WCA Local Governing Unit. The wetland
permitting process will be coordinated with the Army Corps of Engineers , which has
regulatory authority for Section 404 of the Clean Water Act. The Minnesota Department of
Natural Resources may require permits through the Minnesota Public Waters program that
they administer. Avoidance and minimization of all impacts to wetlands (if any) and public
waters is being incorporated into the site design and implemented.
Grading, Drainage and Erosion Control
Grading for the community solar garden limited to the extent practical. It may include (1)
creating grass -covered service roads among the blocks of arrays (2) creating pads for the
electrical inverters, (3) stabilizing the construction entrances and exits and access road and (4)
establishing the parking and staging areas for vehicle and equipment storage / laydown and
maintenance. The solar arrays can conform to the slopes and do not require that terraces be
created because each solar array is installed by simply drilling posts into the ground.
Disturbed soils will be returned closely to their original contours. The final site will be seeded
with fast-growing grasses and mowed as necessary to prevent woody species from establishing.
Consequently, the rate, volume and quality of the surface water runoff is expected to be
improved from the present values generated by a plowed field of row crops.
The existing drainage from the site is not expected to be changed.
315 Manitoba Avenue, Suite 200, Wayzata, MN 55391
It is unlikely that water running from the face of the panels will create erosion under the
bottom edge of the lower panels. The panels are set one-half inch apart to allow some of the
runoff to drip to the sides. Water dripping from the bottom edge tends to disperse somewhat
by wind action. Solar operators do not want erosion under the panels, as that could create
minor problems.
Solar Energy Conversion Panels
The solar energy conversion panels will be single -axis trackers, which tilt up and down to
follow the sun during the year but not during the day or a fixed tilt system that faces south and
does not move. They will be approximately 12 feet tall and arranged in arrays as illustrated
below. There would be approximately 4,000 individual solar panels.
Figure 6: Typical Solar Arrays
Figure 7: Appearance of Typical Solar Panel Arrays in a Field
The panels will be mounted on a steel and aluminum racking structure and average
approximately 12 feet above grade when in their most upright position.
The racking system is installed in the ground with pilings (I -beams) that are driven directly
into the group at a depth usually between 6 feet and 8 feet depending on soil conditions.
315 Manitoba Avenue, Suite 200, Wayzata, MN 55391
The racking system manufacturer's engineer will provide certification that the design of the
foundations and panels are within accepted professional standards, given local soil and climate
controls . The equipment is designed to withstand wind up to 90 miles per hour and fifty
pounds per square foot of snow.
Each of the gardens will have one concrete equipment pad, typically less than 320 square feet,
to support interconnection and metering equipment.
The panels will be arranged into rows. Each row of solar panels will connect to an inverter.
The inverters will be connected by directionally bored underground conduit that is housed
inside of housing that will be installed 2 feet below the surface. The conduit will lead to the
concrete equipment pad for each garden. The inverters transform the direct current power
generated by the photovoltaic system to alternating current power, which is then connected to
the existing Xcel Energy three phase power distribution line at the point of common coupling.
The solar array will be contained within an area protected by a six-foot chain link fence. It will
not create any noise, dust, fumes, glare, or other.
Ground Cover
Native plantings will be used as ground cover. These grasses and forbs will enhance local
biodiversity, consistent with the Pollinator Protection Pledge of the local solar power industry.
They will be especially helpful to pollinator species such as bees and butterflies. The ground
cover will be kept mowed to a workable height, and noxious weeds will not be allowed to
flourish and spread into nearby farm fields.
Tree Protection
No trees will be removed from this site for the community solar garden.
Perimeter Fence
A 6 -foot, galvanized chain-link perimeter fence will be installed for safety and security. The
fence will meet the setback requirement.
Sign
A small freestanding sign will be erected near the entrance to the site. The sign will include
the site address in 6 -inch letters, emergency contact information, and emergency procedures.
315 Manitoba Avenue, Suite 200, Wayzata, MN 55391
Operations and Maintenance
Monitoring
The solar garden site will operate and be monitored 24 hours a day, 365 days a
year after construction has been completed.
Equipment Inspection
Equipment inspection will occur at regular intervals, including:
■ PV modules: visual check of the PV modules, tracking system and surrounding grounds to
verify the integrity of the PV modules and racking structure, or the presence of animals
and nests, etc.;
■ Inverters, transformer and electrical panels: visual check of the devices including the
connection equipment and the grounding network.
■ Check for presence of water and dust;
■ Electrical check: measurement of the insulation level and dispersion.
■ Check of the main switches and safety devices (fuses);
■ Noise: check of abnormal sounds;
■ Cabling and wiring: visual check of electrical lines (where visible) and connection box to
verify its status.
Performance Monitoring
Performance monitoring will consist of a real-time and continuous assimilation of the data
acquired by the facility meteorological station, energy meter and SCADA system. Operators
and or maintenance personnel will be immediately notified of abnormalities so timely
corrective action such as repair or replacement on: modules, racking, the collection system,
and etc., can occur.
Facility Maintenance
Routine maintenance of the Project will include road maintenance, fence and gate inspection,
and lighting system checks. Module washing is not needed on a scheduled basis. Rain keeps
the modules sufficiently clean and the site is vegetated to keep dust down so that washing
modules would occur infrequently and only as determined by maintenance technicians. Snow
and ice removal is not needed. The system is designed to shed rain, snow and ice. Vegetation
maintenance will include scheduled mowing and spot spraying weeds using registered
herbicides.
Maintenance Frequency
The electrical and mechanical components of the community solar garden would be checked
on a regular basis to ensure safety and reliability. The maintenance schedule would range from
weekly to yearly depending on the component.
315 Manitoba Avenue, Suite 200, Wayzata, MN 55391
De -Commissioning, Restoration and Repowering
At the end of commercial operation, FastSun or its successors will be responsible for
decommissioning by removing all of the arrays and equipment. We have contractual
obligations to the landowners regarding decommissioning
Financial Surety
FastSun will post a financial surety for the County that covers the cost of de -commissioning
the site. This surety will conform to the County's requirements in the Code.
De -Commissioning Procedures
All equipment and structures will be removed within 90 days from either of the following: (a)
the end of the system's serviceable life or (b) the day the system is discontinued. A system
shall be considered to be discontinued after one year without energy production unless a plan
is submitted to the Zoning Administrator outlining the steps and schedule for returning the
system to service.
Decommissioning at the end of the project's useful life, which is estimated to be
approximately 25 to 30 years, would include removing the arrays, inverters, transformers,
above -ground portions of the electrical collection system, fencing, lighting, and supply
structure from the Project.
Standard decommissioning and restoration practices will be used, including dismantling and
repurposing, salvaging, recycling or disposing of the solar energy improvements, and
restoration. Land returned to agricultural production will be reclaimed to restore topsoil that
may have been scraped and stockpiled from areas that are designated in the final design plan.
Table 2
De -Commissioning Plan Summary
Phase Facility
Timeline Decommissioning is estimated to take approximately 90 days to
complete. The decommissioning crew will ensure that all equipment is
recycled or disposed of properly.
Financial The project developer will be responsible for all costs to decommission
Resource Plan the Project. Because of the uncertainty in predicting future
decommissioning costs and salvage values, we will review and update
the original decommissioning plan that was approved by the City closer
to the end of the Project's life. We will abide by the applicable
condition(s) and ensure the Project is decommissioned in accordance
with the Conditional Use Permit.
Removal and
The removal and disposal of the Project components are found below.
Disposal of
Project
Photovoltaic PV modules will be inspected for physical damage,
Components
Modules tested for functionality, and removed from racking.
Functioning PV modules will be packed and stored
for reuse. Non-functioning PV modules will be sent
315 Manitoba Avenue, Suite 200, Wayzata, MN 55391
Phase Facility
............
to the manufacturer or a third party for recycling or
other appropriate disposal method.
Racking, Poles
Racking, utility poles, and fencing will be
and Fencing
dismantled/removed and will be sent to a metal
recycling facility. Holes will be backfilled with soil
from the Project facility.
Wire
Above-ground wire will be sent to a facility for
proper disposal and/or recycling. Below-ground wire
will be cut back to a depth of two to three feet below
grade and abandoned in place.
Conduit
Above-ground conduit will be disassembled at the
Project and sent to a recycling facility.
Junction Boxes,
The boxes will be sent to an electronics recycler.
Combiner
Boxes, External
Disconnect
Boxes, etc.
Inverters
Functioning inverter parts will be re-used. Non-
functioning inverters will be sent to the
manufacturer or an electronics recycler as
applicable.
Restoration
and
Reclamation of
the Site
Concrete Pads Material from concrete pads will be removed and
sent to a concrete recycler.
Computers, Computer components will be sent to an electronics
Monitors, Hard recycler and functioning parts will be reused.
Drives and
Similar
After all equipment is removed, the Project site will be restored to a
condition similar to its pre -construction use if the Project site will once
again be used for agricultural. If holes are created when infrastructure
is removed, they will be back-filled and covered with topsoil. Concrete
pads and all other equipment will be removed and disposed of as
described above. Unless requested otherwise, permanent access roads
constructed on the Project will be removed. Topsoil that was stripped
and relocated to designated areas on the site during construction will
be re -worked to cover exposed subsoils.
315 Manitoba Avenue, Suite 200, Wayzata, MN 55391
Decommissioning Plan I Rev.0
De -Commissioning
Contents
OPENING STATEMENT..................................................................................................................................2
GENERAL DECOMMISSIONING SCOPE..........................................................................................................2
SEQUENCEOF WORK....................................................................................................................................2
TEMPORARY EROSION CONTROL..................................................................................................................3
SYSTEM REMOVAL COSTS.............................................................................................................................3
TABLE 1 (Decommissioning Costs)............................................................................................................3
SALVAGEVALUE............................................................................................................................................ 4
TABLE2 (Salvage Value)............................................................................................................................5
NET COSTS FOR DECOMMISSIONING...........................................................................................................5
DECOMMISSIONING FUND...........................................................................................................................5
1
Decommissioning Plan I Rev.0
OPENING STATEMENT
The community solar garden consists of numerous recyclable materials, including glass, semiconductor material,
steel, aluminum, copper, and plastics. When the project reaches the end of its operational life, which is expected
to be 25 (twenty five) years from date of PTO (Permission To Operate) from interconnecting Utility and local
permitting government but could be in excess of 40 (forty) or more years, the component parts will be dismantled
and recycled as described below. That time period will be established by the local permitting government in its
permit. In addition, the decommissioning can also take place after twelve (12) months of non -operation, as
required by the site lease and the local government.
At the time of decommissioning, the project components will be dismantled and removed by use of minimal
ground surface impact construction equipment, and materials will be safely recycled and or disposed of in
accordance with requirements. Specific opportunities for reuse or recycling (e.g., panels) will be considered to the
maximum amount practicable. Where such options are not viable, components will be decommissioned and
disposed of at an appropriately licensed facility.
As laid out below, the security fence and equipment will be dismantled, stored on site and then transported to the
appropriate locations. All access roads will be removed and grading will be returned to as close to its original state
(unless determined otherwise by the landowner and/or local government). Based on our preliminary designs, we
expect that the solar gardens will be installed with minimal, if any, grading required. Hence any restoration
activities at the time of decommissioning will likewise require minimal re -grading.
GENERAL DECOMMISSIONING SCOPE
The project owner will be responsible for all the decommissioning costs. The general scope of such
decommissioning will be:
1) Obtain any permits required for the decommissioning, removal and legal disposal prior to commencement of
decommissioning activities
2) Remove and disposal of all equipment components
3) Remove all hazardous materials (if any) and transport them to be disposed of by licensed contractors at the
appropriate facility, in accordance with rules and regulations.
4) If appropriate, re -grade, and revegetate in accordance with lease, permits and in compliance with all
applicable rules and regulations
5) To the best extent possible, preserve and reclaim the soils on the project site to a level of pre -project quality
6) Reclaim soils in access driveway and equipment pad areas by removing imported aggregate material and
concrete foundations and replaced with soils as needed
7) Remove electrical conduits and backfill trenches with the native soils removed
8) Reseed as much disturbed areas using a seed mix pre -approved by the local permitting government
SEQUENCE OF WORK
The sequence for decommissioning of the project generally occurs in the reverse order of the installation:
1) The solar system will be disconnected from the powergrid.
2) PV modules will be disconnected, unattached, collected, and removed.
