HomeMy WebLinkAboutHazardous Material Letter of Assurance
February 1, 2023
Town of Barnstable Planning Board
Town Hall
367 Main Street
Hyannis, MA 02601
Re: Hazardous Material Assurance Letter
Proposed Solar Array – Special Permit Application
810 Wakeby Road, Marstons Mills, MA
Dear Members of the Planning Board:
Pursuant to 240-44.2 E(2)(p) of the Barnstable Zoning Bylaws, Ground-Mounted Solar
Photovoltaic Overlay District – Safety and Environmental Standards, this letter presents an
assurance the solar array components proposed for the 810 Wakeby Road Solar Project do not
pose any risks to the environment assuming proper measures are taken. Use, storage and
containment of hazardous materials complies with all Federal, State, Regional, and local codes
and regulations, including building, fire, and health codes. Hazardous materials stored or used on
the site do not exceed the amount for a Very Small Quantity Generator of Hazardous Waste as
defined by the Massachusetts Department of Environmental Protection (MassDEP) pursuant to
310 CMR 30.000.
Per the Question and Answer – Ground Mounted Solar Photovoltaic Systems guide from the
Massachusetts Department of Energy Resources, Massachusetts Department of Environmental
Protection and Massachusetts Clean Energy Center dated June 2015, all solar panel materials are:
(1) contained in a solid matrix, (2) insoluble and non-volatile at ambient conditions. Therefore,
releases to the ground from leaching to the air from volatilization during use, or from panel
breakage, are not a concern. Particulate emissions could only occur if the materials were ground
to a fine dust, but there is no realistic scenario for this occurrence. A copy of this guide is attached
as Appendix A.
Hazardous Material Assurance Letter
TJA Clean Energy
Wakeby Road Solar Project
February 1, 2023
In accordance with Barnstable Zoning Bylaw 240-44.2 E(2)(p), TJA Clean Energy (the Applicant)
is requiring that all manufacturers to attest and certify that all solar panels, solar sheets, and all
other materials used on the proposed site do not contain Per- and Polyfluoroalkyl Substances
(PFAS).
Additionally, there are no hazardous materials that will be permanently introduced or stored on the
site as part of the solar panel installation. The solar panels will be mounted two to three feet above
ground on a racking systems. The proposed electrical inverters will be cooled via a forced air
ventilation system and will not utilize liquid coolant. Transformers utilized for the project are
anticipated to utilize biodegradable Envirotemp FR3 Fluid as the cooling medium. As per
discussions with Karl Jacob of Cargill, Inc., the FR3 Fluid does not contain PFAS/Genx chemicals.
Additionally, Karl Jacob confirmed that Cargill does not use PFAS/GenX chemicals in any of the
processes or plants. A copy of the Material Safety Data Sheet (MSDS), FR3 Fluid FAQ Sheet and
correspondence with Cargill Inc., attached as Appendix B for reference.
If you have any questions, please feel free to contact us at (508) 888-9282.
Very truly yours,
Sincerely,
ATLANTIC DESIGN ENGINEERS, INC.
Richard J. Tabaczynski, P.E.
Vice President
Hazardous Material Assurance Letter
TJA Clean Energy
Wakeby Road Solar Project
February 1, 2023
Appendix A
Question and Answer – Ground Mounted Solar Photovoltaic Systems
Massachusetts Department of Energy Resources
Massachusetts Department of Environmental Protection
Massachusetts Clean Energy Center
June 2015
Questions
&
Answers
Ground-‐Mounted
Solar
Photovoltaic
Systems
June
2015
Massachusetts
Department
of
Energy
Resources
Massachusetts
Department
of
Environmental
Protection
Massachusetts
Clean
Energy
Center
Westford
Solar
Park,
photo
courtesy
of
EEA
2
Table
of
Contents
Background……………………………………………………………………………………………………….3
Hazardous
Materials………………………………………………………………………………………...5
End-‐of-‐Life/Decommissioning…………………………………………………………………………..7
Ambient
Temperature
(“Heat
Island”)……………………………………………………………...9
Electric
and
Magnetic
Fields
(EMF)………………………………………………………………....10
Property
Values…………………………………………………………………………….……………..….13
Public
Safety
(including
fires)…………………………………………………………………………..14
Historic
Preservation……………………………………………………………………………………….16
Noise……………………………………………………………………………………………………………….18
Water-‐Related
Impacts……………………………………………………………………………………20
Glare……………………………………………………………………………………………………………….22
Endangered
Species
and
Natural
Heritage………………………………………………………23
3
Background
Encouraging
increased
use
of
solar
photovoltaic
(PV)
technology,
which
converts
sunlight
directly
into
electricity,
is
a
key
priority
for
state
clean
energy
efforts.
The
environmental
benefits
of
solar
PV
abound.
Unlike
conventional
fossil
fuel
power
generation
(such
as
coal,
gas
and
oil),
generating
electricity
with
ground-‐mounted
solar
PV
involves
no
moving
parts,
uses
no
water,
and
produces
no
direct
emissions
of
climate-‐warming
greenhouse
gases.
Solar
PV
environmental
and
energy
benefits,
combined
with
strong
incentives
available
for
solar
projects,
have
significantly
increased
the
use
of
this
technology
recently.
The
Commonwealth’s
vibrant
solar
industry
has
a
variety
of
ownership
and
financing
options
for
Massachusetts
residents
and
businesses
looking
to
install
solar
PV
systems.
Purchasing
a
solar
PV
system
generally
involves
upfront
installation
and
equipment
costs,
but
there
are
significant
upfront
and
production-‐based
incentives1.
As
the
Massachusetts
clean
energy
sector
grows,
the
Baker
Administration
is
working
to
ensure
that
solar
PV
and
other
clean
energy
technologies
are
sited
in
a
way
that
is
most
protective
of
human
health
and
the
environment,
and
minimizes
impacts
on
scenic,
natural,
and
historic
resources.
Purpose
of
Guide
This
guide
is
intended
to
help
local
decision-‐makers
and
community
members
answer
common
questions
about
ground-‐mounted
solar
PV
development.
Ground-‐mounted
solar
PV
has
many
proven
advantages
and
there
has
been
a
steady
growth
of
well
received
projects
in
the
Commonwealth.
However,
these
systems
are
still
relatively
new
and
unfamiliar
additions
to
our
physical
landscape.
This
guide
focuses
on
questions
that
have
been
raised
concerning
the
installation
and
operation
of
ground-‐mounted
solar
PV
projects.
It
provides
summaries
and
links
to
existing
research
and
studies
that
can
help
understand
solar
PV
technology
in
general
and
ground-‐mounted
solar
in
particular.
Solar
PV
panels
can
and
are
of
course
also
installed
on
buildings2,
car
ports
or
light
poles.
This
guide
focuses
on
ground-‐mounted
systems
since
most
questions
relate
to
this
type
of
solar
installation.
Developed
through
the
partnership
of
the
Massachusetts
Department
of
Energy
Resources
(DOER),
the
Massachusetts
Department
of
Environmental
Protection
(MassDEP),
and
the
Massachusetts
Clean
Energy
Center
(MassCEC),
this
guide
draws
from
existing
recent
literature
in
the
United
States
and
abroad
and
is
not
the
result
of
new
original
scientific
studies.
The
text
was
reviewed
by
the
National
Renewable
Energy
Laboratory
(NREL).
As
more
or
new
information
becomes
available,
the
guide
will
be
updated
and
expanded
accordingly.
1
For
a
comprehensive
overview,
start
at
http://masscec.com/index.cfm/page/Solar-‐PV/pid/12584
2
For
an
overview
of
the
multiple
options
for
siting
PV
and
buildings
in
the
same
footprint,
see
the
Solar
Ready
Buildings
Planning
Guide,
NREL,
2009.
