Design and Development
This information is intended for sites where the cleanup program, whether Federal, state, or Tribal, has been identified.
This section provides key considerations for renewable energy development on contaminated lands, as well as two specific design scenarios. The design and development phase can begin once you have established that the site is a viable project location with sufficient renewable energy resources, reasonable interconnection prospects to nearby transmission or distribution lines, viable economics, and have thoroughly evaluated cleanup needs. Regardless of what type of environmental contamination is present on site, there are several key considerations when designing a renewable energy project on your site:
Incorporating renewable energy development for sites requiring cleanup
Considering reuse options and renewable energy development early in the cleanup process can allow remedial design to accommodate the technical siting requirements of the selected type of renewable energy. The project should ensure, through careful planning, that renewable energy development does not compromise the effectiveness or operation of the selected cleanup remedy.
EPA developed a series of renewable energy development checklists that are tailored to the cleanup program occurring on site.
Accommodating institutional controls (ICs) and protectiveness
When considering renewable energy development at any phase in the cleanup process, special attention should be paid to institutional controls (e.g., easements and covenants). ICs often are implemented on a site-specific basis to minimize the potential for exposure to contamination and/or protect the integrity of the remedy components. If ICs have already been implemented, renewable energy development must be carefully planned to ensure adherence to IC restrictions or notices that are in place.
For sites requiring cleanup, EPA, state, or Tribal cleanup leads will evaluate whether the implementation and remedy is or will be protective of human health and the environment. This is generally referred to as the protectiveness of the site and should be maintained and accommodated by renewable energy redevelopment. More information on maintaining protectiveness.
Coordination and risk management
Renewable energy development is often made possible with the support of various stakeholders. Many projects require land use and zoning reviews, permits or approvals by local departments such as a planning review board or other local permitting bodies. Depending on the state, some projects also require county level land use permits and state level reviews for potential cultural and natural resources impacts. Projects should consider the necessary approvals and requirements when estimating project timeline and associated risks.
Coordinate communications and robust input with involved stakeholders, including EPA, state and Tribal partners, developers, local government representatives, site owners, and the public throughout the redevelopment process to overcome potential challenges and discuss solutions. Challenges could include:
- Uncooperative or uninterested site owners or potentially responsible parties.
- Lack of a viable site owner to negotiate a cleanup or renewable energy development.
- Zoning uncertainties or other complexities with renewable energy reuse, or community preferences for other reuse alternatives.
- Complex environmental cleanup schedules that are too prolonged to interest a developer looking for an immediate investment, and/or
- Inconsistencies in schedules (e.g., cleanup is almost complete, and the reuse assessment has been finalized before renewable energy is considered).
More information on conducting community engagement.
Specific Development Scenarios:
Community solar and solar on landfills are two specific development scenarios with lessons learned and unique considerations.
Learn more about Community Solar.
Learn more about Solar on Landfills.
Renewable Energy Reuse and Protectiveness
EPA works collaboratively with states, Tribes, local government, and other stakeholders to achieve its mission of assessing, cleaning up and restoring contaminated sites to set the stage for redevelopment or facilitate the continued use of the facility. For the Superfund Program, EPA directly oversees the cleanup activities. Other EPA programs were designed by Congress to be delegated or authorized to states (e.g., RCRA Corrective Action, Underground Storage Tanks) or established as a grant program (Brownfields). The majority of site-specific cleanup decisions are made by the state-run or state-delegated programs, including decisions about protectiveness.
Developers of renewable energy projects on formerly contaminated lands, as well as landfills and mining sites, have adopted strategies, through collaboration with site owners, engineering and environmental consultants, and overseeing agencies, to cost effectively install such technology and maintain the integrity and protectiveness of the cleanup remedy.
The strategies include:
- Ballasted racking and foundation systems so that solar panels can rest on top of the surface without penetrating the ground, site cover system, landfill cap, or otherwise creating unwanted preferential pathways for stormwater to enter the subsurface.
- Use of at-grade or above ground, protected electrical conduits to avoid the need for trenching.
- Selecting certain sub-sections of the site for reuse where contamination was limited or non-existent.
- Designing renewable energy structures that effectively use, enhance, or complement aspects particular to the material contained on site (e.g., mill tailings) without exacerbating existing contamination.
- Adjusting the locations of groundwater monitoring stations or extraction wells, landfill gas vents, or other remedial features to places that maximize flat, open areas for solar panels, but still providing the necessary and spatially relevant information to monitor the site.
- Minimizing soil disturbance in design, installation, and operation of the renewable energy system.
In these and other ways, it is possible for renewable energy to be developed consistent with the chosen cleanup remedy to protect the site.