2
Decommissioning Plan I Rev.0
3) Site aboveground and underground electrical interconnection and distribution cables will be removed and
recycled off-site by an approved recycler.
4) PV module support racking will be removed and resold or recycled off-site by an approved recycler.
5) PV module support steel and support posts will be removed and recycled off-site by an approved recycler.
6) Electrical devices, including transformers, and inverters, will be removed and recycled off-site by an approved
recycler.
7) Concrete pads will be removed and recycled off-site by an approved recycler.
8) Fencing will be removed and recycled by an approved recycler.
The project site may be converted to other uses in accordance with applicable land use regulations at the time of
decommissioning. There are no permanent changes to the site, and it can be restored to its original condition.
This is one of the many great advantages about solar gardens. If desired, the site can return to productive
farmland after the system is removed.
TEMPORARY EROSION CONTROL
During the decommissioning of the project, Decommissioning Contractor will use if necessary, appropriate
temporary (construction -related) and sedimentation control best management practices as described in the
project Storm -water Pollution Prevention Plan (SWPPP).
SYSTEM REMOVAL COSTS
The breakdown of costs for removal of the Community Solar Garden is found in TABLE 1 below. The costs are
based upon typical quantities for a 1mwAC/1.35mwDC Fixed Tilt array. Costs may slightly vary depending on site
specific quantities at time of construction.
TABLE 1 (Decommissioning Costs
Quantity
Unit
Unit Cost
Total Cost
Mobilization/Demobilization
Mobilization/Demobilization
1
Sump
$10,000.00
$10,000.00
Subtotal Mob/Demob
$10,000.00
Permitting
State Permits
1
S mp
$1,200.00
$1,200.00
Subtotal Permitting
$1,200.00
Civil Infrastructure
Removal Gravel Surfacing from Road
325
Cy
$5.80
$1,885
Haul Gravel Removed from Road
325
Cy
$6.84
$2,223
Disposal of Gravel Removal from Road
325
Cy
$0.00
$0
Removal Geotextile Fabric from Road Area
16,000
SF
$0.10
$1,600
Culvert Removal and Disposal
0
Each
$1,200
$0.00
De -Compact and Grade Road Corridor
1,000
LF
$1.00
$1,000.00
Topsoil and Stabilization on Removed Road Area
0.45
Acres
$17,000.00
$7,650.00
Removal of Security Fence
2,500
LF
$6.50
$16,250.00
Subtotal Civil Infrastructure
$30,608
Decommissioning Plan I Rev.0
SALVAGE VALUE
Solar power systems retain some of their value after their operating life. The solar modules are known to continue
to have useful life and in turn can be resold or recycled due to the metallurgic properties. Additionally, the
community solar garden has large usage of steel piers, aluminum railing, copper and aluminum conductors and
various other materials that have salvage value.
The breakdown of the salvage values are found in TABLE 2 below. The salvage values are based on typical
quantities for a 1mwAC / 1.35mwDC Single Axis Tracker array. Values may slightly vary depending on site specific
quantities at time of construction.
4
Structural Infrastructure
Remove PV Rack Steel Posts to a 4' Depth
575
Each
$13.00
$7,475
Haul PV Rack Array Steel Post
31
Ton
$6.75
$209
Removal Transformer Station Post to a 4' Depth
10
Each
$13.00
$130
Haul Transformer Station Post
0.4
Ton
$6.75
$3
Removal Array Tracker & Motors
120
Each
$110.00
$13,200
Haul Array Tracker & Motors
90
Ton
$6.75
$608
Remove, Load, Haul Concrete Electrical Pads
30
CY
$150.00
$4,500
Subtotal Structural Infrastructure
$26,124
Electrical Collection/Transmission System
Removal of PV Modules
4,032
Each
$10.00
$40,320
Haul PV Modules
80
Ton
$6.75
$540
Remove and Load Inverters
2
Each
$300.00
$600
Haul Inverters
2
Ton
$135.00
$270
Removal Loading and Freight of Transformers
1
Each
$400.00
$400
Removal, Loading and Freight of Electrical Equipment
1
Each
$500.00
$500
Removal and Disposal of SCADA Equipment
1
Each
$300.00
$300
Removal and Load Underground Collector System
Cables
10,000
LF
$0.07
$700
Haul Underground Cable
3
Ton
$135.00
$405
Subtotal Electrical Collection/Transmission System
$44,035
Site Restoration
Perimeter Controls
2,000
LF
$4.00
$8,000
Topsoil and Turf Establishment on area within Removed
Array
11
Acres
$1,300.00
$14,300
Subtotal Site Restoration
22 300
Grand Total: Decommissioning & Site Restoration
$134,267
SALVAGE VALUE
Solar power systems retain some of their value after their operating life. The solar modules are known to continue
to have useful life and in turn can be resold or recycled due to the metallurgic properties. Additionally, the
community solar garden has large usage of steel piers, aluminum railing, copper and aluminum conductors and
various other materials that have salvage value.
The breakdown of the salvage values are found in TABLE 2 below. The salvage values are based on typical
quantities for a 1mwAC / 1.35mwDC Single Axis Tracker array. Values may slightly vary depending on site specific
quantities at time of construction.
4
Decommissioning Plan I Rev.0
TABLE 2 (Salvage Value)
NET COSTS FOR DECOMMISSIONING
The estimated cost, salvage value, and net costs of decommissioning the project are below.
Demo & Restoration Cost $ 134,267
Salvage Value (104,732)
Total Net Cost $ 29,536
DECOMMISSIONING FUND
1) Decommissioning of the system will occur within 60 days from either of the following:
A. The end of the system's serviceable life; or
B. The system becomes a discontinued use. A system shall be considered a discontinued use after one year
without energy production, unless a plan is developed and submitted to the Zoning Administrator outlining
the steps and schedule for returning the system toservice.
2) The anticipated manner in which the solar farm project will be decommissioned and site restored:
The manner in which the solar farm will be decommissioned is found in aforementioned in this document.
3) Timetable for completion of decommissioning:
The decommissioning will be completed within the time frame stated in the Conditional or Interim Use Permit.
We recommend 6 months.
4) The party responsible for decommissioning:
The permittee or its assignee shall be responsible for the decommissioning. In the event the property owner
and/or responsible party fail to timely decommission the solar farm/garden facility as required above, the Local
permitting government shall be entitled to take all measures allowed by the Minnesota State Statutes, as well as
the right to levy penalties as provided in the Local permitting government Code, the right to obtain a permanent
injunction ordering the removal of such solar farm/garden facility, and the right to obtain a court order permitting
the Local permitting government to remove such solar farm/garden facility.
Quantity
Unit
Unit Cost
Total Cost
Salvage
Fencing
6.25
Tons
$50.00
$313
Steel Posts
31
Tons
$175.00
$5,425
Module Trackers and Motors
90
Tons
$175.00
$15,750
PV Modules
4,032
Each
$20.00
$80,640
Transformers
1
Each
$2,500.00
$2,500
Switch Gear, Capacitors, Fuses, Etc.
1
Each
$0.00
$0
Collection Lines
5,200
Pounds
$0.02
$104
Subtotal Salvage
$104,732
Total Demolition Minus Salvage Value
29,536
NET COSTS FOR DECOMMISSIONING
The estimated cost, salvage value, and net costs of decommissioning the project are below.
Demo & Restoration Cost $ 134,267
Salvage Value (104,732)
Total Net Cost $ 29,536
DECOMMISSIONING FUND
1) Decommissioning of the system will occur within 60 days from either of the following:
A. The end of the system's serviceable life; or
B. The system becomes a discontinued use. A system shall be considered a discontinued use after one year
without energy production, unless a plan is developed and submitted to the Zoning Administrator outlining
the steps and schedule for returning the system toservice.
2) The anticipated manner in which the solar farm project will be decommissioned and site restored:
The manner in which the solar farm will be decommissioned is found in aforementioned in this document.
3) Timetable for completion of decommissioning:
The decommissioning will be completed within the time frame stated in the Conditional or Interim Use Permit.
We recommend 6 months.
4) The party responsible for decommissioning:
The permittee or its assignee shall be responsible for the decommissioning. In the event the property owner
and/or responsible party fail to timely decommission the solar farm/garden facility as required above, the Local
permitting government shall be entitled to take all measures allowed by the Minnesota State Statutes, as well as
the right to levy penalties as provided in the Local permitting government Code, the right to obtain a permanent
injunction ordering the removal of such solar farm/garden facility, and the right to obtain a court order permitting
the Local permitting government to remove such solar farm/garden facility.
Decommissioning Plan I Rev.0
5) Financial Assurance:
The local permitting government may require assurance that funds will be there for the necessary
decommissioning work when the project reaches the end of its purposeful life, been condemned, or has been
abandoned. A "financial assurance level" of 20% of total project decommissioning costs can be established by
year 10 with increases over time until it reaches 100% for year 25 of operation. Assurance can be achieved via
Letter of Credit or cash set aside in an escrow account controlled by a third -party insurance company. The
financial assurance is recommended to be in the amount of; $30,000.00 (per net costs after salvage value of
equipment and costs for decommissioning).
Upon successful decommissioning, the local permitting government is expected to release the cash escrow,
letter of creditor bond within 30 days of a request. Partial release(s) commensurate with the decommissioning
completed as of the date of the request is requested.
M
RESOLUTION 2018 -
APPROVING AN INTERIM USE PERMIT TO ALLOW FOR A SOLAR FARM
ON PROPERTY LOCATED NORTH OF 165TH STREET NORTH AND WEST
OF HENNA AVENUE NORTH
WHEREAS, FastSun 4, LLC. has requested approval of an Interim Use Permit (IUP) to
allow for a solar farm on the property legally described as follows:
(See Attached)
WHEREAS, the Planning Commission has reviewed the request at a duly called public
hearing and recommends approval, and;
NOW, THEREFORE, BE IT HEREBY RESOLVED BY THE CITY COUNCIL OF
THE CITY OF HUGO, MINNESOTA, that it should and hereby does approve the
request by FastSun 4, LLC. for an Interim Use Permit (IUP) to allow a solar farm, subject
to the following findings of fact:
The applicant has a lease agreement with the property owner of the
property in question.
2. The proposed solar farm is an allowed permitted use within the Future
Urban Service (FUS) zoning district.
3. The spirit and intent of the ordinance is to allow for the generation of
renewable energy within the City of Hugo. Promoting the safe, effective,
and efficient use of solar energy, may reduce the onsite consumption of
fossil fuels and utility -supplied electric energy while avoiding adverse
impacts on the community at large. The solar farm meets the spirit and
intent of the ordinance.
4. The solar farm will not impede the City's ability to implement its
Comprehensive Plan.
The intent of the Future Urban Service (FUS) zoning district is to promote
the preservation of large parcels that are eligible for city services.
Because of this, this area is generally treated as a rural/agricultural area of
the City. Many of the uses in this zoning district are single family homes
with the remaining land used for agricultural activities. These uses
generally translate into having a low impact on adjacent properties with
limited noise, traffic, etc. The solar farm will not adversely affect the
surrounding area and is compatible with the present character of the
surrounding area.
6. To construct and operate the solar farm on the property the applicant
agrees to sign the interim use permit and agrees to the conditions outlined
in the permit.
Resolution 2018 -
Page 2
7. The interim use permit shall be reviewed every five years from date of
approval.
The interim use permit shall expire 25 years from the date of the
issuance/approval of the final building inspection on site.
ADOPTED by the City Council this day of , 2018
Tom Weidt, Mayor
ATTEST:
Michele Lindau, City Clerk
DATE OF APPROVAL:
APPLICANT:
PROPERTY OWNER:
INTERIM USE PERMIT
August 6, 2018
FastSun 4, LLC.
601 Carlson Parkway
Minnetonka, MN 55305
Linda M. Gregoire
264203 1 01h Place
Aitkin, MN 56431
PROPERTY ADDRESS: N/A
PROPERTY ID: 10.031.21.23.0003
DURATION: Expires in 25 years (timeline beginning at the approval of
the final building permit inspection)
REVIEW: The permit shall be reviewed eveLy 5 ye
ZONING DISTRICT:
LEGAL DESCRIPTION:
Future Urban Service (FUS)
See attached Exhibit A
THIS INTERIM USE PERMIT ALLOWS FOR THE FOLLOWING:
A solar farm on the property generally located north of 165th Street North and west of
Henna Avenue North.