4
Solar
PV
Projects
Are
Sited
Locally
The
siting
authority
for
solar
PV
projects
resides
at
the
local
-‐
not
the
state
-‐
level.
One
purpose
of
this
guide
is
to
inform
and
facilitate
local
efforts
to
expand
clean
energy
generation
in
a
sustainable
way,
and
provide
a
consolidated
source
of
existing
research
and
information
that
addresses
common
questions
faced
by
communities.
As
part
of
the
Green
Communities
Act
of
2008,
DOER
and
the
Massachusetts
Executive
Office
of
Energy
and
Environmental
Affairs
(EOEEA)
developed
a
model
zoning
by-‐law/ordinance
called
“as-‐of-‐right
siting”
that
does
not
require
a
special
permit.
It
is
designed
to
help
communities
considering
adoption
of
zoning
for
siting
of
large-‐scale
solar.
This
model
zoning
by-‐law/ordinance
provides
standards
for
the
placement,
design,
construction,
operation,
monitoring,
modification
and
removal
of
new
large-‐scale
ground-‐mounted
solar
PV
installations.
The
latest
version
of
the
model
by-‐law
was
published
in
December
20143.
It
provides
useful
information
that
will
not
be
repeated
extensively
in
this
guide.
Consider
Impacts
of
Other
Possible
Developments
at
Site
Use
of
land
for
the
purpose
of
solar
photovoltaic
power
generation
should
be
compatible
with
most
other
types
of
land
usage.
However,
DOER
strongly
discourages
designating
locations
that
require
significant
tree
cutting
because
of
the
important
water
management,
cooling
and
climate
benefits
trees
provide.
DOER
encourages
designating
locations
in
industrial
and
commercial
districts,
or
on
vacant,
disturbed
land.
When
assessing
the
impact
of
new
ground-‐mounted
solar
arrays,
communities
and
other
stakeholders
should
carefully
consider
other
types
of
development
that
might
take
place
in
a
particular
location
if
there
was
no
solar
installation.
Stakeholders
should
bear
in
mind
the
higher
or
lower
impacts
that
those
alternatives
might
have
in
terms
of
noise,
air
pollution
or
landscape.
These
alternative
impacts
fall
outside
the
scope
of
this
guide,
but
are
relevant
when
looking
at
individual
projects.
3
http://www.mass.gov/eea/docs/doer/green-‐communities/grant-‐program/model-‐solar-‐zoning.pdf
5
Hazardous
Materials
The
Question:
What,
if
any,
health
risks
do
chemicals
used
to
manufacture
solar
panels
and
other
devices
used
in
solar
PV
arrays
pose
if
they
are
released
into
the
environment?
Bottom
Line:
Because
PV
panel
materials
are
enclosed,
and
don’t
mix
with
water
or
vaporize
into
the
air,
there
is
little,
if
any,
risk
of
chemical
releases
to
the
environment
during
normal
use.
The
most
common
type
of
PV
panel
is
made
of
tempered
glass,
which
is
quite
strong.
They
pass
hail
tests,
and
are
regularly
installed
in
Arctic
and
Antarctic
conditions.
Only
in
the
unlikely
event
of
a
sufficiently
hot
fire
is
there
a
slight
chance
that
chemicals
could
be
released.
This
is
unlikely
because
most
residential
fires
are
not
hot
enough
to
melt
PV
components
and
PV
systems
must
conform
to
state
and
federal
fire
safety,
electrical
and
building
codes.
Transformers
used
at
PV
installations,
that
are
similar
to
the
ones
used
throughout
the
electricity
distribution
system
in
cities
and
towns,
have
the
potential
to
release
chemicals
if
they
leak
or
catch
fire.
Transformer
coolants
containing
halogens
have
some
potential
for
toxic
releases
to
the
air
if
combusted.
However,
modern
transformers
typically
use
non-‐toxic
coolants,
such
as
mineral
oils.
Potential
releases
from
transformers
using
these
coolants
at
PV
installations
are
not
expected
to
present
a
risk
to
human
health.
More
Information:
Ground-‐mounted
PV
solar
arrays
are
typically
made
up
of
panels
of
silicon
solar
cells
covered
by
a
thin
layer
of
protective
glass,
which
is
attached
to
an
inert
solid
underlying
substance
(or
“substrate”).
While
the
vast
majority
of
PV
panels
currently
in
use
are
made
of
silicon,
certain
types
of
solar
cells
may
contain
cadmium
telluride
(CdTe),
copper
indium
diselenide
(CIS),
and
gallium
arsenide
(GaAs).
All
solar
panel
materials,
including
the
chemicals
noted
above,
are
contained
in
a
solid
matrix,
insoluble
and
non-‐volatile
at
ambient
conditions,
and
enclosed.
Therefore,
releases
to
the
ground
from
leaching,
to
the
air
from
volatilization
during
use,
or
from
panel
breakage,
are
not
a
concern.
Particulate
emissions
could
only
occur
if
the
materials
were
ground
to
a
fine
dust,
but
there
is
no
realistic
scenario
for
this.
Panels
exposed
to
extremely
high
heat
could
emit
vapors
and
particulates
from
PV
panel
components
to
the
air.
However,
researchers
have
concluded
that
the
potential
for
emissions
derived
from
PV
components
during
typical
fires
is
limited
given
the
relatively
short-‐duration
of
most
fires
and
the
high
melting
point
(>1000
degrees
Celsius)
of
PV
materials
compared
to
the
roof
level
temperatures
typically
observed
during
residential
fires
(800-‐900
degrees
Celsius).
In
the
rare
instance
where
a
solar
panel
might
be
subject
to
higher
temperatures,
the
silicon
and
other
chemicals
that
comprise
the
solar
panel
would
likely
bind
to
the
glass
that
covers
the
PV
cells
and
be
retained
there.
Release
of
any
toxic
materials
from
solid
state
inverters
is
also
unlikely
provided
appropriate
electrical
and
installation
requirements
are
followed.
For
more
information
on
public
safety
and
fire,
see
the
Public
Safety
section
of
this
document.
We
should
also
note
that
usually
the
rain
is
sufficient
to
keep
the
panels
clean,
so
no
extra
cleaning
in
which
cleaning
products
might
be
used,
is
necessary.
6
Resources:
Fthenakis,
V.M.,
Overview
of
Potential
Hazards
in
Practical
Handbook
of
Photovoltaics:
Fundamentals
and
Applications,
General
editors
T.
Markvart
and
L.
Castaner,
to
be
published
by
Elsevier
in
2003.
Fthenakis,
V.M.
Life
cycle
impact
analysis
of
cadmium
in
CdTe
PV
production.
Renewable
and
Sustainable
Energy
Reviews
8,
303-‐334,
2004.
Fthenakis
V.M.,
Kim
H.C.,
Colli
A.,
and
Kirchsteiger
C.,
Evaluation
of
Risks
in
the
Life
Cycle
of
Photovoltaics
in
a
Comparative
Context,
21st
European
Photovoltaic
Solar
Energy
Conference,
Dresden,
Germany,
4-‐8
September
2006.
Moskowitz
P.
and
Fthenakis
V.,
Toxic
materials
released
from
photovoltaic
modules
during
fires;
health
risks,
Solar
Cells,
29,
63-‐71,
1990.
Sherwani,
A.F.,
Usmani,
J.A.,
&
Varun.
Life
cycle
assessment
of
solar
PV
based
electricity
generation
systems:
A
review.
Renewable
and
Sustainable
Energy
Reviews.
14,
540-‐544,
2010.
Zayed,
J;
Philippe,
S
(2009-‐08).
"Acute
Oral
and
Inhalation
Toxicities
in
Rats
With
Cadmium
Telluride"
(PDF).