For an example of renewable energy reuse and protectiveness, refer to Solar on Landfills.
How should I involve the community?
Community engagement is an ongoing process occurring alongside site cleanup and renewable energy project development and is critical to ensure that future reuse plans are compatible with the local community’s priorities. Community engagement best practices include:
- Understand what local community groups may be heavily involved in or affected by the potential reuse.
- Obtain early input from these groups and the community at large on priorities for how the site should be redeveloped and specific ideas for how renewable energy may be part of the redevelopment. Doing so should reduce potential concerns or roadblocks at later phases of development.
- Continue to involve the community throughout the cleanup and redevelopment process via town hall meetings, public comment periods, distribution of project updates, and/or hearings.
- Hold discussions with local land use planning authorities, other appropriate local officials, and the public to discuss renewable energy and other options for the future use of the land.
- At sites requiring cleanup, work with EPA or the appropriate state or Tribal agency that has the lead for cleanup to ensure compatibility between renewable energy as a reuse option and the cleanup remedy.
Working with Tribes
Investing in energy strategies that lower emissions can be an effective way for Tribal governments to achieve multiple goals: improving air quality and public health, strengthening their energy resilience, reducing air pollution, and saving money. Similar to any redevelopment, clear communication early and often in the engagement process is critical to ensuring Tribal nations are a partner in renewable energy development. In support of empowering decision making at the Tribal level, consider using a local facilitator during community outreach that understands the community’s culture and history.
In addition to following the best practices described above, meaningful communication and coordination between EPA and Tribal officials on a government-to-government basis is essential prior to EPA taking actions or implementing decisions that may affect tribes. Each of EPA’s cleanup programs provide program-specific information and technical assistance to support meaningful engagement with tribes throughout the cleanup process.
For more information on EPA’s policy on consultation and coordination with Indian Tribes, please refer to Consultation with Tribes | US EPA
Impacts on Low Income and Disadvantaged Communities
Investing in renewable energy, as well as other types of clean energy, is an important way for state, local, and Tribal governments to provide a variety of benefits to low-income and disadvantaged communities and environmental justice communities, including energy cost savings, tax revenues, job creation, property improvement, and improved air quality. Renewable energy installations on Superfund, Brownfields, and RCRA sites are often found in or adjacent to low-income communities and have limited, other reuse options. By using these lands to support renewable energy, communities can also divert renewable development pressures away from open space and preserve undeveloped land and habitat. One example of a successfully developed renewable project on a potentially contaminated sites benefitting low-income communities is profiled here:
RE-Powering partners with EPA’s Brownfields Job Training Grants Program to provide competitive grant funding to recruit, train, and place unemployed and under-employed residents of areas affected by the presence of brownfield sites, including low-income and underserved residents. Through the Program, graduates develop the skills needed to secure full-time, sustainable employment in various aspects of hazardous substances, pollutants, contaminants, and petroleum products within the larger environmental field, including sustainable cleanup and reuse and chemical safety. These green jobs reduce environmental contamination and build more sustainable futures for communities.
Community Solar
Community solar projects are one way to develop solar on contaminated lands. Community solar projects allow residential and commercial utility customers to opt into a subscription plan that provides a share of either the solar panel capacity or electricity output. These projects allow utility customers to purchase power from a local solar project without having to install a project on their own property and may create long-run cost savings for them.
Community solar is similar in concept to a community agricultural farm, where participants each have a plot of land or a share of the farm's produce. As shown in the Community Solar photo below, specific solar panels are allocated to each individual customer.
Community solar projects (sometimes called Shared Renewables) expand solar access by allowing residential and commercial utility customers that either: 1) lack the technical ability or financial resources to install solar on their premises, or 2) are located in an area where relying on solar would be impractical or inefficient, to purchase solar power for some or all of their electricity needs. For example, properties that are shaded by buildings or trees can instead purchase solar power through direct participation in local projects. A subscriber can live many miles from the solar project to which they subscribe, but will still receive credits on their monthly electric bill just as if the panels were mounted on their roof. See EPA’s website on Shared Renewables for additional information.
Photo credit: ©hiv360/Adobe Stock
Why is Community Solar important on RE-Powering Sites?
Community solar projects are typically between 1 to 5 megawatts and cover 6 to 30 acres of land. Landfills and mid-sized brownfield sites are typically a similar size, and this makes landfills and brownfields ideal locations for community solar projects.
As of October 2022, 42 community solar projects across a total of 18 states and U.S. territories have been installed on RE-Powering sites. In the past decade, community solar projects have grown significantly as a percentage of RE-Powering projects. The following graph illustrates types of solar projects over time and shows that the relative proportion of RE-Powering community solar projects have grown from zero in 2012 to 44% in 2021.