THIS INTERIM USE PERMIT IS APPROVED SUBJECT TO COMPLIANCE
WITH THE FOLLOWING SPECIAL CONDITIONS:
1. A building permit shall be required for the erection of the solar farm.
2. The solar farm shall operate in a manner that is consistent with applicant's
narrative (Exhibit SAB) and applicant's site plan (Exhibit CB).
3. The solar farm owner/operator shall abide by the decommissioning plan (Exhibit
DE) and decommission plan City standards outlined in Section 90-278.
4. The solar farm shall not permit light, glare, noise, odor, smoke, dust, or vibration
that will in any way have an objectionable effect upon adjacent or nearby property
owners.
5. It shall be the responsibility of the property owner to secure any solar energy
easements, if applicable, to protect solar access for the system (as per MN Statute
Section 500.30).
6. A small sign will be allowed at the entrance of the site to display the site address,
emergency contact information, and emergency procedures. A permit for any
sign installed on site will require review and approval of a sign permit application
by the Community Development Director or designee.
Prior to the issuance of a building permit the following must be completed:
7. The solar farm owner/operator shall submit a current -day decommissioning cost
estimate and shall post a cash escrow to the City.
8. The solar farm owner/operator must provide evidence of an agreement with the
local utility.
8-.9. The solar farm owner/operator shall provide a copy of the issuance policy
for the solar farm and property, for review by City staff.
9-.10. The solar owner/operator shall work with City staff regarding the
landscape plan. The Community Development Director or designee shall review
and approve the landscape plan prior to installation of any landscaping.
2,. Any plantings installed shall be coniferous trees.
gib. The plan shall be revised to include a staggered plantings in two rows.
b. Any plantings seleete rtobe planted within the wetlands must be native in
Minnesota.
c. The installation of landscaping shall be done as to not result in excessive
disturbance to topsoil or vegetation within the wetland areas.
d. All landscaping shall meet section 90-181 — Landscaping in regards to
sizes of plantings and minimum installation requirements.
411. A landscape maintenance agreement shall be reviewed and approved by
Cit., staff.
12. The owner/operator of the solar farm shall receive approval of all necessary
permits and abide by all requirements indicated in the associated Notice of
Decision (NOD) provided by the Technical Evaluation Panel (TEP). This
includes requirements for time of installation, panel height requests, etc.
13. A stormwater management plan meeting all City requirements shall be reviewed
and approved by staff. A stormwater permit shall be issued by the CitY.
44,14. A cash escrow shall be deposited to the City for the grand total amount for
decommissioning and site restoration of $134,267.00 found in Exhibit C.
Prior to the issuance/approval of a building permit final the following conditions
must be met/completed:
44-.15. All exterior electrical or other service lines shall be buried underground.
The collection system may be placed overhead near substations or points of
interconnection to the electrical grid.
4-2-.16. All landscaping shall be installed in accordance with the approved
landscape plan.
4-3-.17. The solar energy panels shall be installed as to have the same elevation
and be consistent throughout the site.
44.18. The solar energy system shall not exceed 15 feet in height when oriented
at maximum tilt.
419. Solar energy system components shall be labeled with the manufacturers
name and address, model number, and serial number.
420. The solar farm shall be in compliance with the adopted city and state
building code, electrical code, and plumbing code, as amended and receive any
necessary permits or approvals from any regulatory agency having jurisdiction.
ADOPTED by the City Council this 15* day of �t , 20186.
Tom Weidt, Mayor
STATE OF MINNESOTA )
) ss.
COUNTY OF WASHINGTON)
On this day of , 2018, before me, a Notary
Public, personally appeared Tom Weidt, Mayor of the City of Hugo, a Minnesota
municipality within the State of Minnesota, and that said instrument was signed on behalf of
the City of Hugo by the authority of the City Council of the City of Hugo, and Tom Weidt,
Mayor, acknowledge said instrument to be the free act and deed of said City of Hugo.
Notary Public
STATE OF MINNESOTA )
) ss.
COUNTY OF WASHINGTON)
(name -printed), (title)
(Individual Notary)
On this day of , 2018, before me, a Notary
Public, personally appeared FastSun 4, LLC., represented by
(name), (title)
who signed the foregoing instrument and acknowledged said instrument to be his free act
and deed.
Notary Public
THIS INSTRUMENT WAS DRAFTED BY: THE CITY OF HUGO
14669 Fitzgerald Avenue North
Hugo, MN 55038
w a t e r
E07 e c o l o g y
community
Project Name FS4 Hugo -Gregoire Date 1 8/16/18
To / Contact info Chuck Beisner, Project Development Manager, SEV
Cc / Contact info, Rachel Juba, Community Development Director, City of Hugo Received
of
Paula Kalinosk y EOR City Augus Hugo
st 16, 2018
From / Contact info Ryan Fleming EOR
Jason Naber EOR
Regarding I Preliminary Stormwater Management Design for FS4 Hugo -Gregoire Solar Garden
Stormwater Management and Hugo -Gregoire
This memo contains a summary of preliminary stormwater management design elements for
FastSun 4, Hugo -Gregoire, the proposed solar garden at 7260 165th St N, Hugo, MN 55038. This
information is being provided at the request of the City of Hugo as a supplement to the materials
submitted by Sunrise Energy Venture for the Condition Use Permit application for this site.
Although stormwater design is still at a preliminary stage for this site, key components of the
design - treatment requirements, volume to be treated, appropriate best management practices for
the site context - have been determined. These are explained in as much detail as is possible at this
stage in the design process.
Site Grading Impacts
The proposed solar garden is located on a portion of the property that exhibits gently undulating
slopes of less than seven percent. Therefore, the only anticipated grading will be to construction
the access road and stormwater features. A site grading plan will be developed for the building
permit submittal and construction plan set.
Erosion and Sediment Control
Prior to construction, the applicant will submit a Stormwater Management Pollution Prevention
Plan (SWPPP) to fulfill the requirements of the Minnesota NPDES General Construction Stormwater
Permit. These requirements includes temporary practices such as silt fence and storage ponds to
control runoff sediment during construction as well as permanent practices such as appropriate
vegetation and permanent stormwater facilities ensure downstream water quality is protected.
Stormwater Management
Stormwater management best management practices (BMPs) will be constructed to reduce
nutrient and sediment pollution following the requirements of the Minnesota Pollution Control
Agency (MPCA) and the Rice Creek Watershed District (RCWD); and to ensure that stormwater is
not discharged from the site at rates exceeding existing conditions according to RCWD Rule 7.a.
Water quality treatment will be achieved by installing filtration practices in strategic areas to
capture and treat runoff from the access road and solar panel. Preliminary stormwater BMP sizing
calculations have been completed following the Minnesota Pollution Control Agency (MPCA)
method for calculating impervious surface for solar panels. Based on the required water quality
treatment volume and the cohesive nature of the underlying soil, the area required to provide
treatment for the access road and solar panel array is approximately 1,800 square feet (0.4 acres).
Stormwater treatment practices will be located along the edges of the solar array, and along the
EOR is an Equal Opportunity Affirmative Action Employer
Emmons & Olivier Resources. Inc. 7030 6`' St. North Oakdale. MN 5512.8 T/ 651.770.8448 F/ 651.770.2552 www.eorinc.com
memo
2of2
downstream portion of the access road, and, where unavoidable, between panel rows to capture
water from the array and road surface. The total open space between and around the panel rows
(approximately 3.3 acres) is significantly greater than the BMP footprint area required, allowing for
optimal siting of stormwater practices (see attached exhibit).
The options under consideration include bioretention basins, rock trenches, and bioretention
swales. Because soils on the site are generally poorly drained, the practices would be installed with
an underdrain. This configuration allows water to filter slowly through engineered soil media
before being discharge to the onsite wetland. The practices will remove pollutants and slow the
movement of water across the landscape.
Additionally, open areas between the rows of the solar array will be stabilized by planting with
native, pollinator -friendly species. Plantings will help to both stabilize soils on the site and to
improve the soil capacity to infiltrate stormwater. The flow rate and volume of stormwater leaving
the property will be lower and the water quality will improve as a result of the proposed solar
installation.
Wetland Impacts
About 50% of the leased property is composed of wetland. Solar panels have been located in upland
areas to the extent practical, and fringe (degraded) wetland areas. Higher quality wetlands have
been avoided and protected. Approximately 1/4 - 1/3 of the pilings for the solar arrays will be
located within wetland areas (primarily degraded wetland areas). The owner is seeking area No -
Loss Decision from the WCA LGU (MN Rule 8420.0420 Subp.6(A)). The cumulative area of piling
installation is significantly less than the 0.5 acre threshold referenced in this rule. The site plan
does include some impacts to wetland areas for construction of the access road, but because the site
is relatively flat; grading impacts to adjacent wetland areas are minimal. The total area of impact
due to road construction is less than 0.25 acres. The owner proposes to use wetland banking credits
to mitigate the area of impact. Additionally, runoff from the roadway will be directed to filtration
BMPs to mitigate pollution and disperse flow as described above.
Emmons & Olivier Resources, Inc.
7030 6`h St. North Oakdale. MN 55128 T/ 651.770.8448 F/ 651.770.2552 www.eorinc.com
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— 701 Xenia Avenue South I Suite 300 1 Minneapolis, MN 55416 1 (763) 541-4800
Memorandum
To: Rachel Juba, City of Hugo
Cc: Mark Erichson, WSB & Associates
From: Stephanie Hatten, WSB & Associates
Date: August 17, 2018
Re: Stormwater Management Requirements — Gregoire Solar Site
WSB Project No. 010469-000
The following memo summarizes the City of Hugo/RCWD stormwater management requirements for the
Gregoire Solar Site. These requirements will need to be met prior to issuing a Stormwater and Erosion
Control Permit. A Permit is needed before construction will begin.
Volume Control/Water Quality
The Solar Site will need to meet the City's volume reduction requirement of 1.1 inches off new impervious
surfaces. The MPCA Solar Panel Calculator spreadsheet must be used to calculate the volume reduction
needed for the site. Since the entire solar array is not a continuous impervious surface, the MPCA has
chosen to modify the calculations to allow for stormwater credit for a portion of the runoff that will infiltrate
into the ground below the solar panels. Any additional stormwater runoff from access roads (gravel or
paved) or other impervious surfaces must also be added to the volume reduction requirement from the
MPCA spreadsheet for the solar panels.
Infiltration or water reuse is the preferred method for volume reduction. Soil borings or other
documentation must be submitted. Some site restrictions for infiltration may include HSG C and D soils,
soil contamination or high groundwater elevations. If infiltration or reuse is not feasible onsite, any BMP
may be used. The TP removal factor from Table C1 of RCWD rules must be applied for the chosen BMP.
TP and TSS removal will be considered met once the volume control requirement has been met. Area not
treated for phosphorus may not exceed 15% of all new or reconstructed impervious surface. For all
untreated surface, TSS must be removed to the maximum extent practicable.
Rate Control
Peak stormwater runoff rates for the site must not exceed existing rates for the 2 -year and 10 -year 24-
hour rainfall events using Atlas 14 rainfall depths. Peak stormwater runoff rates for the 100 -year 24-hour
rainfall event is limited to 0.1 cfs/acre.
Submittal Requirements
• Property lines and delineation of lands under ownership of the applicant
• Delineation of the subwatershed contributing runoff from off-site, proposed and existing
subwatersheds onsite, emergency overflows, and drainageways.
• Geotechnical analysis including soil borings at all proposed stormwater management facility
locations utilizing ASTM D5921 and D5879, as amended.
Building a legacy —your legacy.
Equal Opportunity Employer I wsbeng.com
City of Hugo
August 17, 2018
Page 2
• Proposed and existing stormwater facilities' location, alignment and elevation.
• Delineation of existing on-site wetland, marshes and floodplain areas.
• Identification of existing and proposed normal, ordinary high and 100 -year water elevations on-
site.
• Identification of existing and proposed contour elevations within the project site related to NAVD
88.
• Construction plans and specifications of all proposed stormwater management facilities, including
design details for outlet control structures.
• Grading plan showing floodplain elevations, EOF locations and elevations, building elevations,
and grading limits.
• Stormwater runoff volume and rate analyses for the 2-, 10 -,100 -year, and 10 -day snowmelt
critical events, existing and proposed conditions utilizing NOAA Atlas 14.