International
journal
of
toxicology
(International
Journal
of
Toxicology)
28
(4):
259–65.
doi:10.1177/1091581809337630.
PMID
19636069. http://ijt.sagepub.com/cgi/content/short/28/4/259.
7
End-‐of-‐Life/Decommissioning
Question:
How
do
I
manage
solar
panels
after
they
are
decommissioned
and
no
longer
in
use?
Can
they
be
recycled
and
do
hazardous
waste
disposal
requirements
apply?
Bottom
Line:
As
more
solar
panels
are
decommissioned
interest
in
recycling
the
panels
has
increased
in
Europe
and
the
U.S.
Massachusetts
regulations
ensure
proper
disposal
and
recycling
of
panels
if
they
have
components
that
constitute
solid
or
hazardous
waste
under
state
regulations.
More
information:
The
average
life
of
solar
PV
panels
can
be
20-‐30
years
(or
longer)
after
initial
installation.
PV
cells
typically
lose
about
0.5%
of
their
energy
production
capacity
per
year.
At
the
time
of
decommissioning,
panels
may
be
reused,
recycled
or
disposed.
Since
widespread
use
of
solar
PV
is
recent
in
Massachusetts,
only
a
small
percentage
of
solar
panels
in
use
in
the
state
have
had
to
be
replaced
due
to
damage
or
reached
the
end
of
their
useful
lifetime.
A
significant
increase
in
the
amount
of
end-‐of-‐life
PV
modules
is
expected
over
the
next
few
decades.
When
solar
panels
are
decommissioned
and
discarded,
state
rules
require
that
panel
disposal
be
“properly
managed”
pursuant
to
the
Massachusetts
hazardous
waste
regulations,
310
CMR
30.000.
There
are
many
different
types
of
solar
panels
used
in
ground-‐mounted
or
roof
mounted
solar
PV
systems;
some
of
these
panels
have
components
that
may
require
special
hazardous
waste
disposal
or
recycling.
Solar
module
manufacturers
typically
provide
a
list
of
materials
used
in
the
manufacturing
of
their
product,
which
may
be
used
to
determine
the
proper
disposal
requirements
at
the
time
of
decommissioning.
Under
the
hazardous
waste
regulations,
the
burden
is
on
the
generator
of
the
panels
to
determine
if
the
waste
being
generated
(the
solar
panels)
is
hazardous
or
not.
This
determination
can
be
made
using
“knowledge”
(i.e.
an
MSDS
sheet
listing
the
materials
used
in
manufacture
of
the
panels)
or
testing
(i.e.
the
Toxicity
Characteristic
Leaching
Procedure
–
TCLP).
If
a
panel
is
tested
and
passes
TCLP
then
it
is
regulated
as
a
solid
waste;
if
it
fails
TCLP
then
it
is
regulated
as
a
hazardous
waste.
However,
if
the
solar
panel
is
determined
to
be
hazardous
due
solely
to
the
presence
of
metal-‐bearing
circuit
boards,
the
panels
may
be
conditionally
exempt
from
the
hazardous
waste
regulations
if
destined
for
recycling.
See
310
CMR
30.202(5)(d)-‐(e)
in
the
Mass.
Hazardous
Waste
Regulations.4
People
who
lease
land
for
solar
projects
are
encouraged
to
include
end-‐of-‐life
panel
management
as
part
of
the
lease.
In
cases
where
panels
are
purchased,
owners
need
to
determine
whether
the
end-‐of
4
(5)
The
following
materials
are
not
subject
to
310
CMR
30.200,
or
any
other
provision
of
310
CMR
30.000:
(d)
Whole
used
circuit
boards
being
recycled
provided
they
are
free
of
mercury
switches,
mercury
relays,
nickel-‐cadmium
batteries,
or
lithium
batteries.
(e)
Shredded
circuit
boards
being
recycled
provided
that
they
are:
1.
managed
in
containers
sufficient
to
prevent
a
release
to
the
environment
prior
to
recovery;
and,
2.
free
of
mercury
switches,
mercury
relays
and
nickel-‐cadmium
batteries
and
lithium
batteries.
8
life
panels
are
a
solid
or
hazardous
waste
and
dispose
or
recycle
the
panels
appropriately.
Massachusetts
regulations
require
testing
of
waste
before
disposal.
Because
of
the
various
materials
used
to
produce
solar
panels
(such
as
metal
and
glass),
interest
in
recycling
of
solar
modules
has
grown.
Throughout
Europe,
a
not-‐for-‐profit
association
(PV
Cycle)
is
managing
a
voluntary
collection
and
recycling
program
for
end-‐of-‐life
PV
modules.
The
American
photovoltaic
industry
is
not
required
by
state
or
federal
regulation
to
recycle
its
products,
but
several
solar
companies
are
starting
to
recycle
on
a
voluntary
basis.
Some
manufacturers
are
offering
end-‐of-‐life
recycling
options
and
independent
companies
looking
to
recycle
solar
modules
are
growing.
This
allows
for
the
recycling
of
the
PV
panels
and
prevents
issues
with
the
hazardous
materials.
Currently,
the
California
Department
of
Toxic
Substances
Control
is
considering
standards
for
the
management
of
solar
PV
panels
at
the
end
of
their
use.
DOER’s
model
zoning
provides
language
on
requirements
for
abandonment
and
decommissioning
of
solar
panels
for
use
by
local
officials
considering
local
approvals
for
these
projects.
Resources
End-‐of-‐life
PV:
then
what?
-‐
Recycling
solar
PV
panels
http://www.renewableenergyfocus.com/view/3005/end-‐of-‐life-‐pv-‐then-‐what-‐recycling-‐solar-‐pv-‐panels/
MassDEP
Hazardous
Waste
Regulations
310
CMR
30.000
http://www.mass.gov/eea/agencies/massdep/recycle/regulations/310-‐cmr-‐30-‐000.html
PV
Cycle,
Europe:
http://www.pvcycle.org/
California
Department
of
Toxic
Substances
Control,
Proposed
Standards
for
the
Management
of
Hazardous
Waste
Solar
Modules,
http://www.dtsc.ca.gov/LawsRegsPolicies/Regs/Reg_Exempt_HW_Solar_Panels.cfm
9
Ambient
Temperature
(“Heat
Island”)
The
Question:
Does
the
presence
of
ground-‐mounted
solar
PV
arrays
cause
higher
ambient
temperatures
in
the
surrounding
neighborhood
(i.e.,
the
“heat
island”
effect)?
Bottom
Line:
All
available
evidence
indicates
that
there
is
no
solar
“heat
island”
effect
caused
by
the
functioning
of
solar
arrays.
Cutting
shade
trees
for
solar
PV
might
increase
the
need
for
cooling
if
those
trees
were
shading
buildings.
This
is
primarily
a
concern
in
town
centers
and
residential
areas
(locations
where
large
ground-‐mounted
PV
is
not
encouraged)
and
is
a
potential
impact
of
any
development
activity
that
requires
tree-‐cutting.
More
Information:
All
available
evidence
indicates
that
there
is
no
solar
“heat
island”
effect
caused
by
the
functioning
of
solar
arrays.
Solar
panels
absorb
photons
from
direct
sunlight
and
convert
it
to
electricity.
This
minimizes
the
likelihood
of
substantially
changing
temperatures
at
the
site
or
the
surrounding
neighborhood.
For
an
area
with
no
PV
system,
solar
energy
impacting
the
ground
is
either
reflected
or
absorbed.
There
is
no
research
to
support
heat
production
from
the
solar
panels
themselves.
Sunpower,
a
private
solar
manufacturer,
conducted
a
study
on
the
impact
of
solar
PV
on
the
local
temperature,
and
concluded
that
a
solar
PV
array
can
absorb
a
higher
percentage
of
heat
than
a
forested
parcel
of
land
without
an
array.
