The California Department of Toxic Substances Control’s (DTSC) proposed solar recycling regulations are so baffling they resemble San Jose’s haunted Winchester Mansion.
The Winchester Mansion was built in 1884 by Sarah Winchester, the gun-manufacturer heiress. She believed she was being haunted by victims killed by Winchester rifles and she spent the latter part of her life building rooms and doors onto her mansion in order to appease these spirits. She added 160 rooms and 950 doors, most of which lead to dead-ends.
Similarly, DTSC continues to add to the State’s complex maze of hazardous waste regulation without a blueprint for environmental sustainability.
For example, The DTSC Proposed Standards for Management of Waste Solar Panel recommends solar modules to be regulated under the same universal waste rule as the State’s e-waste.
This is a bad idea. The State e-waste recycling program continues to allow California waste to be dumped overseas to poor countries that do not have infrastructure to recycle the waste. We have seen this type of dumping devastate entire villages and impact human health.
DTSC’s proposal for solar waste recycling does not include any incentive for the recyclers or solar companies to build recycling infrastructure in California, so we can expect our solar waste to suffer the same fate as e-waste.
That means California will lose recycling jobs and the State’s toxic solar waste will also be dumped in poor countries or shipped to out of-state landfills.
The proposed recycling program will also lead to consumer confusion. Solar customers will have no idea what to do with their panels at the end of the panel’s life.
DTSC’s proposed solar recycling program only includes solar panels that are classified as hazardous waste. And the proposal does not require a label to let customers know that the panel is hazardous waste and how the solar panel should be recycled.
SVTC wrote a letter expressing our concerns about these regulations when they were first introduced in 2010 . After two years of internal review, DTSC has not come up with any new ideas. In 2012 they released almost exactly the same proposal. Unfortunately,DTSC has wasted a lot of time and opportunity on this poorly thought-out proposal.
SVTC resubmitted our 2010 comments strongly stating our concern that any new solar recycling regulations should require manufacturers to take responsibility for recycling their own products. We also recommended that DTSC conduct a third party review of regulations three years after adoption
The solar technology is rapidly changing which means that the industry’s recycling needs will also change. Yet the DTSC proposal does not even include a provision to evaluate the regulations to see if the recycling program is working.
DTSC is continuing to construct a daunting solar panel recycling system that is full of regulatory twist and turns that lead to a dead-end.
DTSC is building its own version of the Winchester Mansion.