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Solar Industry Comments re: PV Recycling in NYS Solid Waste Management Plan

June 28, 2023

NYSEIA submitted comments regarding PV panel recycling in response to the 2023 New York State Solid Waste Management plan jointly with the Alliance for Clean Energy New York (ACE NY) and the Solar Energy Industries Association (SEIA).

Our comments voiced general support for the plan, but reminded the DEC that solar panels have a long lifespan and therefore solar PV panel recycling is not an urgent near-term issue. Our comments encouraged the DEC to avoid extended producer responsibility (EPR) requirements for solar panels (which would put the recycling requirement on the manufacturer) and to instead leverage existing industry practices to address end-of-life solar panels (e.g. decomissioning plans). NYSEIA opposes EPR because, as we see in Niagara County, state and local EPR policies are not feasible for global manufacturers to comply with, and can effectively prevent solar deployment and slow our transition to clean energy. NYSEIA believes that decommissioning plans already largely address concerns regarding future solar panel waste, and we are confident that recycling infrastructure for solar PV will develop over the next few decades as the solar panels installed in NY today near the end of their useful life.

NYSEIA support solar panel recycling, and we look forward to working closely with the DEC, NYSERDA and industry to develop a thoughtful approach to solar PV recycling that minimizes solar panel waste while encouraging rapid solar deployment so New York can continue making progress toward our ambitious clean energy goals.

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