• All hydrologic, water quality and hydraulic computations completed to design the proposed
stormwater management facilities. Atlas 14 rainfall depths and MSE 3 distribution curve method
must be used. Runoff from pervious and impervious areas within the model must be modeled
separately. Curve numbers for pervious areas shall be consistent with values recommended in
the Minnesota Stormwater Manual. Curve numbers for post -development condition within
construction limits shall be shifted down one classification for HSG B and half a classification for
HSG A to account for impacts of grading on soil structure unless the project specifications
incorporate soils amendments.
Narrative including a project description, discussion of BMP selection, and revegetation plan for
the project site.
• Utility plan including storm sewer design and details plates.
• Other project site-specific submittal requirements as may be required by the City.
K:\010469-000\Admin\Docs\Stormwater Requirements Memo.docx
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T ,.,,pr tureCoefficient ofVoc -0.31%/°C
`gmperat, Coefficient of Isc 0.045 %/°C
Cell Type: 144 multicrystalline in 6 strings of 24 cells
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Max Series Fuse Rating: 20A
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10 year product warranty. Dimensions: 78.9"x39.4"x1.2"(2005x1001 x30 mm)
Sp° DVE 25 year linear power output warranty Area: 21.6ft' (2.01m1)
US (max. degression in performance of 0.7%p.a.). Weight: 48.5 lbs (22 kg)
Pending: UL 1703, UL Fire Type 2, CEC listed
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Health and Safety Impacts of Solar Photovoltaics
The increasing presence of utility -scale solar photovoltaic (PV) systems (sometimes referred to as
solar farms) is a rather new development in North Carolina's landscape. Due to the new and unknown
nature of this technology, it is natural for communities near such developments to be concerned about
health and safety impacts. Unfortunately, the quick emergence of utility -scale solar has cultivated fertile
grounds for myths and half-truths about the health impacts of this technology, which can lead to
unnecessary fear and conflict.
Photovoltaic (PV) technologies and solar inverters are not known to pose any significant health
dangers to their neighbors. The most important dangers posed are increased highway traffic during the
relative short construction period and dangers posed to trespassers of contact with high voltage equipment.
This latter risk is mitigated by signage and the security measures that industry uses to deter trespassing.
As will be discussed in more detail below, risks of site contamination are much less than for most other
industrial uses because PV technologies employ few toxic chemicals and those used are used in very small
quantities. Due to the reduction in the pollution from fossil -fuel -fired electric generators, the overall
impact of solar development on human health is overwhelmingly positive. This pollution reduction results
from a partial replacement of fossil -fuel fired generation by emission -free PV -generated electricity, which
reduces harmful sulfur dioxide (SO2), nitrogen oxides (NO,,), and fine particulate matter (PM2.5). Analysis
from the National Renewable Energy Laboratory and the Lawrence Berkeley National Laboratory, both
affiliates of the U.S. Department of Energy, estimates the health-related air quality benefits to the southeast
region from solar PV generators to be worth 8.0 ¢ per kilowatt-hour of solar generation..' This is in addition
to the value of the electricity and suggests that the air quality benefits of solar are worth more than the
electricity itself.
Even though we have only recently seen large-scale installation of PV technologies, the technology
and its potential impacts have been studied since the 1950s. A combination of this solar -specific research
and general scientific research has led to the scientific community having a good understanding of the
science behind potential health and safety impacts of solar energy. This paper utilizes the latest scientific
literature and knowledge of solar practices in N.C. to address the health and safety risks associated with
solar PV technology. These risks are extremely small, far less than those associated with common
activities such as driving a car, and vastly outweighed by health benefits of the generation of clean
electricity.
This paper addresses the potential health and safety impacts of solar PV development in North
Carolina, organized into the following four categories:
(1) Hazardous Materials
(2) Electromagnetic Fields (EMF)
(3) Electric Shock and Arc Flash
(4) Fire Safety
1. Hazardous Materials
One of the more common concerns towards solar is that the panels (referred to as "modules" in
the solar industry) consist of toxic materials that endanger public health. However, as shown in this
section, solar energy systems may contain small amounts of toxic materials, but these materials do not
endanger public health. To understand potential toxic hazards coming from a solar project, one must
understand system installation, materials used, the panel end -of -life protocols, and system operation. This
section will examine these aspects of a solar farm and the potential for toxicity impacts in the following
subsections:
(1.2) Project Installation/Construction
(1.2) System Components
1.2.1 Solar Panels: Construction and Durability
1.2.2 Photovoltaic technologies
(a) Crystalline Silicon
(b) Cadmium Telluride (CdTe)
(c) CIS/CIGS
1.2.3 Panel End of Life Management
1.2.4 Non -panel System Components
(1.3) Operations and Maintenance
1.1 Project Installation/Construction
The system installation, or construction, process does not require toxic chemicals or processes.
The site is mechanically cleared of large vegetation, fences are constructed, and the land is surveyed to
layout exact installation locations. Trenches for underground wiring are dug and support posts are driven
into the ground. The solar panels are bolted to steel and aluminum support structures and wired together.
Inverter pads are installed, and an inverter and transformer are installed on each pad. Once everything is
connected, the system is tested, and only then turned on.
Figure 1: Utility -scale solar facility (S MWAc) located in Catawba County. Source: Strata Solar
2
1.2 System Components
1.2.1 Solar Panels: Construction and Durability
Solar PV panels typically consist of glass, polymer, aluminum, copper, and semiconductor
materials that can be recovered and recycled at the end of their useful life. 2 Today there are two PV
technologies used in PV panels at utility -scale solar facilities, silicon, and thin film. As of 2016, all thin
film used in North Carolina solar facilities are cadmium telluride (CdTe) panels from the US manufacturer
First Solar, but there are other thin film PV panels available on the market, such as Solar Frontier's CIGS
panels. Crystalline silicon technology consists of silicon wafers which are made into cells and assembled
into panels, thin film technologies consist of thin layers of semiconductor material deposited onto glass,
polymer or metal substrates. While there are differences in the components and manufacturing processes
of these two types of solar technologies, many aspects of their PV panel construction are very similar.
Specifics about each type of PV chemistry as it relates to toxicity are covered in subsections a, b, and c in
section 1.2.2; on crystalline silicon, cadmium telluride, and CIS/CIGS respectively. The rest of this section
applies equally to both silicon and thin film panels.
Aluminum Frame
Sealing
/ Glass
Tedlar Film
Figure 2: Components of crystalline silicon panels.
The vast majority of silicon panels consist of a glass
sheet on the topside with an aluminum frame providing
structural support. Image Source:
www.riteksolar.com.tw
Figure 3: Layers of a common frameless thin-film
panel (CdTe). Many thin film panels are frameless,
including the most common thin-film panels, First
Solar's CdTe. Frameless panels have protective glass
on both the front and back of the panel. Layer
thicknesses not to scale. Image Source:
www.homepower.com
To provide decades of corrosion -free operation, PV cells in PV panels are encapsulated from air
and moisture between two layers of plastic. The encapsulation layers are protected on the top with a
layer of tempered glass and on the backside with a polymer sheet. Frameless modules include a
protective layer of glass on the rear of the panel, which may also be tempered. The plastic ethylene -vinyl
acetate (EVA) commonly provides the cell encapsulation. For decades, this same material has been used
between layers of tempered glass to give car windshields and hurricane windows their great strength. In
the same way that a car windshield cracks but stays intact, the EVA layers in PV panels keep broken
panels intact (see Figure 4). Thus, a damaged module does not generally create small pieces of debris;
instead, it largely remains together as one piece.
Transparent
_—Conductive
Front Glass l�
Oxide ITCOI
Cadmium
Cadmium
Telluride (CdTe)
Sulfide {CdSI
Encapsulant
Back
Electrode
Sack Glass
Figure 3: Layers of a common frameless thin-film
panel (CdTe). Many thin film panels are frameless,
including the most common thin-film panels, First
Solar's CdTe. Frameless panels have protective glass
on both the front and back of the panel. Layer
thicknesses not to scale. Image Source:
www.homepower.com
To provide decades of corrosion -free operation, PV cells in PV panels are encapsulated from air
and moisture between two layers of plastic. The encapsulation layers are protected on the top with a
layer of tempered glass and on the backside with a polymer sheet. Frameless modules include a
protective layer of glass on the rear of the panel, which may also be tempered. The plastic ethylene -vinyl
acetate (EVA) commonly provides the cell encapsulation. For decades, this same material has been used
between layers of tempered glass to give car windshields and hurricane windows their great strength. In
the same way that a car windshield cracks but stays intact, the EVA layers in PV panels keep broken
panels intact (see Figure 4). Thus, a damaged module does not generally create small pieces of debris;
instead, it largely remains together as one piece.
fir
Figure 4: The mangled PV panels in this picture illustrate the nature of broken solar panels; the glass cracks but the panel is
still in one piece. Image Source: http://img.alibaba.com/Photo/l15259576/broken—solar�anel.jpg
PV panels constructed with the same basic components as modern panels have been installed
across the globe for well over thirty years .3 The long-term durability and performance demonstrated
over these decades, as well as the results of accelerated lifetime testing, helped lead to an industry -
standard 25 -year power production warranty for PV panels. These power warranties warrant a PV panel
to produce at least 80% of their original nameplate production after 25 years of use. A recent SolarCity
and DNV GL study reported that today's quality PV panels should be expected to reliably and
efficiently produce power for thirty-five years..4
Local building codes require all structures, including ground mounted solar arrays, to be
engineered to withstand anticipated wind speeds, as defined by the local wind speed requirements. Many
racking products are available in versions engineered for wind speeds of up to 150 miles per hour, which
is significantly higher than the wind speed requirement anywhere in North Carolina. The strength of PV
mounting structures were demonstrated during Hurricane Sandy in 2012 and again during Hurricane
Matthew in 2016. During Hurricane Sandy, the many large-scale solar facilities in New Jersey and New
York at that time suffered only minor damage..5 In the fall of 2016, the US and Caribbean experienced
destructive winds and torrential rains from Hurricane Matthew, yet one leading solar tracker
manufacturer reported that their numerous systems in the impacted area received zero damage from
wind or flooding..6
In the event of a catastrophic event capable of damaging solar equipment, such as a tornado, the
system will almost certainly have property insurance that will cover the cost to cleanup and repair the
project. It is in the best interest of the system owner to protect their investment against such risks. It is
also in their interest to get the project repaired and producing full power as soon as possible. Therefore,
the investment in adequate insurance is a wise business practice for the system owner. For the same
E
reasons, adequate insurance coverage is also generally a requirement of the bank or firm providing
financing for the project.
1.2.2 Photovoltaic (PV) Technologies
a. Crystalline Silicon
This subsection explores the toxicity of silicon -based PV panels and concludes that they do not
pose a material risk of toxicity to public health and safety. Modern crystalline silicon PV panels, which
account for over 90% of solar PV panels installed today, are, more or less, a commodity product. The
overwhelming majority of panels installed in North Carolina are crystalline silicon panels that are
informally classified as Tier I panels. Tier I panels are from well-respected manufacturers that have a good
chance of being able to honor warranty claims. Tier I panels are understood to be of high quality, with
predictable performance, durability, and content. Well over 80% (by weight) of the content of a PV panel
is the tempered glass front and the aluminum frame, both of which are common building materials. Most
of the remaining portion are common plastics, including polyethylene terephthalate in the backsheet, EVA
encapsulation of the PV cells, polyphenyl ether in the junction box, and polyethylene insulation on the
wire leads. The active, working components of the system are the silicon photovoltaic cells, the small
electrical leads connecting them together, and to the wires coming out of the back of the panel. The
electricity generating and conducting components makeup less than 5% of the weight of most panels. The
PV cell itself is nearly 100% silicon, and silicon is the second most common element in the Earth's crust.
The silicon for PV cells is obtained by high-temperature processing of quartz sand (SiO2) that removes its
oxygen molecules. The refined silicon is converted to a PV cell by adding extremely small amounts of
boron and phosphorus, both of which are common and of very low toxicity.
The other minor components of the PV cell are also generally benign; however, some contain lead,
which is a human toxicant that is particularly harmful to young children. The minor components include
an extremely thin antireflective coating (silicon nitride or titanium dioxide), a thin layer of aluminum on
the rear, and thin strips of silver alloy that are screen -printed on the front and rear of cell. In order for
the front and rear electrodes to make effective electrical contact with the proper layer of the PV cell, other
materials (called glass frit) are mixed with the silver alloy and then heated to etch the metals into the cell.
