• Joint Petition for Regulating Photovoltaic Solar Panels as Universal Waste

November 19, 2021

Dear Administrator Regan: The Edison Electric Institute, American Clean Power Association, National Association of Manufacturers, U.S. Chamber of Commerce, American Public Power Association, Large Public Power Council, National Rural Electric Cooperative Association, Utility Solid Waste Activities Group, and Cross-Cutting Issues Group, (collectively, the “Petitioners”) submit the enclosed rulemaking petition (“Petition”) in accordance with 40 C.F.R. § 260.20, 40 C.F.R. § 260.23, and 40 C.F.R. § 273.80, requesting that the U.S. Environmental Protection Agency (“EPA”) adopt a universal waste management standard for photovoltaic solar panels (“PV Panels”) to support the transition to clean energy. Such a standard is appropriate for used PV Panels, will improve management practices for such materials, and will encourage recycling by allowing for used PV Panels to be collected and mass recycled.

The electric sector is at the forefront of the clean energy transformation and has taken the lead on reducing greenhouse gas emissions over the past decade, while keeping reliability and affordability front and center for the customers and communities they serve. This transformation is being driven by a wide range of factors, including declining costs for natural gas and renewable energy resources, energy efficiency and demand-side management, technological improvements, customer demand for clean energy, federal and state regulations and policies, and the increasing use of distributed energy resources. With the right policies and a balance of technologies, the electric sector can find cost-effective ways to provide reliable, affordable, and clean energy. With support by manufacturers and critical labor workers, the electric sector is poised to continue leading the clean energy transformation, reducing greenhouse gas emissions, and being a part of the solution to climate change.