The
study
points
out
that
while
solar
PV
modules
can
reach
high
operating
temperatures
up
to
120
degrees
Fahrenheit,
they
are
thin
and
lightweight
and
therefore
do
not
store
a
large
amount
of
heat.
Because
of
this,
and
the
fact
that
panels
are
also
shown
to
cool
to
ambient
air
temperature
shortly
after
the
sun
sets,
the
Sunpower
study
concludes
that
the
area
surrounding
a
large-‐scale
solar
array
is
unlikely
to
experience
a
net
heating
change
from
the
panels.
If
trees
are
removed
that
were
previously
shading
a
building,
that
building
could
get
warmer
in
full
sunshine
than
when
the
trees
were
shading
it.
The
June
1,
2011
tornado
that
ripped
through
Western
Massachusetts
created
an
opportunity
to
empirically
measure
the
effects
of
the
loss
of
neighborhood
trees
on
temperatures
and
air
humidity
in
the
streets.
A
report
by
the
U.S.
Department
of
Agriculture
Forest
Service
concluded
that
daily
mean
morning
and
afternoon
temperatures
were
typically
greater
in
the
tornado-‐impacted
neighborhood
in
Springfield,
Massachusetts
than
in
the
unaffected
neighborhood
and
forest
sites,
but
were
similar
at
night.
Residents
noted
increased
use
of
air-‐conditioning
units
and
an
overall
increase
in
energy
costs
in
July
and
August
of
2011.
Resources:
SUNPOWER,
Impact
of
PV
Systems
on
Local
Temperature,
July
2010
USDA
Forest
Services
report:
http://www.regreenspringfield.com/wp-‐
content/uploads/2011/11/tornado%20climate%20report%203.pdf
10
Electric
and
Magnetic
Fields
(EMF)
The
Question:
What,
if
any,
health
risks
do
the
electric
and
magnetic
fields
(EMF)
from
solar
panels
and
other
components
of
solar
PV
arrays
pose?
Bottom
Line:
Electric
and
magnetic
fields
are
a
normal
part
of
life
in
the
modern
world.
PV
arrays
generate
EMF
in
the
same
extremely
low
frequency
(ELF)
range
as
electrical
appliances
and
wiring
found
in
most
homes
and
buildings.
The
average
daily
background
exposure
to
magnetic
fields
is
estimated
to
be
around
one
mG
(milligauss
–
the
unit
used
to
measure
magnetic
field
strength),
but
can
vary
considerably
depending
on
a
person’s
exposure
to
EMF
from
household
electrical
devices
and
wiring.
The
lowest
exposure
level
that
has
been
potentially
associated
with
a
health
effect
is
three
mG.
Measurements
at
three
commercial
PV
arrays
in
Massachusetts
demonstrated
that
their
contributions
to
off-‐site
EMF
exposures
were
low
(less
than
0.5
mG
at
the
site
boundary),
which
is
consistent
with
the
drop
off
of
EMF
strength
based
on
distance
from
the
source.
More
Information:
Solar
PV
panels,
inverters
and
other
components
that
make
up
solar
PV
arrays
produce
extremely
low
frequency
EMF
when
generating
and
transmitting
electricity.
The
extremely
low
frequency
EMF
from
PV
arrays
is
the
same
as
the
EMF
people
are
exposed
to
from
household
electrical
appliances,
wiring
in
buildings,
and
power
transmission
lines
(all
at
the
power
frequency
of
60
hertz).
EMF
produced
by
cell
phones,
radios
and
microwaves
is
at
much
higher
frequencies
(30,000
hertz
and
above).
Electric
fields
are
present
when
a
device
is
connected
to
a
power
source,
but
are
shielded
or
blocked
by
common
materials,
resulting
in
low
potential
for
exposures.
On
the
other
hand,
magnetic
fields,
which
are
only
generated
when
a
device
is
turned
on,
are
not
easily
shielded
and
pass
through
most
objects,
resulting
in
greater
potential
for
exposure.
Both
types
of
fields
are
strongest
at
the
source
and
their
strength
decreases
rapidly
as
the
distance
from
the
source
increases.
For
example,
the
magnetic
field
from
a
vacuum
cleaner
six
inches
away
from
the
motor
is
300
mG
and
decreases
to
two
mG
three
feet
away.
People
are
exposed
to
EMF
during
normal
use
of
electricity
and
exposure
varies
greatly
over
time,
depending
on
the
distance
to
various
household
appliances
and
the
length
of
time
they
are
on.
The
daily
average
background
level
of
magnetic
fields
for
US
residents
is
one
mG.
EMF
from
PV
Arrays:
Solar
PV
panels
produce
low
levels
of
extremely
low
frequency
(ELF)
EMF,
with
measured
field
strengths
of
less
than
one
mG
three
inches
from
the
panel.
Solar
PV
power
inverters,
transformers
and
conduits
generate
higher
levels
of
ELF-‐EMF.
The
amount
of
ELF-‐EMF
is
proportional
to
the
electrical
capacity
of
the
inverter
and
is
greater
when
more
current
(electricity)
is
flowing
through
a
power
line.
In
a
study
of
two
PV
arrays
(using
10-‐20
kW
invertors)
in
Kerman
and
Davis,
California,
the
magnetic
field
was
highest
at
the
inverters
and
transformers,
but
decreased
rapidly
to
less
than
one
mG
within
50
feet
of
the
units,
well
within
the
boundary
of
the
PV
array
(Chang
and
Jennings
1994).
This
data
indicates
that
extremely
low
frequency
EMF
field
strengths
at
residences
near
systems
of
this
size
would
be
below
the
typical
levels
experienced
by
most
people
at
home.
The
highest
extremely
low
frequency
EMF
(up
to
1,050
mG)
was
found
next
to
an
inverter
unit
at
the
point
of
entry
of
the
electrical
conduits.
Even
this
11
value
is
less
than
the
extremely
low
frequency
EMF
reported
for
some
common
household
devices
such
as
an
electric
can
opener
with
a
maximum
of
1500
mG
at
6
inches.
In
a
recent
study
of
three
ground
mounted
PV
arrays
in
Massachusetts,
the
above
results
were
confirmed.
The
PV
arrays
had
a
capacity
range
of
1
to
3.5
MW.
Magnetic
field
levels
along
the
PV
array
site
boundary
were
in
the
very
low
range
of
0.2
to
0.4
mG.
Magnetic
fields
at
3
to
7
feet
from
the
inverters
ranged
from
500
to
150
mG.
At
a
distance
of
150
feet
from
the
inverters,
these
fields
dropped
back
to
very
low
levels
of
0.5
mG
or
less,
and
in
many
cases
to
much
less
than
background
levels
(0.2
mG).
Potential
Health
Effects:
Four
research
studies
have
reported
an
association
between
three
to
four
mG
EMF
exposure
and
childhood
leukemia,
while
11
other
studies
have
not.
These
studies
are
inconsistent
and
do
not
demonstrate
a
causal
link
that
would
trigger
a
World
Health
Organization
(WHO)
designation
of
EMF
as
a
possible
carcinogen5.
Studies
looking
at
other
cancers
in
humans
and
animals
have
not
found
evidence
of
a
link
to
residential
ELF-‐EMF
exposure.
Reference
Exposure
Levels:
To
protect
the
general
public
from
health
effects
from
short-‐term
high
level
magnetic
fields,
the
International
Commission
on
Non-‐Ionizing
Radiation
Protection
(ICNIRP,
2010)
advised
an
exposure
limit
for
extremely
low
frequency
magnetic
fields
at
2000
mG.
ICNIRP
determined
that
the
evidence
on
the
impact
of
long-‐term
exposure
to
low
level
magnetic
fields
was
too
uncertain
to
use
to
set
a
guideline.