This glass frit historically contains a small amount of lead (Pb) in the form of lead oxide. The 60 or 72 PV
cells in a PV panel are connected by soldering thin solder -covered copper tabs from the back of one cell
to the front of the next cell. Traditionally a tin -based solder containing some lead (Pb) is used, but some
manufacturers have switched to lead-free solder. The glass frit and/or the solder may contain trace amounts
of other metals, potentially including some with human toxicity such as cadmium. However, testing to
simulate the potential for leaching from broken panels, which is discussed in more detail below, did not
find a potential toxicity threat from these trace elements. Therefore, the tiny amount of lead in the grass
frit and the solder is the only part of silicon PV panels with a potential to create a negative health impact.
However, as described below, the very limited amount of lead involved and its strong physical and
chemical attachment to other components of the PV panel means that even in worst-case scenarios the
health hazard it poses is insignificant.
As with many electronic industries, the solder in silicon PV panels has historically been a lead-
based solder, often 36% lead, due to the superior properties of such solder. However, recent advances in
lead-free solders have spurred a trend among PV panel manufacturers to reduce or remove the lead in their
panels. According to the 2015 Solar Scorecard from the Silicon Valley Toxics Coalition, a group that
tracks environmental responsibility of photovoltaic panel manufacturers, fourteen companies (increased
from twelve companies in 2014) manufacture PV panels certified to meet the European Restriction of
5
Hazardous Substances (RoHS) standard. This means that the amount of cadmium and lead in the panels
they manufacture fall below the RoHS thresholds, which are set by the European Union and serve as the
world's de facto standard for hazardous substances in manufactured goods. $ The Restriction of Hazardous
Substances (RoHS) standard requires that the maximum concentration found in any homogenous material
in a produce is less than 0.01% cadmium and less than 0.10% lead, therefore, any solder can be no more
than 0.10% lead..9
While some manufacturers are producing PV panels that meet the RoHS standard, there is no
requirement that they do so because the RoHS Directive explicitly states that the directive does not apply
to photovoltaic panels..10 The justification for this is provided in item 17 of the current RoHS Directive:
"The development of renewable forms of energy is one of the Union's key objectives, and the contribution
made by renewable energy sources to environmental and climate objectives is crucial. Directive
2009/28/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of the use
of energy from renewable sources (4) recalls that there should be coherence between those objectives and
other Union environmental legislation. Consequently, this Directive should not prevent the development
of renewable energy technologies that have no negative impact on health and the environment and that
are sustainable and economically viable."
The use of lead is common in our modern economy. However, only about 0.5% of the annual lead
consumption in the U.S. is for electronic solder for all uses; PV solder makes up only a tiny portion of this
0.5%. Close to 90% of lead consumption in the US is in batteries, which do not encapsulate the pounds of
lead contained in each typical automotive battery. This puts the lead in batteries at great risk of leaching
into the environment. Estimates for the lead in a single PV panel with lead-based solder range from 1.6 to
24 grams of lead, with 13g (less than half of an ounce) per panel seen most often in the literature.." At 13
g/panel 12, each panel contains one-half of the lead in a typical 12 -gauge shotgun shell. This amount
equates to roughly 1/750t1i of the lead in a single car battery. In a panel, it is all durably encapsulated from
air or water for the full life of the panel..14
As indicated by their 20 to 30 -year power warranty, PV modules are designed for a long service
life, generally over 25 years. For a panel to comply with its 25 -year power warranty, its internal
components, including lead, must be sealed from any moisture. Otherwise, they would corrode and the
panel's output would fall below power warranty levels. Thus, the lead in operating PV modules is not at
risk of release to the environment during their service lifetime. In extreme experiments, researchers have
shown that lead can leach from crushed or pulverized panels.. 15, 16 However, more real-world tests
designed to represent typical trash compaction that are used to classify waste as hazardous or non-
hazardous show no danger from leaching.. 17, .18 For more information about PV panel end -of -life, see the
Panel Disposal section.
As illustrated throughout this section, silicon -based PV panels do not pose a material threat to
public health and safety. The only aspect of the panels with potential toxicity concerns is the very small
amount of lead in some panels. However, any lead in a panel is well sealed from environmental exposure
for the operating lifetime of the solar panel and thus not at risk of release into the environment.
b. Cadmium Telluride (CdTe) PV Panels
This subsection examines the components of a cadmium telluride (CdTe) PV panel. Research
demonstrates that they pose negligible toxicity risk to public health and safety while significantly reducing
the public's exposure to cadmium by reducing coal emissions. As of mid -2016, a few hundred MWs of
2
cadmium telluride (CdTe) panels, all manufactured by the U.S. company First Solar, have been installed
in North Carolina.
Questions about the potential health and environmental impacts from the use of this PV technology
are related to the concern that these panels contain cadmium, a toxic heavy metal. However, scientific
studies have shown that cadmium telluride differs from cadmium due to its high chemical and thermal
stability..19 Research has shown that the tiny amount of cadmium in these panels does not pose a health or
safety risk..20 Further, there are very compelling reasons to welcome its adoption due to reductions in
unhealthy pollution associated with burning coal. Every GWh of electricity generated by burning coal
produces about 4 grams of cadmium air emissions.. 2 1 Even though North Carolina produces a significant
fraction of our electricity from coal, electricity from solar offsets much more natural gas than coal due to
natural gas plants being able to adjust their rate of production more easily and quickly. If solar electricity
offsets 90% natural gas and 10% coal, each 5 -megawatt (5 MWac, which is generally 7 MWnc) CdTe
solar facility in North Carolina keeps about 157 grams, or about a third of a pound, of cadmium out of our
environment.22, 23
Cadmium is toxic, but all the approximately 7 grams of cadmium in one CdTe panel is in the form
of a chemical compound cadmium telluride, .24 which has 1/100t1' the toxicity of free cadmium .25.
Cadmium telluride is a very stable compound that is non-volatile and non -soluble in water. Even in the
case of a fire, research shows that less than 0.1 % of the cadmium is released when a CdTe panel is exposed
to fire. The fire melts the glass and encapsulates over 99.9% of the cadmium in the molten glass.. 27
It is important to understand the source of the cadmium used to manufacture CdTe PV panels. The
cadmium is a byproduct of zinc and lead refining. The element is collected from emissions and waste
streams during the production of these metals and combined with tellurium to create the CdTe used in PV
panels. If the cadmium were not collected for use in the PV panels or other products, it would otherwise
either be stockpiled for future use, cemented and buried, or disposed of. 28 Nearly all the cadmium in old
or broken panels can be recycled which can eventually serve as the primary source of cadmium for new
29
PV panels..
Similar to silicon -based PV panels, CdTe panels are constructed of a tempered glass front, one
instead of two clear plastic encapsulation layers, and a rear heat strengthened glass backing (together
>98% by weight). The final product is built to withstand exposure to the elements without significant
damage for over 25 years. While not representative of damage that may occur in the field or even at a
landfill, laboratory evidence has illustrated that when panels are ground into a fine powder, very acidic
water is able to leach portions of the cadmium and tellurium,, 0 similar to the process used to recycle CdTe
panels. Like many silicon -based panels, CdTe panels are reported (as far back ask 199831) to pass the
EPA's Toxic Characteristic Leaching Procedure (TCLP) test, which tests the potential for crushed panels
in a landfill to leach hazardous substances into groundwater.. 32 Passing this test means that they are
classified as non -hazardous waste and can be deposited in landfills. 33,34 For more information about PV
panel end -of -life, see the Panel Disposal section.
There is also concern of environmental impact resulting from potential catastrophic events
involving CdTe PV panels. An analysis of worst-case scenarios for environmental impact from CdTe PV
panels, including earthquakes, fires, and floods, was conducted by the University of Tokyo in 2013. After
reviewing the extensive international body of research on CdTe PV technology, their report concluded,
"Even in the worst-case scenarios, it is unlikely that the Cd concentrations in air and sea water will exceed
the environmental regulation values. ,.35 In a worst-case scenario of damaged panels abandoned on the
ground, insignificant amounts of cadmium will leach from the panels. This is because this scenario is
7
much less conducive (larger module pieces, less acidity) to leaching than the conditions of the EPA's
TCLP test used to simulate landfill conditions, which CdTe panels pass.. 36
First Solar, a U.S. company, and the only significant supplier of CdTe panels, has a robust panel
take -back and recycling program that has been operating commercially since 2005._37 The company states
that it is "committed to providing a commercially attractive recycling solution for photovoltaic (PV) power
plant and module owners to help them meet their module (end of life) EOL obligation simply, cost-
effectively and responsibly." First Solar global recycling services to their customers to collect and recycle
panels once they reach the end of productive life whether due to age or damage. These recycling service
agreements are structured to be financially attractive to both First Solar and the solar panel owner. For
First Solar, the contract provides the company with an affordable source of raw materials needed for new
panels and presumably a diminished risk of undesired release of Cd. The contract also benefits the solar
panel owner by allowing them to avoid tipping fees at a waste disposal site. The legal contract helps
provide peace of mind by ensuring compliance by both parties when considering the continuing trend of
rising disposal costs and increasing regulatory requirements.
c. CIS/CIGS and other PV technologies
Copper indium gallium selenide PV technology, often referred to as CIGS, is the second most
common type of thin-film PV panel but a distant second behind CdTe. CIGS cells are composed of a thin
layer of copper, indium, gallium, and selenium on a glass or plastic backing. None of these elements are
very toxic, although selenium is a regulated metal under the Federal Resource Conservation and Recovery
Act (RCRA). 38 The cells often also have an extremely thin layer of cadmium sulfide that contains a tiny
amount of cadmium, which is toxic. The promise of high efficiency CIGS panels drove heavy investment
in this technology in the past. However, researchers have struggled to transfer high efficiency success in
the lab to low-cost full-scale panels in the field..39 Recently, a CIGS manufacturer based in Japan, Solar
Frontier, has achieved some market success with a rigid, glass -faced CIGS module that competes with
silicon panels. Solar Frontier produces the majority of CIS panels on the market today.. 40 Notably, these
panels are RoHS compliant,. thus meeting the rigorous toxicity standard adopted by the European Union
even thought this directive exempts PV panels. The authors are unaware of any completed or proposed
utility -scale system in North Carolina using CIS/CIGS panels.
1.2.3 Panel End -of -Life Management
Concerns about the volume, disposal, toxicity, and recycling of PV panels are addressed in this
subsection. To put the volume of PV waste into perspective, consider that by 2050, when PV systems
installed in 2020 will reach the end of their lives, it is estimated that the global annual PV panel waste
tonnage will be 10% of the 2014 global e -waste tonnage _42 In the U.S., end -of -life disposal of solar
products is governed by the Federal Resource Conservation and Recovery Act (RCRA), as well as state
policies in some situations. RCRA separates waste into hazardous (not accepted at ordinary landfill) and
solid waste (generally accepted at ordinary landfill) based on a series of rules. According to RCRA, the
way to determine if a PV panel is classified as hazardous waste is the Toxic Characteristic Leaching
Procedure (TCLP) test. This EPA test is designed to simulate landfill disposal and determine the risk of
hazardous substances leaching out of the landfill. 43, 44, 4s Multiple sources report that most modern PV
panels (both crystalline silicon and cadmium telluride) pass the TCLP test. 46,41 Some studies found that
some older (1990s) crystalline silicon panels, and perhaps some newer crystalline silicon panels (specifics
are not given about vintage of panels tested), do not pass the lead (Pb) leachate limits in the TCLP test. 48,
49
M
The test begins with the crushing of a panel into centimeter -sized pieces. The pieces are then mixed
in an acid bath. After tumbling for eighteen hours, the fluid is tested for forty hazardous substances that
all must be below specific threshold levels to pass the test. Research comparing TCLP conditions to
conditions of damaged panels in the field found that simulated landfill conditions provide overly
conservative estimates of leaching for field -damaged panels -50 Additionally, research in Japan has found
no detectable Cd leaching from cracked CdTe panels when exposed to simulated acid rain.. 51
Although modern panels can generally be landfilled, they can also be recycled. Even though recent
waste volume has not been adequate to support significant PV -specific recycling infrastructure, the
existing recycling industry in North Carolina reports that it recycles much of the current small volume of
broken PV panels. In an informal survey conducted by the NC Clean Energy Technology Center survey
in early 2016, seven of the eight large active North Carolina utility -scale solar developers surveyed
reported that they send damaged panels back to the manufacturer and/or to a local recycler. Only one
developer reported sending damaged panels to the landfill.
