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TRC has proudly supported EUEC for more than 15 years
February 10, 2017
A Bright Idea: Solar on Brownfields
TRC has proudly supported EUEC for more than 15 years 2
Outline
• Solar + Brownfield = Brightfield• Brownfields are Abundant• Why – Municipalities• Why – Utilities• Brownfield Challenges• Brownfield Liability Protection • Construction Considerations• Stakeholder Management• Other Opportunities• Success Stories
TRC has proudly supported EUEC for more than 15 years 3
The Perfect Marriage
Brownfield
Solar Development
Brightfield
TRC has proudly supported EUEC for more than 15 years 4
Brownfields Are Abundant Nationwide
• 450,000+ nationwide
• 5 million acres • Average size is 8-15
acres• Large cities, small
towns, rural
• Abandoned industrial sites• Closed landfills• Abandoned & reclaimed mine lands
TRC has proudly supported EUEC for more than 15 years 5
Revitalization of abandoned property, tax reversions, and underperforming assets Rebuild property tax base Promote brownfield cleanup Attract eco-minded industry Fixed power price for municipal services for duration of
PPA Lower carbon footprint Community solar
Property can still have alternative future beyond PPA
Why – Municipalities?
TRC has proudly supported EUEC for more than 15 years 6
Community engagement
Community solar – visibility of program
RPS goals
Lower cost lease
Existing infrastructure (e.g., substations and transmission)
Lesser permitting threshold
Off-site power offering
Opportunities for land in dense urban areas
Brownfield incentives may be available
Why – Utilities?
TRC has proudly supported EUEC for more than 15 years 7
Brownfield Challenges• Actual and perceived
• Presence of contamination
• Uncertainty of liability
• Additional expense to develop?
• On-going site management and compliance (e.g., consent orders & decrees, restrictive covenants relative to construction activities)
• Potential future remediation activities by others that could disrupt solar plant operations
TRC has proudly supported EUEC for more than 15 years 8
Brownfield Liability Protection• U.S. EPA – CERCLA Liability Exemption
& Bona Fide Prospective Purchaser (BFPP) – Self implemented.
• Includes purchased and leased property. – Tenants sometimes derive protection
through landlord.
• Must achieve/maintain BFPP status.
Not affiliated with liable party/person.Take reasonable precautions to prevent releases of hazardous substances.Provide cooperation, assistance and access to property for those undertaking cleanup activities.Provide legally required notices.Do not impede cleanup work.Comply with land use restrictions and institutional controls.
TRC has proudly supported EUEC for more than 15 years 9
Brownfield Liability Protection
Typical steps in liability protection:
• Phase I ESA/All Appropriate Inquiry
• Phase II ESA (e.g., soil investigation)• Landfill may have sufficient data• Can combine with geotechnical
• Compliance Mechanism• Construction Environmental
Planning (e.g., maintain compliance)
• Post-Construction Monitoring
TRC has proudly supported EUEC for more than 15 years 10
Construction ConsiderationsWork with Local Unit of Government To Be Prepared
Appropriate zoning/Special Use for power generation Public acceptance Visibility – line of sight Road access/site accessibility Landfill cap protection & permit planning Racking ballast stability Special construction techniques Residuals management Security
TRC has proudly supported EUEC for more than 15 years 11
Have A Stakeholder Management Plan!
Communication with community is vital.• Former creosote treatment plant with
90-year history of contamination; USEPA cleanup activities since 2003.
• Site perception with local residents was not managed upfront.
• After two years of planning & debate over concerns, including environmental justice issues, special use permit was finally approved.
Quotes: • “Opponents of the development are also worried about the disturbance of possibly contaminated soil remaining
from when [redacted] operated from 1905 to 1991.
• “First, at all of the various meetings on this issue, no one has taken the time to put all of the relevant information together. There has been an ongoing failure to communicate, consider the views of other parties, and synthesize the issues.” City Council Member
• There were also statements made by the audience saying the council’s decision was fueled more by money than representing the needs of its residents.
TRC has proudly supported EUEC for more than 15 years 12
Other Opportunities - Pollinator Habitat
Promote monarch butterfly, honey bee and other threatened & endangered species
Native species ground cover – identified by plant survey
Create plant palette - Plants with maximum heights below panel drip line (~30”)
Reduces mowing and costs
Introduction of herbaceous plants will benefit species and discourage invasion by woody species that create shading effects.
TRC has proudly supported EUEC for more than 15 years 13
Brightfields Nationwide
TRC has proudly supported EUEC for more than 15 years 14
Kokomo Solar 1, Kokomo, IN
Former Continental Steel Superfund Site – Main Plant
Kokomo 1 Solar – 7 MW Power Plant Constructed on Clean Fill Cover
TRC has proudly supported EUEC for more than 15 years 15
Greenfield Solar Project – 2MW, First Solar on Landfill Permitted in MA
TRC has proudly supported EUEC for more than 15 years 16
Sullivan’s Ledge – 1.5 MW Solar onSuperfund Landfill
TRC has proudly supported EUEC for more than 15 years
Questions?Doug Kilmer, [email protected]
Beth [email protected]