Why is this important to low-and moderate-income communities?
Many community solar projects allocate a certain percentage of subscriptions to low- and moderate-income customers, use local subcontractors to assist with installation and maintenance, and provide solar employment training for community residents.
See the National Community Solar Partnership for more information about supporting equitable community solar development in the U.S. The National Community Solar Partnership is a coalition of community solar stakeholders working to expand access to affordable community solar for every American household.
How do I find sites for Community Solar?
One way to identify sites suitable for community solar is to use the RE-Powering Mapper. The RE-Powering Mapper Tutorial – Searching for Sites guides users through the process of locating acceptable sites that meet specific traits or criteria.
How do state programs help Community Solar?
Some states have programs enabling community solar in the form of legislation that creates a third-party market for community solar and requires both project developers and utilities to follow certain regulations to enroll customers and develop community solar installations. In states without community solar programs, projects are typically developed and managed by the local utility.
For additional information on state-level policies and programs for community solar, including how states and territories address low- and moderate-income participation, see State Policies and Programs for Community Solar.
For example, New Jersey has implemented a Community Solar Energy Pilot Program, which applies evaluation criteria that prioritize brownfields, landfills, areas of historic fill, rooftops, and parking canopies. This program addresses environmental equity by allocating a significant portion of program capacity to low- and moderate-income communities.
Among Year 1 and 2 program awards, a total of 35 megawatts Direct Current (DC) and 41 megawatts DC respectively, were on landfill or brownfield sites. See Profiles of State Programs for more information on the New Jersey program and other RE-Powering-related programs.
Examples of Community Solar on RE-Powering Sites
Completed community solar projects that include environmental equity components:
- Oxon Run (2.65 megawatts DC) Brownfield Community Solar Project in Washington, DC Located on a 15-acre site that was contaminated with petroleum residues from nearby gas stations, this project provides several direct benefits to the area. Local subcontractors participated in solar construction, and approximately 750 income-qualifying households in the surrounding community each receive $500 of free electricity annually from the solar project. Extensive habitat enhancements were also made to the site, including restoration of native trees and pollinator plants.
- Coyote Ridge (1.95 megawatts) Landfill Community Solar Project in Fort Collins, CO This project covers 9 acres of landfill buffer and is managed by the local utility, Poudre Valley Rural Electric Association, an electric cooperative. Most of the community solar panels are allocated to income-qualified customers of the electric cooperative association and local non-profit organizations. Due to its popularity, the project is already fully subscribed.
For more information on community benefits from RE-Powering projects, see the RE-Powering Benefits Matrix.
Solar on Landfills
Reusing former landfills as large solar projects is a clear, growing trend. In 1988, there were nearly 8,000 landfills in the United States. In 2009, that number had dropped to below 2,000. The landfills that closed over the intervening years-plus portions of active landfills with closed cells-represent thousands of acres that may be suitable for siting solar projects.
Many landfills are particularly well-suited for solar development because they are often:
- Located near critical infrastructure including electric transmission lines and roads;
- Located near areas with high energy demand (e.g., large population bases);
- Constructed with large areas of minimal grade (0-2 percent) needed for optimal siting of solar photovoltaic structures.
- Offered at lower land costs when compared to open space; and
- Able to accommodate net metered or utility scale projects.
EPA and the Department of Energy’s National Renewable Energy Laboratory (NREL) jointly developed the Best Practices for Siting Solar Photovoltaics on Municipal Solid Waste Landfills. EPA and NREL created this document to address common technical challenges for siting solar photovoltaic on municipal solid waste landfills.
- Best Practices for Siting Solar Photovoltaics on Municipal Solid Waste Landfills This document provides best practices unique to siting solar photovoltaics on municipal solid waste landfills. Many stakeholders, including solar developers, landfill owners, and federal, state, and local governments may find this information useful.
Additional Design Considerations
It is often important to consider additional remedial site design criteria when incorporating renewable energy, for example:
- Designing access roads, groundwater monitoring stations, and other above ground protrusions around the edges of the anticipated footprint of the solar project.
- Grading and selecting appropriate materials of cap. Capping involves placing a cover over contaminated material such as landfill waste or contaminated soil.
- Consider a final site grade of less than 3% and maximize the orientation of the grade for southern exposure to maximize solar electricity production.
- Consider final cap materials that are compatible with solar projects, i.e., compatible vegetation cover.
- Ensuring that existing transmission and distribution infrastructure remains in place as it could reduce the cost and timeline for interconnecting the renewable project to the grid.
- Involving a solar developer or consultant to determine early on which type of solar design is most appropriate for the property and amend the cleanup design accordingly (i.e., modify cap depth, cover materials, water management, and/or grading requirements).