The developers reported at that time that they are usually paid a small amount per panel by local
recycling firms. In early 2017, a PV developer reported that a local recycler was charging a small fee per
panel to recycle damaged PV panels. The local recycling firm known to authors to accept PV panels
described their current PV panel recycling practice as of early 2016 as removing the aluminum frame for
local recycling and removing the wire leads for local copper recycling. The remainder of the panel is sent
to a facility for processing the non-metallic portions of crushed vehicles, referred to as "fluff' in the
recycling industry. 52 This processing within existing general recycling plants allows for significant
material recovery of major components, including glass which is 80% of the module weight, but at lower
yields than PV -specific recycling plants. Notably almost half of the material value in a PV panel is in the
few grams of silver contained in almost every PV panel produced today. In the long-term, dedicated PV
panel recycling plants can increase treatment capacities and maximize revenues resulting in better output
quality and the ability to recover a greater fraction of the useful materials ..53 PV -specific panel recycling
technologies have been researched and implemented to some extent for the past decade, and have been
shown to be able to recover over 95% of PV material (semiconductor) and over 90% of the glass in a PV
panel. .54
A look at global PV recycling trends hints at the future possibilities of the practice in our country.
Europe installed MW -scale volumes of PV years before the U.S. In 2007, a public-private partnership
between the European Union and the solar industry set up a voluntary collection and recycling system
called PV CYCLE. This arrangement was later made mandatory under the EU's WEEE directive, a
program for waste electrical and electronic equipment..55 Its member companies (PV panel producers)
fully finance the association. This makes it possible for end-users to return the member companies'
defective panels for recycling at any of the over 300 collection points around Europe without added costs.
Additionally, PV CYCLE will pick up batches of 40 or more used panels at no cost to the user. This
arrangement has been very successful, collecting and recycling over 13,000 tons by the end of 2015.66
In 2012, the WEEE Directive added the end -of -life collection and recycling of PV panels to its
scope _57 This directive is based on the principle of extended -producer -responsibility. It has a global impact
because producers that want to sell into the EU market are legally responsible for end -of -life management.
Starting in 2018, this directive targets that 85% of PV products "put in the market" in Europe are recovered
and 80% is prepared for reuse and recycling.
The success of the PV panel collection and recycling practices in Europe provides promise for the
future of recycling in the U.S. In mid -2016, the US Solar Energy Industry Association (SEIA) announced
that they are starting a national solar panel recycling program with the guidance and support of many
0
leading PV panel producers. 58 The program will aggregate the services offered by recycling vendors and
PV manufacturers, which will make it easier for consumers to select a cost-effective and environmentally
responsible end -of -life management solution for their PV products. According to SEIA, they are planning
the program in an effort to make the entire industry landfill -free. In addition to the national recycling
network program, the program will provide a portal for system owners and consumers with information
on how to responsibly recycle their PV systems.
While a cautious approach toward the potential for negative environmental and/or health impacts
from retired PV panels is fully warranted, this section has shown that the positive health impacts of
reduced emissions from fossil fuel combustion from PV systems more than outweighs any potential risk.
Testing shows that silicon and CdTe panels are both safe to dispose of in landfills, and are also safe in
worst case conditions of abandonment or damage in a disaster. Additionally, analysis by local engineers
has found that the current salvage value of the equipment in a utility scale PV facility generally exceeds
general contractor estimates for the cost to remove the entire PV system.. 59, 60, 61
1.2.4 Non -Panel System Components (racking, wiring, inverter, transformer)
While previous toxicity subsections discussed PV panels, this subsection describes the non -panel
components of utility -scale PV systems and investigates any potential public health and safety concerns.
The most significant non -panel component of a ground -mounted PV system is the mounting structure of
the rows of panels, commonly referred to as "racking". The vertical post portion of the racking is
galvanized steel and the remaining above -ground racking components are either galvanized steel or
aluminum, which are both extremely common and benign building materials. The inverters that make the
solar generated electricity ready to send to the grid have weather-proof steel enclosures that protect the
working components from the elements. The only fluids that they might contain are associated with their
cooling systems, which are not unlike the cooling system in a computer. Many inverters today are RoHS
compliant.
The electrical transformers (to boost the inverter output voltage to the voltage of the utility
connection point) do contain a liquid cooling oil. However, the fluid used for that function is either a non-
toxic mineral oil or a biodegradable non-toxic vegetable oil, such as BIOTEMP from ABB. These
vegetable transformer oils have the additional advantage of being much less flammable than traditional
mineral oils. Significant health hazards are associated with old transformers containing cooling oil with
toxic PCBs. Transfers with PCB -containing oil were common before PCBs were outlawed in the U.S. in
1979. PCBs still exist in older transformers in the field across the country.
Other than a few utility research sites, there are no batteries on- or off-site associated with utility -
scale solar energy facilities in North Carolina, avoiding any potential health or safety concerns related to
battery technologies. However, as battery technologies continue to improve and prices continue to decline
we are likely to start seeing some batteries at solar facilities. Lithium ion batteries currently dominate the
world utility -scale battery market, which are not very toxic. No non -panel system components were found
to pose any health or environmental dangers.
1.4 Operations and Maintenance — Panel Washing and Vegetation
Control
Throughout the eastern U.S., the climate provides frequent and heavy enough rain to keep panels
adequately clean. This dependable weather pattern eliminates the need to wash the panels on a regular
basis. Some system owners may choose to wash panels as often as once a year to increase production,
but most in N.C. do not regularly wash any PV panels. Dirt build up over time may justify panel
washing a few times over the panels' lifetime; however, nothing more than soap and water are required
for this activity.
The maintenance of ground -mounted PV facilities requires that vegetation be kept low, both for
aesthetics and to avoid shading of the PV panels. Several approaches are used to maintain vegetation at
NC solar facilities, including planting of limited -height species, mowing, weed -eating, herbicides, and
grazing livestock (sheep). The following descriptions of vegetation maintenance practices are based on
interviews with several solar developers as well as with three maintenance firms that together are
contracted to maintain well over 100 of the solar facilities in N.C. The majority of solar facilities in
North Carolina maintain vegetation primarily by mowing. Each row of panels has a single row of
supports, allowing sickle mowers to mow under the panels. The sites usually require mowing about once
a month during the growing season. Some sites employ sheep to graze the site, which greatly reduces the
human effort required to maintain the vegetation and produces high quality lamb meat. 62
In addition to mowing and weed eating, solar facilities often use some herbicides. Solar facilities
generally do not spray herbicides over the entire acreage; rather they apply them only in strategic
locations such as at the base of the perimeter fence, around exterior vegetative buffer, on interior dirt
roads, and near the panel support posts. Also unlike many row crop operations, solar facilities generally
use only general use herbicides, which are available over the counter, as opposed to restricted use
herbicides commonly used in commercial agriculture that require a special restricted use license. The
herbicides used at solar facilities are primarily 2-4-D and glyphosate (Round -up®), which are two of the
most common herbicides used in lawns, parks, and agriculture across the country. One maintenance firm
that was interviewed sprays the grass with a class of herbicide known as a growth regulator in order to
slow the growth of grass so that mowing is only required twice a year. Growth regulators are commonly
used on highway roadsides and golf courses for the same purpose. A commercial pesticide applicator
license is required for anyone other than the landowner to apply herbicides, which helps ensure that all
applicators are adequately educated about proper herbicide use and application. The license must be
renewed annually and requires passing of a certification exam appropriate to the area in which the
applicator wishes to work. Based on the limited data available, it appears that solar facilities in N.C.
generally use significantly less herbicides per acre than most commercial agriculture or lawn
maintenance services.
2. Electromagnetic Fields (EMF)
PV systems do not emit any material during their operation; however, they do generate
electromagnetic fields (EMF), sometimes referred to as radiation. EMF produced by electricity is non -
ionizing radiation, meaning the radiation has enough energy to move atoms in a molecule around
(experienced as heat), but not enough energy to remove electrons from an atom or molecule (ionize) or to
damage DNA. As shown below, modern humans are all exposed to EMF throughout our daily lives
without negative health impact. Someone outside of the fenced perimeter of a solar facility is not exposed
to significant EMF from the solar facility. Therefore, there is no negative health impact from the EMF
11
produced in a solar farm. The following paragraphs provide some additional background and detail to
support this conclusion.
Since the 1970s, some have expressed concern over potential health consequences of EMF from
electricity, but no studies have ever shown this EMF to cause health problems._63 These concerns are based
on some epidemiological studies that found a slight increase in childhood leukemia associated with
average exposure to residential power -frequency magnetic fields above 0.3 to 0.4 gT (microteslas) (equal
to 3.0 to 4.0 mG (milligauss)). gT and mG are both units used to measure magnetic field strength. For
comparison, the average exposure for people in the U.S. is one mG or 0.1 J, with about 1% of the
population with an average exposure in excess of 0.4 gT (or 4 mG)..64 These epidemiological studies,
which found an association but not a causal relationship, led the World Health Organization's International
Agency for Research on Cancer (IARC) to classify ELF magnetic fields as "possibly carcinogenic to
humans". Coffee also has this classification. This classification means there is limited evidence but not
enough evidence to designate as either a "probable carcinogen" or "human carcinogen". Overall, there is
very little concern that ELF EMF damages public health. The only concern that does exist is for long-term
exposure above 0.4 gT (4 mG) that may have some connection to increased cases of childhood leukemia.
In 1997, the National Academies of Science were directed by Congress to examine this concern and
concluded:
"Based on a comprehensive evaluation of published studies relating to the effects of
power -frequency electric and magnetic fields on cells, tissues, and organisms (including
humans), the conclusion of the committee is that the current body of evidence does not
show that exposure to these fields presents a human -health hazard. Specifically, no
conclusive and consistent evidence shows that exposures to residential electric and
magnetic fields produce cancer, adverse neurobehavioral effects, or reproductive and
developmental effects." 65
There are two aspects to electromagnetic fields, an electric field and a magnetic field. The electric
field is generated by voltage and the magnetic field is generated by electric current, i.e., moving electrons.
A task group of scientific experts convened by the World Health Organization (WHO) in 2005 concluded
that there were no substantive health issues related to electric fields (0 to 100,000 Hz) at levels generally
encountered by members of the public. 66 The relatively low voltages in a solar facility and the fact that
electric fields are easily shielded (i.e., blocked) by common materials, such as plastic, metal, or soil means
that there is no concern of negative health impacts from the electric fields generated by a solar facility.
Thus, the remainder of this section addresses magnetic fields. Magnetic fields are not shielded by most
common materials and thus can easily pass through them. Both types of fields are strongest close to the
source of electric generation and weaken quickly with distance from the source.
The direct current (DC) electricity produced by PV panels produce stationary (0 Hz) electric and
magnetic fields. Because of minimal concern about potential risks of stationary fields, little scientific
research has examined stationary fields' impact on human health..67 In even the largest PV facilities, the
DC voltages and currents are not very high. One can illustrate the weakness of the EMF generated by a
PV panel by placing a compass on an operating solar panel and observing that the needle still points north.
While the electricity throughout the majority of a solar site is DC electricity, the inverters convert
this DC electricity to alternating current (AC) electricity matching the 60 Hz frequency of the grid.
Therefore, the inverters and the wires delivering this power to the grid are producing non -stationary EMF,
known as extremely low frequency (ELF) EMF, normally oscillating with a frequency of 60 Hz. This
frequency is at the low-energy end of the electromagnetic spectrum. Therefore, it has less energy than
12
other commonly encountered types of non -ionizing radiation like radio waves, infrared radiation, and
visible light.