Guidelines
for
the
magnetic
field
allowed
at
the
edge
of
transmission
line
right-‐of-‐
ways
have
been
set
at
200
mG
by
Florida
and
New
York.
Exposure
to
magnetic
fields
greater
than
1000
mG
is
not
recommended
for
people
with
pacemakers
or
defibrillators
(ACGIH,
2001).
Resources:
American
Conference
of
Government
Industrial
Hygienist
(ACGIH).
2001.
as
cited
in
NIEHS
2002.
Chang,
GJ
and
Jennings,
C.
1994.
Magnetic
field
survey
at
PG&E
photovoltaic
sites.
PG&E
R&D
Report
007.5-‐94-‐6.
Electric
Power
Research
Institute
(EPRI).
2012.
EMF
and
your
health.
http://my.epri.com/portal/server.pt?Abstract_id=000000000001023105.
International
Commission
on
Non-‐Ionizing
Radiation
Protection
(ICNIRP).
2010.
ICNIRP
Guidelines
for
limiting
exposure
to
time-‐varying
electric
and
magnetic
fields
(1
Hz
–
100kHz).
Health
Physics
99(6):818-‐
836.
National
Cancer
Institute
(NCI).
2005.
Magnetic
Field
Exposure
and
Cancer:
Questions
and
Answers.
U.S.
Department
of
Health
and
Human
Services,
National
Institutes
of
Health.
Available
http://www.cancer.gov/cancertopics/factsheet/Risk/magnetic-‐fields,
accessed
May
14,
2012.
5
WHO
has
designated
ELF-‐EMF
as
a
possible
carcinogen.
The
use
of
the
label
“possible
carcinogen”
indicates
that
there
is
not
enough
evidence
to
designate
ELF-‐EMF
as
a
“probable
carcinogen
“or
“human
carcinogen,”
the
two
indicators
of
higher
potential
for
being
carcinogenic
in
humans.
12
National
Institute
of
Environmental
Health
Science
(NIEHS)
2002.
Electric
and
Magnetic
Fields
Associated
with
the
Use
of
Electric
Power:
Questions
and
Answers.
Available
http://www.niehs.nih.gov/health/assets/docs_p_z/results_of_emf_research_emf_questions_answers_b
ooklet.pdf,
accessed
May
11,
2012.
National
Institute
of
Environmental
Health
Science
(NIEHS)
web
page
on
EMF.
Available
http://www.niehs.nih.gov/health/topics/agents/emf/,
accessed
May
11,
2012.
Oregon
Department
of
Transportation
(Oregon
DOT).
Scaling
public
concerns
of
electromagnetic
fields
produced
by
solar
photovoltaic
arrays.
Produced
by
Good
Company
for
ODOT
for
the
West
Linn
Solar
Highway
Project.
Available
www.oregon.gov/ODOT/HWY/OIPP/docs/emfconcerns.pdf.
World
Health
Organization
(WHO).
2007.
Electromagnetic
fields
and
public
health:
Exposure
to
extremely
low
frequency
fields.
Fact
sheet
N°322.
June
2007.
Available
http://www.who.int/mediacentre/factsheets/fs322/en/index.html,
accessed
May
16,
2012.
This
fact
sheet
provides
a
short
summary
of
the
in-‐depth
review
documented
in
the
WHO
2007,
Environmental
Health
Criteria
238.
Available
http://www.who.int/peh-‐emf/publications/elf_ehc/en/index.html.
13
Property
Values
Question:
How
do
ground-‐mounted
solar
PV
arrays
adjacent
to
residential
neighborhoods
influence
the
property
values
in
those
neighborhoods?
Bottom
Line:
No
research
was
found
specific
to
ground-‐mounted
solar
PV
and
property
values.
Residential
property
value
research
on
roof-‐mounted
solar
PV
and
wind
turbines
illustrates
no
evidence
of
devaluation
of
homes
in
the
area.
Municipalities
that
adopt
zoning
for
solar
facilities
may
want
to
consider
encouraging
project
developers
to
include
screening
vegetation
along
site
borders
to
minimize
visual
impacts
on
surrounding
neighborhoods.
More
Information:
A
review
of
literature
nationwide
shows
little
evidence
that
solar
arrays
influence
nearby
property
values.
An
analysis
focused
on
roof-‐mounted
solar
PV
done
by
the
U.S.
Department
of
Energy
Lawrence
Berkeley
National
Laboratory
concludes
that
household
solar
installation
actually
increases
home
property
values.
This
research
analyzes
a
large
dataset
of
California
homes
that
sold
from
2000
through
mid-‐2009
with
PV
installed.
Across
a
large
number
of
repeat
sales
model
specifications
and
robustness
tests,
the
analysis
finds
strong
evidence
that
California
homes
with
PV
systems
have
sold
for
a
premium
over
comparable
homes
without
PV
systems.
Resources:
An
Analysis
of
the
Effects
of
Residential
Photovoltaic
Energy
Systems
on
Home
Sales
Prices
in
California
http://emp.lbl.gov/sites/all/files/lbnl-‐4476e.pdf
14
Public
Safety
(including
fires)
Question:
What
public
safety
issues
arise
from
people’s
(including
children)
access
to
areas
where
solar
arrays
are
installed?
Can
electrical
and
other
equipment
associated
with
solar
projects
cause
electrical
fires?
Bottom
Line:
Large-‐scale
ground-‐mounted
arrays
are
typically
enclosed
by
fencing.
This
prevents
children
and
the
general
public
from
coming
into
contact
with
the
installations,
thus
preventing
unsafe
situations.
The
National
Electric
Code
has
mandatory
requirements
to
promote
the
electrical
safety
of
solar
PV
arrays.
Emergency
personnel
responding
to
potential
emergencies
at
a
solar
PV
site
face
the
most
risk,
but
the
solar
industry
and
firefighters
provide
training
and
education
for
emergency
personnel
to
ensure
that
the
proper
safety
precautions
are
taken.
More
Information:
The
National
Electric
Code
has
mandatory
requirements
for
the
electrical
safety
of
solar
PV
arrays.
To
protect
against
intruders,
Article
690
of
the
National
Electric
Code
covers
the
safety
standards
for
solar
PV
installation
and
requires
that
conductors
installed
as
part
of
solar
PV
be
“not
readily
accessible”.
With
a
large-‐scale
ground-‐mounted
array,
a
fence
is
typically
installed
around
the
system
to
prevent
intruders.
Some
communities
have
solar
PV
or
signage
by-‐laws
that
require
identification
of
the
system
owner
and
24-‐hour
emergency
contact
information.
DOER’s
Model
by-‐Law/ordinance
requires
owners
of
solar
PV
facilities
to
provide
a
copy
of
the
project
summary,
electrical
schematic,
and
site
plan
to
the
local
fire
chief,
who
can
then
work
with
the
owner
and
local
emergency
services
to
develop
an
emergency
response
plan.
These
measures
can
be
combined
with
products
to
prevent
theft
of
the
panels.
Some
are
very
low
cost
options
(fastener
type)
while
there
are
other
options
that
are
more
expensive
(alarm
system
type)
but
also
more
effective.
The
biggest
potential
risk
associated
with
solar
PV
systems
is
the
risk
of
shock
or
electrocution
for
firefighters
and
other
emergency
responders
who
could
come
in
contact
with
high
voltage
conductors.
A
2010
study
on
firefighter
safety
and
emergency
response
for
solar
PV
systems
by
the
Fire
Protection
Research
Foundation,
based
in
Quincy,
Massachusetts,
recommended
steps
firefighters
can
take
when
dealing
with
wiring
and
other
components
that
may
be
energized.
