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June 16, 2014
Renewable energy on contaminated sites

In the latest Project Tracking Matrix for EPA’s 5-year-old Repowering America’s Land Initiative (RE-Powering Initiative), the Agency reports that there are 110 renewable energy installations on 103 contaminated sites, with a cumulative installed capacity over 709 megawatts (MW). 

More than half of these installations are large-scale systems with a project capacity of 1 MW or greater, says the EPA, either exporting energy onto the utility grid or offsetting on-site energy demands.  Topping the list are 20 wind installations with a capacity of 485.7 MW and 86 solar photovoltaic installations with 204.1 MW of capacity. The Agency adds that there has been consistent growth in total installations since the inception of the RE-Powering Initiative.

Advice available

Under the initiative, the EPA provides assistance to both remediate contaminated sites with renewable energy and convert the sites to renewable energy installations.  The assistance generally takes the form of technical, funding, and legal advice for state and federal governments as well as private entities, NGOs, and other stakeholders that have questions about the feasibility of building renewable energy installations on contaminated properties.  Descriptions of the specific information and assistance the EPA says it will provide are included in the Agency’s Draft Action Plan 2.0 for the RE-Powering Initiative, which was released about the same time as the tracking matrix. 

Liability and comfort letters

Using renewable energy and/or developing a renewable energy installation on a Superfund, RCRA corrective action, or brownfields site do not liberate the developer or property owner from the liability concerns associated with those contaminated properties.  However, in the matrix report, the EPA notes that it is particularly interested in encouraging appropriate renewable energy development on environmentally impaired lands by issuing comfort letters, which generally provide assurance to developers that the Agency will not initiate enforcement if specific site-remediation actions are taken. 

Rapid response 

The draft action plan lists activities that will be conducted over the next 2 years to support the development of renewable energy projects on contaminated lands, landfills, and mine sites.  The three general goals are provision of technical and programmatic assistance; promotion of policies and best practices that encourage renewable energy on contaminated lands; and partnership with stakeholders and leverage of Agency efforts. 

Examples of specific objectives include:

  • Development by summer 2014 of an electronic version of solar and wind decision trees, which help developers determine if the characteristics of a site make it attractive for development.  The current decisions trees are contained in a “static” publication. 
  • Continued improvement of EPA’s Rapid Response Team, which provides technical assistance to stakeholders, helps facilitate processes, and shares information, contacts, and perspectives.
  • Assistance to local governments in developing requests for proposals (RFPs) to develop renewable energy projects on contaminated land.
  • Analysis of the potential for developing renewable energy installations on contaminated land close to critical infrastructure (e.g., hospitals and wastewater treatment plants) to mitigate the possible consequences of extreme weather events. 
  • Exploring ways to facilitate, support, and utilize a network of communities, wherein those that have successfully installed renewable energy on their contaminated lands can inspire such development and share lessons learned with others who do not have the experience or technical capacity to evaluate such projects.

Project tracking matrix

Draft action plan