The wide use of electricity results in background levels of ELF EMFs in nearly all locations where
people spend time — homes, workplaces, schools, cars, the supermarket, etc. A person's average exposure
depends upon the sources they encounter, how close they are to them, and the amount of time they spend
there _68 As stated above, the average exposure to magnetic fields in the U.S. is estimated to be around one
mG or 0.1 µT, but can vary considerably depending on a person's exposure to EMF from electrical devices
and wiring.. 69 At times we are often exposed to much higher ELF magnetic fields, for example when
standing three feet from a refrigerator the ELF magnetic field is 6 mG and when standing three feet from
a microwave oven the field is about 50 mG..70 The strength of these fields diminish quickly with distance
from the source, but when surrounded by electricity in our homes and other buildings moving away from
one source moves you closer to another. However, unless you are inside of the fence at a utility -scale solar
facility or electrical substation it is impossible to get very close to the EMF sources. Because of this, EMF
levels at the fence of electrical substations containing high voltages and currents are considered "generally
negligible".. 71, 72
The strength of ELF -EMF present at the perimeter of a solar facility or near a PV system in a
commercial or residential building is significantly lower than the typical American's average EMF
exposure. 73°74 Researchers in Massachusetts measured magnetic fields at PV projects and found the
magnetic fields dropped to very low levels of 0.5 mG or less, and in many cases to less than background
levels (0.2 mG), at distances of no more than nine feet from the residential inverters and 150 feet from the
utility -scale inverters .75 Even when measured within a few feet of the utility -scale inverter, the ELF
magnetic fields were well below the International Commission on Non -Ionizing Radiation Protection's
recommended magnetic field level exposure limit for the general public of 2,000 mG.. 76 It is typical that
utility scale designs locate large inverters central to the PV panels that feed them because this minimizes
the length of wire required and shields neighbors from the sound of the inverter's cooling fans. Thus, it is
rare for a large PV inverter to be within 150 feet of the project's security fence.
Anyone relying on a medical device such as pacemaker or other implanted device to maintain
proper heart rhythm may have concern about the potential for a solar project to interfere with the operation
of his or her device. However, there is no reason for concern because the EMF outside of the solar facility's
fence is less than 1/1000 of the level at which manufacturers test for ELF EMF interference, which is
1,000 mG..77 Manufacturers of potentially affected implanted devices often provide advice on
electromagnetic interference that includes avoiding letting the implanted device get too close to certain
sources of fields such as some household appliances, some walkie-talkies, and similar transmitting
devices. Some manufacturers' literature does not mention high-voltage power lines, some say that
exposure in public areas should not give interference, and some advise not spending extended periods of
time close to power lines. 78
3. Electric Shock and Arc Flash Hazards
There is a real danger of electric shock to anyone entering any of the electrical cabinets such as
combiner boxes, disconnect switches, inverters, or transformers; or otherwise coming in contact with
voltages over 50 Volts. 79 Another electrical hazard is an arc flash, which is an explosion of energy that
can occur in a short circuit situation. This explosive release of energy causes a flash of heat and a
shockwave, both of which can cause serious injury or death. Properly trained and equipped technicians
and electricians know how to safely install, test, and repair PV systems, but there is always some risk of
13
injury when hazardous voltages and/or currents are present. Untrained individuals should not attempt to
inspect, test, or repair any aspect of a PV system due to the potential for injury or death due to electric
shock and arc flash, The National Electric Code (NEC) requires appropriate levels of warning signs on all
electrical components based on the level of danger determined by the voltages and current potentials. The
national electric code also requires the site to be secured from unauthorized visitors with either a six-foot
chain link fence with three strands of barbed wire or an eight -foot fence, both with adequate hazard
warning signs.
4. Fire Safety
The possibility of fires resulting from or intensified by PV systems may trigger concern among
the general public as well as among firefighters. However, concern over solar fire hazards should be
limited because only a small portion of materials in the panels are flammable, and those components
cannot self-support a significant fire. Flammable components of PV panels include the thin layers of
polymer encapsulates surrounding the PV cells, polymer backsheets (framed panels only), plastic junction
boxes on rear of panel, and insulation on wiring. The rest of the panel is composed of non-flammable
components, notably including one or two layers of protective glass that make up over three quarters of
the panel's weight.
Heat from a small flame is not adequate to ignite a PV panel, but heat from a more intense fire or
energy from an electrical fault can ignite a PV panel.,80 One real-world example of this occurred during
July 2015 in an and area of California. Three acres of grass under a thin film PV facility burned without
igniting the panels mounted on fixed -tilt racks just above the grass._81 While it is possible for electrical
faults in PV systems on homes or commercial buildings to start a fire, this is extremely rare... 82 Improving
understanding of the PV -specific risks, safer system designs, and updated fire -related codes and standards
will continue to reduce the risk of fire caused by PV systems.
PV systems on buildings can affect firefighters in two primary ways, 1) impact their methods of
fighting the fire, and 2) pose safety hazard to the firefighters. One of the most important techniques that
firefighters use to suppress fire is ventilation of a building's roof. This technique allows superheated toxic
gases to quickly exit the building. By doing so, the firefighters gain easier and safer access to the building,
Ventilation of the roof also makes the challenge of putting out the fire easier. However, the placement of
rooftop PV panels may interfere with ventilating the roof by limiting access to desired venting locations.
New solar -specific building code requirements are working to minimize these concerns. Also, the
latest National Electric Code has added requirements that make it easier for first responders to safely and
effectively turn off a PV system. Concern for firefighting a building with PV can be reduced with proper
fire fighter training, system design, and installation. Numerous organizations have studied fire fighter
safety related to PV. Many organizations have published valuable guides and training programs. Some
notable examples are listed below.
• The International Association of Fire Fighters (IAFF) and International Renewable Energy Council
(IREC) partnered to create an online training course that is far beyond the PowerPoint click -and -
view model. The self -paced online course, "Solar PV Safety for Fire Fighters," features rich video
content and simulated environments so fire fighters can practice the knowledge they've learned.
www.iaff.org/pvsafe!yLraining
• Photovoltaic Systems and the Fire Code: Office of NC Fire Marshal
• Fire Service Training, Underwriter's Laboratory
14
• Firefighter Safety and Response for Solar Power Systems, National Fire Protection Research
Foundation
• Bridgingthe Fire Safety & Green Buildings, National Association of State Fire Marshalls
• Guidelines for Fire Safety Elements of Solar Photovoltaic Systems, Orange County Fire Chiefs
Association
• Solar Photovoltaic Installation Guidelines, California Department of Forestry & Fire Protection,
Office of the State Fire Marshall
• PV Safety & Firefighting, Matthew Paiss, Homepower Magazine
• PV Safety and Code Development: Matthew Paiss, Cooperative Research Network
Summary
The purpose of this paper is to address and alleviate concerns of public health and safety for
utility -scale solar PV projects. Concerns of public health and safety were divided and discussed in the
four following sections: (1) Toxicity, (2) Electromagnetic Fields, (3) Electric Shock and Arc Flash, and
(4) Fire. In each of these sections, the negative health and safety impacts of utility -scale PV
development were shown to be negligible, while the public health and safety benefits of installing these
facilities are significant and far outweigh any negative impacts.
' Wiser, Ryan, Trieu Mai, Dev Millstein, Jordan Macknick, Alberta Carpenter, Stuart Cohen, Wesley Cole, Bethany Frew,
and Garvin A. Heath. 2016. On the Path to SunShot: The Environmental and Public Health Benefits of Achieving High
Penetrations of Solar Energy in the United States. Golden, CO: National Renewable Energy Laboratory. Accessed March
2017, www.nrel.gov/docs/fyl6osti/65628.pdf
2 IRENA and IEA-PVPS (2016), "End -of -Life Management: Solar Photovoltaic Panels," International Renewable Energy
Agency and International Energy Agency Photovoltaic Power Systems.
s National Renewable Energy Laboratory, Overview of Field Experience — Degradation Rates & Lifetimes. September 14,
2015. Solar Power International Conference. Accessed March 2017, www.nrel.gov/docs/fyl5osti/65040.pdf
4 Miesel et al. SolarCity Photovoltaic Modules with 35 Year Useful Life. June 2016. Accessed March 2017.
http://www. solarcity.com/newsroom/reports/solarcity-photovoltaic-modules-35-year-useful-life
5 David Unger. Are Renewables Stormproof? Hurricane Sandy Tests Solar, Wind. November 2012. Accessed March 2017.
http://www.csmonitor.com/Environment/Energy-Voices/2012/ 1119/Are-renewables-stormproof-Hurricane-Sandy-tests-solar-
wind & http://www.csmonitor.com/Environment/Energy-Voices/2012/1119/Are-renewables-stormproof-Hurricane-Sandy-
tests-solar-wind
6 NEXTracker and 365 Pronto, Tracking Your Solar Investment: Best Practices for Solar Tracker O&M. Accessed March
2017. www.nextracker.com/content/uploads/2017/03/NEXTracker_OandM-WhitePaper_FINAL_March-2017.pdf
Christiana Honsberg, Stuart Bowden. Overview of Screen Printed Solar Cells. Accessed January 2017.
www.pveducation.org/pvcdroni/manufacturing/screen-printed
a Silicon Valley Toxics Coalition. 2015 Solar Scorecard. Accessed August 2016. www.solarscorecard.com/2015/2015-
SVTC-Solar-Scorecard.pdf
9 European Commission. Recast of Reduction of Hazardous Substances (RoHS) Directive. September 2016. Accessed August
2016. http://ec.europa.eu/environment/waste/rohs_eee/index_en.htm
10 Official Journal of the European Union, DIRECTIVE 20111651EU OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic
equipment. June 2011. Accessed May 2017. http://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32011 L0065&from—en
11 Giancarlo Giacchetta, Mariella Leporini, Barbara Marchetti. Evaluation of the Environmental Benefits of New High Value
Process for the Management of the End of Life of Thin Film Photovoltaic Modules. July 2013. Accessed August 2016.
www.researchgate.net/publication/257408804_Evaluation_of_the_environmental_benefits_ of new high_ value—process_for
the—management—of the—end—of life—of thin film_photovoltaic modules
15
12 European Commission. Study on Photovoltaic Panels Supplementing The Impact Assessment for a Recast of the Weee
Directive. April 2011. Accessed August 2016.
http: //ec. europ a. eu/environment/waste/weee/p df/Study%20 on%20P V s%20B io%20 final.p df
" The amount of lead in a typical car battery is 21.4 pounds. Waste 360. Chaz Miller. Lead Acid Batteries. March 2006.
Accessed August 2016. http://waste360.com/mag/waste_leadacid_batteries_3
1s Okkenhaug G. Leaching from CdTe PV module material results from batch, column and availability tests. Norwegian
Geotechnical Institute, NGI report No. 20092155-00-6-R; 2010
16 International Journal of Advanced Applied Physics Research. Renate Zapf-Gottwickl, et al. Leaching Hazardous
Substances out of Photovoltaic Modules. January 2015. Accessed January 2016.
www.cosmosscholars.com/phms/index.php/ij aapr/article/download/485/298
17 ibid
" Parikhit Sinha, et al. Evaluation of Potential Health and Environmental Impacts from End -Of -Life Disposal of
Photovoltaics, Photovoltaics, 2014. Accessed May 2016
19 Bonnet, D. and P. Meyers. 1998. Cadmium -telluride Material for thin film solar cells. J. Mater. Res., Vol. 13, No. 10, pp.
2740-2753
" V. Fthenakis, K. Zweibel. CdTe PV: Real and Perceived EHS Risks. National Center ofr Photovoltaics and Solar Program
Review Meeting, March 24-26,2003. www.nrel.gov/docs/fy03osti/33561.pdf. Accessed May 2017
21 International Energy Agency Photovoltaic Power Systems Programme. Life Cycle Inventories and Life Cycle Assessments
of Photovoltaic Systems. March 2015. Accessed August 2016. http://iea-pvps.org/index.php?id=315
22 Data not available on fraction of various generation sources offset by solar generation in NC, but this is believed to be a
reasonable rough estimate. The SunShot report entitled The Environmental and Public Health Benefits of Achieving High
Penetrations of Solar Energy in the United States analysis contributes significant (% not provided) offsetting of coal-fired
generation by solar PV energy in the southeast.
23 7 MWDc * 1.5 GWh/MWDc * 25 years * 0.93 degradation factor * (0.1 *4.65 grams/GWh + 0.9*0.2 grams/GWh)
21 Vasilis Fthenakis. CdTe PV: Facts and Handy Comparisons. January 2003. Accessed March 2017.
https://www.bnl.gov/pv/files/pdf/art_ 165.pdf
2s Kaczmar, S., Evaluating the Read -Across Approach on CdTe Toxicityfor CdTe Photovoltaics, SETAC North America
32nd Annual Meeting, Boston, MA, November 2011. Available at: ftp://ftp.co.imperial.ca.us/icpds/eir/campo-verde-
solar/final/evaluating-toxicity.pdf, Accessed May 2017
27 V. M. Fthenakis et al, Emissions and Encapsulation of Cadmium in CdTe PV Modules During Fires Renewable Progress in
Photovoltaics: Research and Application: Res. Appl. 2005; 13:1-11, Accessed March 2017,
www.bnl.gov/pv/files/pdf/abs_ 179.pdf
26 Fthenakis V.M., Life Cycle Impact Analysis of Cadmium in CdTe Photovoltaic Production, Renewable and Sustainable
Energy Reviews, 8, 303-334, 2004.
www. cica. columbia. edu/papers/Life_Cycle_Impact_Analysi s_Cadmium_CdTe_Photovoltaic_productio
n.pdf, Accessed May 2017
29 International Renewable Energy Agency. Stephanie Weekend, Andreas Wade, Garvin Heath. End of Life Management:
Solar Photovoltaic Panels. June 2016. Accessed November 2016.