The
Solar
Energy
Business
Association
of
New
England
(SEBANE)
has
been
working
to
provide
training
and
education
to
first-‐responders
to
identify
and
avoid
potential
hazards
when
responding
to
a
solar
PV
fire.
For
more
information
about
toxics/fires,
see
the
Hazardous
Materials
Section.
Resources:
Moskowitz,
P.D.
and
Fthenakis,
V.M.,
Toxic
Materials
Released
from
Photovoltaic
Modules
During
Fires:
Health
Risks,
Solar
Cells,
29,
63-‐71,
1990.
21.
Solar
America
Board
for
Codes
and
Standards
http://www.solarabcs.org/about/publications/reports/blindspot/pdfs/BlindSpot.pdf
Fire
Fighter
Safety
and
Emergency
Response
for
Solar
Power
Systems:
Final
Report,
May
2010.
Prepared
by
The
Fire
Protection
Research
Foundation
15
National
Electric
Code
Article
250:
Grounding
and
Bonding,
Article
300:
Wiring
Methods,
Article
690
Solar
PV
Systems,
Article
705
Interconnected
Electric
Power
Production
Sources
16
Historic
Preservation
The
Question:
What
are
the
appropriate
standards
when
land
with
historical
or
archaeological
significance
is
developed
for
large-‐scale
solar
PV
arrays?
Bottom
Line:
Parties
undertaking
solar
PV
projects
with
state
or
federal
agency
involvement
must
provide
the
Massachusetts
Historical
Commission
(MHC)
with
complete
project
information
as
early
as
possible
in
the
planning
stage,
by
mail
to
the
MHC’s
office
(see
Resources).
Parties
should
also
contact
local
planning,
historical
or
historic
district
commissions
to
learn
about
any
required
local
approvals.
Municipalities
should
also
take
the
presence
of
historic
resources
into
account
when
establishing
zoning
regulations
for
solar
energy
facilities
in
order
to
avoid
or
minimize
impacts.
More
Information:
Land
being
evaluated
for
the
siting
of
large-‐scale
solar
PV
has
historical
or
archaeological
significance
including
properties
listed
in
the
National
or
State
Registers
of
Historic
Places
and/or
the
Inventory
of
Historic
and
Archaeological
Assets
of
the
Commonwealth.
Federal
and
state
laws
require
that
any
new
construction,
demolition
or
rehabilitation
projects
(including
new
construction
of
solar
PV)
that
propose
to
use
funding,
licenses
or
permits
from
federal
or
state
government
agencies
must
be
reviewed
by
the
MHC
so
that
feasible
alternatives
are
developed
and
implemented
to
avoid
or
mitigate
any
adverse
effects
to
historic
and
archaeological
properties.
Projects
receiving
federal
funding,
licenses
or
permits
are
reviewed
by
the
involved
federal
agency
in
consultation
with
the
MHC
and
other
parties
in
compliance
with
Section
106
of
the
National
Historic
Preservation
Act
of
1966
(16
U.S.C.
470f)
and
the
implementing
regulations
(36
CFR
800)
in
order
to
reach
agreement
to
resolve
any
adverse
effects.
Projects
receiving
state
funding,
licenses
or
permits
must
notify
the
MHC
in
compliance
with
M.G.L.
c.
9,
ss.
26-‐27C
and
the
implementing
regulations
950
CMR
71.
If
the
MHC
determines
that
the
project
will
have
an
adverse
effect,
the
involved
state
agency,
the
project
proponent,
the
local
historical
preservation
agencies,
and
other
interested
parties
consult
to
reach
an
agreement
that
outlines
measures
to
be
implemented
to
avoid,
minimize,
or
mitigate
adverse
effects.
For
projects
with
both
federal
and
state
agency
involvement,
the
Section
106
process
is
used.
Some
communities
have
local
preservation
ordinances
or
established
local
historic
districts
that
require
local
approval
for
new
construction
visible
from
a
public
way.
Local
historic
district
commissions
have
adopted
design
guidelines
for
new
construction
within
their
historic
districts
and
historic
neighborhoods.
However,
these
guidelines
must
account
for
Chapter
40C
Section
7
of
the
General
Laws,
which
requires
a
historic
district
commission
to
consider
the
policy
of
the
Commonwealth
to
encourage
the
use
of
solar
energy
systems
and
to
protect
solar
access.
Resources:
Federal
Agency
Assisted
Projects:
Section
106
review
information
and
the
federal
regulations
36
CFR
800
are
available
at
the
Advisory
Council
on
Historic
Preservation
(ACHP)
web
site:
www.achp.gov.
Check
with
the
involved
federal
agency
for
how
they
propose
to
initiate
the
MHC
notification
required
by
36
CFR
800.3.
State
Agency
Assisted
Projects:
17
Massachusetts
General
Laws
Chapter
9,
sections
26-‐27C
MHC
Regulations
950
CMR
71
(available
from
the
State
House
Bookstore)
MHC
Review
&
Compliance
FAQs
http://www.sec.state.ma.us/mhc/mhcrevcom/revcomidx.htm
MHC
Project
Notification
Form
(PNF)
&
Guidance
for
Completing
the
PNF
and
required
attachments
(USGS
locus
map,
project
plans,
current
photographs
keyed
to
the
plan).
Mail
or
deliver
the
complete
project
information
to
the
MHC’s
office:
http://www.sec.state.ma.us/mhc/mhcform/formidx.htm
General
Guidance
about
Designing
Solar
PV
Projects
on
Historic
Buildings
and
in
Historic
Areas:
http://www.nrel.gov/docs/fy11osti/51297.pdf
18
Noise
Question:
Do
the
inverters,
transformers
or
other
equipment
used
as
part
of
ground-‐mounted
solar
PV
create
noise
that
will
impact
the
surrounding
neighborhood?
Bottom
Line:
Ground-‐mounted
solar
PV
array
inverters
and
transformers
make
a
humming
noise
during
daytime,
when
the
array
generates
electricity.
At
50
to
150
feet
from
the
boundary
of
the
arrays,
any
sound
from
the
inverters
is
inaudible.
Parties
that
are
planning
and
designing
ground-‐mounted
solar
PV
should
explore
options
to
minimize
noise
impacts
to
surrounding
areas.
This
could
include
conducting
pre-‐construction
sound
studies,
evaluating
where
to
place
transformers,
and
undertaking
appropriate
noise
mitigation
measures.
More
Information:
Most
typically,
the
source
of
noise
associated
with
ground-‐mounted
solar
PV
comes
from
inverters
and
transformers.
There
also
may
be
some
minimal
noise
from
switching
gear
associated
with
power
substations.
The
crackling
or
hissing
sound
caused
by
high-‐voltage
transmission
lines
(the
“Corona
Effect”)
is
not
a
concern
in
the
case
of
solar
PV,
which
uses
lower
voltage
lines.
Parties
siting
ground-‐mounted
solar
PV
projects
should
consult
equipment
manufacturers
to
obtain
information
about
sound
that
can
be
expected
from
electrical
equipment,
since
this
can
vary.
For
example,
according
to
manufacturer’s
information,
a
SatCon
Powergate
Plus
1
MW
Commercial
Solar
PV
Inverter
has
an
unshielded
noise
rating
of
65
decibels
(dBA)
at
five
feet.
This
is
approximately
the
sound
equivalent
of
having
a
normal
conversation
with
someone
three
feet
away.
Another
source
of
information
is
the
National
Electrical
Manufacturers
Association
(NEMA)
standards,
which
will
provide
maximum
sound
levels
from
various
equipment
arrays.
From
NEMA,
a
large
dry-‐type
transformer
(2001-‐3333
kVA)
that
is
forced
air
cooled
and
ventilated
has
an
average
sound
level
of
71
dBA,
which
is
approximately
the
sound
level
one
would
expect
from
a
vacuum
cleaner
at
ten
feet.
