We would like to clarify several points raised in Joseph McCabe’s article, “First Solar’s Stewardship of Recycled CdTe Modules in Question.”
First Solar has not eliminated its end-of-life program. First Solar continues to provide recycling services, operate recycling facilities, and invest in recycling technology to promote high-value recycling and extended producer responsibility. Product stewardship, or EPR, is the act of minimizing the impacts and maximizing the economic benefits of a product and its packaging throughout its lifecycle. By offering a competitive recycling service to our customers, First Solar is proactively and voluntarily practicing EPR.
First Solar amended its prefunded program to better suit the needs of its changing customer base of utility-scale PV power plant owners. Commercial customers, which have experience with decommissioning requirements as part of their overall operational responsibilities, don't want to pay upfront for recycling services that will be needed 25 years from now. Similarly, a nuclear, coal, or gas power plant owner only pays for decommissioning at the end of the plant’s operational lifetime. It is more efficient to finance PV recycling through later-year project cash flows instead of upfront funding, as solar project rates of return are typically higher than the rates of return First Solar receives via its trust investments.
First Solar will meet collection and recycling obligations of historical agreements. The prefunded trust, which was established to ensure funds will be available to meet our recycling obligation, remains unaffected by this change.
Furthermore, CdTe PV technology does not have unique end-of-life management requirements. Responsible end-of-life management is important to the whole PV sector, as environmentally sensitive materials (e.g., lead, chromium, and cadmium compounds) are common in the industry. Based on comparable quantities of heavy metals, potential environmental impacts from end-of-life disposal of crystalline silicon PV modules are comparable to or greater than that of CdTe PV. Please note that First Solar’s CdTe PV modules have been tested in accordance with applicable waste characterization protocols and at end-of-life can be classified as "non-hazardous waste for recovery" in Europe and as a federal non-hazardous waste in the U.S.
First Solar requires its customers to either recycle or dispose of modules responsibly to ensure that today’s solutions to clean energy don’t pose a waste management burden for future generations.
First Solar is not abandoning its commitment to recycling. The company continues to invest in recycling technology improvements and is implementing a cost reduction roadmap to drive down recycling prices. Focusing on reducing the cost of PV recycling is the best way of ensuring that it becomes the preferred end-of-life management approach. First Solar’s flexible, competitive, and global recycling program enables power plant owners to meet their end-of-life requirements simply, cost-effectively, and responsibly. Our state-of-the-art recycling facilities are operational at all our manufacturing plants and have a scalable capacity to accommodate high volume recycling as more modules reach the end of their 25+ year life. Our proven recycling process achieves high recovery rates: up to 95 percent of the semiconductor material can be reused in new modules and 90 percent of the glass can be reused in new glass products. Through 2012, approximately 48,000 metric tons have been recycled in our facilities worldwide.
With regards to the Abound Solar modules, First Solar has received and recycled nearly 500 tons of Abound’s discarded modules. First Solar will also be providing recycling services to GE.
First Solar has provided industry leadership regarding managing PV modules at the end of life and we stand alone in offering these capabilities and services to the PV sector at scale. The change in our approach reflects an evolution in our business to utility-scaled solutions that offer our sophisticated customer base greater flexibility around how to optimally finance an important aspect in the life of a PV power plant, while at the same time offering them access to state-of-the-art, competitively priced, and environmentally beneficial recycling.
***Alex Heard is the Vice President of EHS, Sustainability and Recycling Services at First Solar.