30 International Journal of Advanced Applied Physics Research. Renate Zapf-Gottwickl, et al. Leaching Hazardous
Substances out of Photovoltaic Modules. January 2015. Accessed January 2016.
www.cosmosscholars.com/phms/index.php/ij aapr/article/download/485/298
31 Cunningham D., Discussion about TCLP protocols, Photovoltaics and the Environment Workshop, July 23-24, 1998,
Brookhaven National Laboratory, BNL -52557
32 Parikhit Sinha, et al. Evaluation of Potential Health and Environmental Impacts from End -Of -Life Disposal of
Photovoltaics, Photovoltaics, 2014. Accessed May 2016
33 Practical Handbook of Photovoltaics: Fundamentals and Applications. T. Markvart and L. Castaner. Chapter VII -2:
Overview of Potential Hazards. December 2003. Accessed August 2016. https://www.bnl.gov/pv/files/pdf/art_170.pdf
3' Norwegian Geotechnical Institute. Environmental Risks Regarding the Use and End -of -Life Disposal of CdTe PV Modules.
April 2010. Accessed August 2016. https://www.dtsc.ca.gov/LawsRegsPolicies/upload/Norwegian-Geotechnical-Institute-
Study.pdf
3s First Solar. Dr. Yasunari Matsuno. December 2013. August 2016. Environmental Risk Assessment of CdTe PV Systems to
be considered under Catastrophic Events in Japan. http://www.firstsolar.com/-/media/Documents/Sustainability/Peer-
Reviews/Japan_Peer-Review_Matsuno_CdTe-P V -Tsunami. ashx
36 First Solar. Parikhit Sinha, Andreas Wade. Assessment of Leaching Tests for Evaluating Potential Environmental Impacts
of PV Module Field Breakage. 2015 IEEE
37 See p. 22 of First Solar, Sustainability Report. Available at: www.firstsolar.com/-/media/First-
Solar/Sustainability-Documents/03801_FirstSolar_SustainabilityReport_08MAR16_Web.ashx, Accessed
May 2017
16
38 40 CFR §261.24. Toxicity Characteristic. May 2017. Accessed May 2017. https://www.ecfr.gov/cgi-bin/text-
idx?node=se40.26.261 124&rgn--div8
" Office of Energy Efficiency & Renewable Energy. Copper Indium Gallium Diselenide. Accessed March 2017.
https: //www. energy. gov/eere/sunshot/copper-indium-gallium-diselenide
41 Mathias Maehlum. Best Thin Film Solar Panels - Amorphous, Cadmium Telluride or GIGS? April 2015. Accessed March
2017. http://energyinformative.org/best-thin-film-solar-panels-amorphous-cadmium-telluride-cigs/
41 RoHS tested certificate for Solar Frontier PV modules. TUVRheinland, signed 11. 11.2013
42 International Renewable Energy Agency. Stephanie Weckend, Andreas Wade, Garvin Heath. End of Life Management:
Solar Photovoltaic Panels. June 2016. Accessed November 2016.
http://www. irena.org/DocumentDownloads/Publications/IRENA_IEAPVPS_End-of-Life_ Solar_PV_Panels_2016.pdf
4140 C.F.R. §261.10. Identifying the Characteristics of Hazardous Waste and for Listing Hazardous Waste. November 2016.
Accessed November 2016 http://www.ecfr.gov/cgi-bin/text-
idx?SID=ce0006d66da40146b490084ca2816143 &mc=true&node=pt40.26.261 &rgn=div5#sp40.28.261.b
44 40 C.F.R. §261.24 Toxicity Characteristic. November 2016. Accessed November 2016. http://www.ecfr.gov/cgi-bin/text-
idx?SID=ce0006d66da40146b490084ca2816143 &mc=true&node=pt40.26.261 &rgn=div5#se40.28.261 _124
45 International Renewable Energy Agency. Stephanie Weckend, Andreas Wade, Garvin Heath. End of Life Management:
Solar Photovoltaic Panels. June 2016. Accessed November 2016.
http://www.irena.org/DocumentDownloads/Publications/IRENA_IEAPVPS End-of-Life_Solar_PV_Panels_2016.pdf
46 TLCP test results from third -party laboratories for REC, Jinko, and Canadian Solar silicon -based panels. Provided by PV
panel manufacturers directly or indirectly to authors
41 Sinovoltaics, Introduction to Solar Panel Recycling, March 2014. Accessed October 2016. http://sinovoltaics.com/solar-
basics/introduction-to-solar-panel-recycling/
48 Brookhaven National Laboratory. Vasilis Fthenakis, Regulations on Photovoltaic Module Disposal and Recycling. January
29, 2001.
49 Parikhit Sinha, et al. Evaluation of Potential Health and Environmental Impacts from End -Of -Life Disposal of
Photovoltaics, Photovoltaics, 2014.
so First Solar. Parikhit Sinha, Andreas Wade. Assessment of Leaching Tests for Evaluating Potential Environmental Impacts
ofPVModule Field Breakage. October 2015. Accessed August 2016. http://www.firstsolar.com/-
/media/Documents/Sustainability/P V SC42-Manuscript-20150912--Assessment-of-Leaching-Tests-for-Evaluating-Potential-
Environmental-Imp a. ashx
51 First Solar. Dr. Yasunari Matsuno. December 2013. Environmental Risk Assessment of CdTe PV Systems to be considered
under Catastrophic Events in Japan. http://www.firstsolar.com/-/media/Documents/Sustainability/Peer-
Reviews/Japan-Peer-Review_Matsuno_CdTe-P V -Tsunami. ashx
s2 Phone interview, February 3, 2016, TT&E Iron & Metal, Garner, NC www.ncscrapmetal.com/
s3 Wen -His Huang, et al. Strategy and Technology To Recycle Water -silicon Solar Modules. Solar Energy, Volume 144,
March 2017, Pages 22-31
54 International Renewable Energy Agency. Stephanie Weckend, Andreas Wade, Garvin Heath. End of Life Management:
Solar Photovoltaic Panels. June 2016. Accessed November 2016.
http://www. irena.org/DocumentDownloads/Publications/IRENA_IEAPVPS-End-of-Life-Solar_PV_Panels-2016.pdf
55 Official Journal of the European Union. Directive 20121191EU of the European Parliament and of the Council
of 4 July 2012 on Waste Electrical and Electronic Equipment. July 2012. Accessed November 2016. http://eur-
lex. europa. eu/legal-content/EN/TXT/?uri=celex%3 A32012L0019
56 PV CYCLE. Annual Report 2015. Accessed November 2016. https://pvcyclepublications.cld.bz/Annual-Report-PV-
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51 Official Journal of the European Union. Directive 20121191EU of the European Parliament and of the Council
of 4 July 2012 on Waste Electrical and Electronic Equipment. July 2012. Accessed November 2016. http://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32012L0019
58 SEIA National PV Recycling Program: www.seia.org/seia-national-pv-recycling-program
59 RBI Solar, Decommissioning Plan submitted to Catawba County associated with permitting of a 5MW solar project in June
2016. Accessed April 2017. www.catawbacountync.gov/Planning/Projects/Rezonings/RZ2015-05-DecommissioningPlan.pdf
60 Birdseye Renewables, Decommissioning Plan submitted to Catawba County associated with permitting of a 5MW solar
project in May 2015. Accessed April 2017. www.catawbacountync.gov/Planning/Projects/Rezonings/RZ2015-
04_ DecommissioningPlan.pdf
61 Cypress Creek Renewables, Decommissioning Plan submitted to Catawba County associated with permitting of a 5MW
solar project in September 2016. Accessed April 2017. www.catawbacountync.gov/Planning/Projects/Rezonings/RZ2016-
06decommission.pdf
62 Sun Raised Farms: http://sunraisedfarms.com/index.html
63 National Institute of Environmental Health Sciences and National Institutes of Health, EMF: Electric and Magnetic Fields
Associated with Electric Power: Questions and Answers, June 2002
17
64 World Health Organization. Electromagnetic Fields and Public Health: Exposure to Extremely Low Frequency Fields.
June 2007. Accessed August 2016. http://www.who.int/peh-emf/publications/facts/fs322/en/
65 Committee on the Possible Effects of Electromagnetic Fields on Biologic Systems, National Research Council, Possible
Health Effects of Exposure to Residential Electric and Magnetic Fields, ISBN: 0-309-55671-6, 384 pages, 6 x 9, (1997) This
PDF is available from the National Academies Press at: http://www.nap.edu/catalog/5155.html
66 World Health Organization. Electromagnetic Fields and Public Health: Exposure to Extremely Low Frequency Fields.
June 2007. Accessed August 2016. http://www.who.int/peh-emf/publications/facts/fs322/en/
67 World Health Organization. Electromagnetic Fields and Public Health: Static Electric and Magnetic Fields. March 2006.
Accessed August 2016. http://www.who.int/peh-emf/publications/facts/fs299/en/
68 Asher Sheppard, Health Issues Related to the Static and Power -Frequency Electric and Magnetic Fields (EMFs) of the
Soitec Solar Energy Farms, April 30, 2014. Accessed March 2017:
www. sandiegocounty. gov/content/dam/sdc/pds/cega/Soitec-Documents/Final-EIR-Files/Appendix_9.0-1 _EMF.pdf
69 Massachusetts Clean Energy Center. Study of Acoustic and EMF Levels from Solar Photovoltaic Projects. December 2012.
Accessed August 2016.
70 Duke Energy Corporation. Frequently Asked Questions: Electric and Magnetic Fields. Accessed August 2016.
https://www.duke-energy.com/about-energy/frequently_asked questions.asp
71 National Institute of Environmental Health Sciences, Electric and Magnetic Fields Associate with the use of Electric
Power: Questions and Answers, 2002. Accessed November 2016
www.niehs.nih.gov/health/materials/electric —
andmagnetic_fields
" Duke Energy Corporation. Frequently Asked Questions: Electric and Magnetic Fields. Accessed August 2016.
https://www.duke-energy.com/about-energy/frequently_asked questions.asp
73 R.A. Tell et al, Electromagnetic Fields Associated with Commercial Solar Photovoltaic Electric Power Generating
Facilities, Journal of Occupational and Environmental Hygiene, Volume 12, 2015,- Issue 11. Abstract Accessed March 2016:
http://www.tandfonline.com/doi/full/I 0. 1080/ 15459624.2015.1047021
74 Massachusetts Department of Energy Resources, Massachusetts Department of Environmental Protection, and
Massachusetts Clean Energy Center. Questions & Answers: Ground -Mounted Solar Photovoltaic Systems. June 2015.
Accessed August 2016. http://www.mass.gov/eea/docs/doer/renewables/solar/solar-pv-guide.pdf
75 Ibid.
76 Ibid.
77 EMFs and medical devices, Accessed March 2017. www.emfs.info/effects/medical-devices/
78 ibid.
79 Damon McCluer. Electrical Construction & Maintenance: NFPA 70E's Approach to Considering DC Hazards. September
2013. Accessed October 2016. http://ecmweb.com/safety/nfpa-70e-s-approach-considering-dc-hazards,
80 Hong-Yun Yang, et. al. Experimental Studies on the Flammability and Fire Hazards of Photovoltaic Modules, Materials.
July 2015. Accessed August 2016. http://www.mdpi.com/1996-1944/8/7/4210/pdf
81 Matt Fountain. The Tribune. Fire breaks out at Topaz Solar Farm. July 2015. Accessed August 2016.
www.sanluisobispo.com/news/local/article39055539.html
" Cooperative Research Network. Matthew Paiss. Tech Surveillance: PV Safety & Code Developments. October 2014.
Accessed August 2016. htt2://www.nreca.coop/wp-content/uploads/2013/06/ts pv fire safely oct_2014.pdf
Published by the N.C. Clean Energy Technology Center at N.C. State University
NC CLEAN ENERGY
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