There
may
be
several
such
units
on
a
substantially
sized
PV
site,
which
would
increase
the
sound
level
to
some
degree.
Sound
impacts
from
electrical
equipment
can
be
modeled
to
the
property
line
or
nearest
sensitive
receptor
(residence).
Sound
impacts
can
be
mitigated
with
the
use
of
enclosures,
shielding
and
careful
placement
of
the
sound-‐generating
equipment
on-‐site.
The
rule
of
thumb
for
siting
noise-‐generating
equipment
is
that
the
sound
impact
can
be
reduced
by
half
by
doubling
the
distance
to
the
receptor.
In
some
areas
both
in
the
US
and
Canada,
sound
impact
analysis
is
required
as
part
of
the
permitting
process
for
large
PV
systems.
For
example,
in
the
Province
of
Ontario,
Canada,
any
project
greater
than
12
MW
is
required
to
perform
a
sound
impact
analysis
(Ontario
359/09).
California
also
requires
a
sound
impact
analysis
for
large
PV
projects.
Massachusetts
currently
has
no
such
requirement,
but
the
reader
should
note
that
ground-‐mounted
systems
in
Massachusetts
very
rarely
go
over
6
MW,
which
is
half
the
size
of
the
12
MW
that
triggers
a
sound
analysis
in
Ontario.
A
recent
study
measured
noise
levels
at
set
distances
from
the
inverters
and
from
the
outer
boundary
of
three
ground-‐mounted
PV
arrays
in
Massachusetts
with
a
capacity
range
of
1
to
3.5
MW.
Close
to
the
inverters
(10
feet),
sound
levels
varied
from
an
average
of
55
dBA
to
65
dBA.
Sound
levels
along
the
fenced
boundary
of
the
PV
arrays
were
generally
at
background
levels,
though
a
faint
inverter
hum
could
be
heard
at
some
locations.
Any
sound
from
the
PV
array
and
equipment
was
inaudible
and
19
sound
levels
were
at
background
levels
at
setback
distances
of
50
to
150
feet
from
the
boundary.
Project
developers
should
consult
with
local
planning
and
zoning
officials
to
determine
if
local
noise
ordinances
may
be
applicable.
Many
local
noise
ordinances
establish
absolute
limits
on
project
impact
noise
(such
as
a
40
dBA
nighttime
limit).
In
these
communities,
a
noise
impact
assessment
may
be
required.
Resources:
NEMA
Standards
Publication
No.
TR=1-‐1993(R2000),
Transformers,
Regulators
and
Reactors
Noise
Assessment:
Borrego
1
Solar
Project,
MUP
3300-‐10-‐26
Prepared
by
Ldn
Consulting,
Inc,
Fallbrook,
CA.
January
14,
2011
Ontario
Regulation
359/09
Renewable
Energy
Approval
(REA)
Regulation,
Ontario
Ministry
of
the
Environment,
Canada
http://www.ontario.ca/environment-‐and-‐energy/renewable-‐energy-‐approvals
Tech
Environmental,
Study
of
Acoustic
and
EMF
levels
from
Solar
Photovoltaic
Projects,
Prepared
for
the
Massachusetts
Clean
Energy
Center,
December
2012,
http://images.masscec.com/uploads/attachments/Create%20Basic%20page/Study_of_Acoustic_and_E
MF_Levels_from_Solar_Photovoltaic_Projects.pdf
20
Water-‐Related
Impacts
Question:
Can
chemicals
that
might
be
contained
in
solar
PV
threaten
public
drinking
water
systems?
Will
flooding
occur
in
cases
where
trees
must
be
removed
in
order
to
install
the
solar
arrays?
How
do
we
ensure
that
wetland
resources
are
protected?
Bottom
Line:
Rules
are
in
place
to
ensure
that
ground-‐mounted
solar
arrays
are
installed
in
a
ways
that
protect
public
water
supplies,
wetlands,
and
other
water
resource
areas.
All
solar
panels
are
contained
in
a
solid
matrix,
are
insoluble
and
are
enclosed.
Therefore,
releases
are
not
a
concern.
More
Information:
Because
trees
offer
multiple
water
management,
cooling
and
climate
benefits,
clear-‐cutting
of
trees
for
the
installation
of
ground-‐mounted
solar
PV
is
discouraged.
For
projects
that
do
propose
to
alter
trees,
the
Massachusetts
Environmental
Policy
Act
(MEPA)
has
thresholds
for
the
proposed
alteration
of
a
certain
number
of
acres
of
land,
the
size
of
electrical
facilities,
and
other
criteria
that
trigger
state
review
of
proposed
projects.
Clear
cutting
of
trees
and
other
aspects
of
proposed
projects
would
be
reviewed
through
an
Environmental
Notification
Form/Environmental
Impact
Statement
if
thresholds
are
triggered.
More
information
is
available
at:
MassDEP
has
determined
that
the
installation
of
solar
arrays
can
be
compatible
with
the
operation
and
protection
of
public
drinking
water
systems.
This
includes
the
installation
of
solar
arrays
within
the
Zone
I,
which
is
a
400-‐foot
protective
radius
around
a
public
ground
water
well.
Solar
projects
proposed
on
lands
owned
by
public
water
systems
outside
the
Zone
I
may
be
approved
subject
to
standard
best
management
practices,
such
as
the
proper
labeling,
storage,
use,
and
disposal
of
products.
MassDEP
has
a
guidance/review
process
in
place
to
ensure
that
the
installation
of
ground-‐mounted
solar
PV
in
these
areas
protects
public
water
supplies.
Installing
solar
arrays
on
undeveloped
land
can
preserve
the
permeable
nature
of
the
land
surface
provided
the
project
design
minimizes
disturbance
to
natural
vegetative
cover,
avoids
concentrated
runoff,
and
precipitation
is
otherwise
recharged
into
the
ground
to
the
greatest
extent
practicable.
Storm
water
flow,
as
well
as
information
about
site-‐specific
soils
and
slope,
is
taken
into
account
during
the
design
and
installation
of
solar
arrays.
MassDEP
discourages
installation
of
ground-‐mounted
solar
PV
systems
in
wetland
areas,
including
riverfront
locations.
Solar
projects
within
wetland
areas
are
unlikely
to
comply
with
the
performance
standards
in
the
Wetlands
Protection
Act
regulations.
If
a
solar
installation
is
proposed
in
a
wetland,
a
riverfront
area,
a
floodplain,
or
within
100
feet
of
certain
wetlands,
the
project
proponent
must
file
a
notice
of
intent
(or
application
to
work
in
wetland
areas)
with
the
local
Conservation
Commission,
which
administers
the
Wetlands
Protection
Act
at
the
municipal
level.
Copies
should
also
go
to
MassDEP.
Solar
installations
may
be
sited
near,
but
outside
of
wetlands,
in
a
manner
that
protects
the
functions
of
wetlands
and
that
minimizes
impacts
from
associated
activities
such
as
access
and
maintenance.
Ancillary
structures
related
to
construction
of
a
solar
installation
or
transmission
of
power
may
be
permitted
to
cross
rivers
and
streams
using
best
design
and
management
practices.
21
Resources:
More
information
about
the
Wetlands
Protection
Act
requirements
may
be
found
in
the
implementing
regulations
at
310
CMR
10.00:
http://www.mass.gov/eea/agencies/massdep/water/regulations/310-‐
cmr-‐10-‐00-‐wetlands-‐protection-‐act-‐regulations.html
MassDEP
Guidance
for
Siting
Wind
and
Solar
in
Public
Water
Supply
Land:
http://www.mass.gov/eea/agencies/massdep/water/regulations/wind-‐and-‐solar-‐energy-‐project-‐on-‐
public-‐water-‐supply-‐land.html
MassDEP
Chapter
91
Guidance
for
Renewable
Energy
Projects:
http://www.mass.gov/eea/agencies/massdep/water/reports/chapter-‐91-‐licensing-‐and-‐renewable-‐
energy.html
22
Glare
Question:
How
important
is
reflectivity
and
potential
visual
impacts
from
solar
projects,
especially
near
airports?
Bottom
Line:
Solar
panels
are
designed
to
reflect
only
about
2
percent
of
incoming
light,
so
issues
with
glare
from
PV
panels
are
rare.
Pre-‐construction
modeling
can
ensure
that
the
placement
of
solar
panels
prevents
glare.
More
Information:
Solar
panels
are
designed
to
absorb
solar
energy
and
convert
it
into
electricity.
Most
are
designed
with
anti-‐reflective
glass
front
surfaces
to
capture
and
retain
as
much
of
the
solar
spectrum
as
possible.
Solar
module
glass
has
less
reflectivity
than
water
or
window
glass.
Typical
panels
are
designed
to
reflect
only
about
2
percent
of
incoming
sunlight.
Reflected
light
from
solar
panels
will
have
a
significantly
lower
intensity
than
glare
from
direct
sunlight.
An
analysis
of
a
proposed
25-‐degree
fixed-‐tilt
flat-‐plate
polycrystalline
PV
system
located
outside
of
Las
Vegas,
Nevada
showed
that
the
potential
for
hazardous
glare
from
flat-‐plate
PV
systems
is
similar
to
that
of
smooth
water
and
not
expected
to
be
a
hazard
to
air
navigation.
Many
projects
throughout
the
US
and
the
world
have
been
installed
near
airports
with
no
impact
on
flight
operations.
United
Kingdom
and
U.S.
aircraft
accident
databases
contain
no
cases
of
accidents
in
which
glare
caused
by
a
solar
energy
facility
was
cited
as
a
factor.
When
siting
solar
PV
arrays
pre-‐construction
modeling
can
ensure
the
panels
are
placed
in
a
way
that
minimizes
any
potential
glare
to
surrounding
areas.
Resources:
Technical
Guidance
for
Evaluating
Selected
Solar
Technologies
on
Airports,
Federal
Aviation
Administration,
November
2010
(currently
under
review),
http://www.faa.gov/airports/environmental/policy_guidance/media/airport_solar_guide.pdf
A
Study
of
the
Hazardous
Glare
Potential
to
Aviators
from
Utility-‐Scale
Flat-‐Plate
Photovoltaic
Systems,
Black
&
Veatch
Corporation,
August
2011,
http://www.isrn.com/journals/re/2011/651857/
Solar
Photovoltaic
Energy
Facilities,
Assessment
of
Potential
Impact
on
Aviation,
Spaven
Consulting,
January
2011:
http://www.solarchoice.net.au/blog/solar-‐panels-‐near-‐airports-‐glare-‐issue/
23
Endangered
Species
and
Natural
Heritage
Question:
Who
ensures
that
rare
animal
and
plant
species
and
their
habitats
are
not
displaced
or
destroyed
during
the
construction
of
ground-‐mounted
solar
PV?
Bottom
Line:
Rules
are
in
place
to
ensure
that
the
installation
of
ground-‐mounted
solar
arrays
protects
state-‐listed
rare
species
and
animals
and
plants.
Project
proponents
can
check
with
the
local
Conservation
Commission
to
determine
if
the
footprint
of
the
solar
PV
project
lies
within
a
rare
species
habtat.
More
Information:
The
Massachusetts
Natural
Heritage
and
Endangered
Species
Program
(NEHSP)
was
created
under
the
Massachusetts
Endangered
Species
Act
(MESA)
and
is
responsible
for
protecting
rare
animal
and
plant
species
and
their
habitats
from
being
displaced
or
destroyed.
Specifically,
NEHSP
reviews
projects
proposed
for:
• Priority
Habitats:
These
are
areas
known
to
be
populated
by
state-‐listed
rare
species
of
animals
or
plants.
Any
project
that
could
result
in
the
alteration
of
more
than
two
acres
of
Priority
Habitat
is
subject
to
NHESP
regulatory
review.
Projects
will
need
to
file
a
MESA
Information
Request
Form,
along
with
a
project
plan,
a
U.S.
Geological
Survey
(USGS)
topographical
map
of
the
site,
and
a
$50
processing
fee.
NHESP
will
let
project
administrators
know
within
30
days
if
the
filing
is
complete,
then
will
determine
within
the
next
60
days
whether
the
project,
as
proposed,
would
result
in
a
“take”
of
state-‐listed
rare
species
that
might
require
the
project
to
redesign,
scale
down,
or
abandon
its
plan.
• Estimated
Habitats:
These
are
a
sub-‐set
of
Priority
Habitats
that
are
based
on
the
geographical
range
of
state-‐listed
rare
wildlife
–
particularly
animals
that
live
in
and
around
wetlands.
If
the
project
is
proposed
for
one
of
these
areas
and
the
local
Conservation
Commission
requires
filing
a
Notice
of
Intent
(NOI)
under
the
Wetlands
Protection
Act,
the
project
will
need
to
submit
copies
of
the
NOI,
project
plans
and
a
U.S.
Geological
Survey
(USGS)
topographical
map
to
NHESP.
Within
30
days
of
receiving
this
information,
NHESP
will
send
its
comments
to
the
Conservation
Commission,
with
copies
to
the
project
administrator,
project
consultants,
and
the
Department
of
Environmental
Protection
(MassDEP).
Resources:
To
learn
more
about
the
NHESP
review
process
and
download
a
MESA
Information
Request
Form,
visit:
http://www.mass.gov/eea/agencies/dfg/dfw/natural-‐heritage/regulatory-‐review/mass-‐endangered-‐
species-‐act-‐mesa/
For
list
of
rare
animal
and
plant
species
in
Massachusetts,
visit:
http://www.mass.gov/eea/agencies/dfg/dfw/natural-‐heritage/species-‐information-‐and-‐
conservation/mesa-‐list/list-‐of-‐rare-‐species-‐in-‐massachusetts.html
24
Hazardous Material Assurance Letter
TJA Clean Energy
Wakeby Road Solar Project
February 1, 2023
Appendix B
Envirotemp FR3 Fluid Information
1
Asa Smith
Subject:FW: FR3 Dielectric Fluid Composition
From: Karl Jakob <Karl_Jakob@cargill.com>
Sent: Friday, February 18, 2022 10:08 AM
To: intern <intern@atlanticcompanies.com>
Cc: Asa Smith <asmith@atlanticcompanies.com>; jake.kennedy <jake.kennedy@shamrockpower.com>; Ryan Kennedy
<ryan.kennedy@shamrockpower.com>
Subject: FR3 Dielectric Fluid Composition
Hi Lukas,
I can confirm that no PFAS/GenX chemicals are in FR3 Fluid, and that we do not use PFAS/GenX chemicals in any of our
processes or plants.
Regards,
Karl Jakob, P.E.
NA Regional Sales Manager, East
Cargill Bioindustrial‐Power Systems
+1 (801) 712‐0607
: karl_jakob@cargill.com
www.cargill.com/bioindustrial | www.envirotempfluids.com | FR3Fluid.com
Hello,
My name is Lukas from Atlantic Design Engineers in Bourne, MA and we are currently working on a solar project and FR3
ester dielectric fluid is planned to be used. For the project to be approved by the town no components can contain
PFAS/GenX chemicals. If you could confirm whether or not the FR3 Envirotemp Natural Ester Fluid contains any
PFAS/GenX chemicals it would be greatly appreciated.
Respectfully,
Lukas Janulaitis
Renewables & Environmental Science
Atlantic Design Engineers, Inc.