For those of you who have been following the progress of Appendix G – PV Modules, we wanted to share another update, including insight from the first public comment period.
The public comment period was open from April 28th to June 12th, 2023, and during that time, SERI received 15 comments from five individual commentors. All comments were anonymized prior to being shared with the R2 Technical Advisory Committee (R2 TAC), and each comment was discussed and debated at both the June and July R2 TAC meetings. When considering comments, the R2 TAC takes into account factors such as: how the proposed change would align with the rest of the R2 Standard, does it create a conflict, is the proposed language auditable, is it too prescriptive, and does it fit with all countries as an international standard, among various other aspects that go into the standards development process.
As an ANSI Accredited Standard Developer, SERI and the R2 TAC operate in accordance with ANSI’s Essential Requirements.
To highlight the decisions that the R2 TAC has to make when engaged in reviewing public comments, we thought this would be a good opportunity to provide a bit of behind-the-scenes insight into their thought process. While all comments are given due consideration, and we will make the public comments and the R2 TAC’s responses public, the one comment provided about batch testing makes a good example to dive into.
This proposed batch testing change would allow the R2 Facility to use batch testing as a method for testing PV modules for reuse, meaning testing a representative sample from the batch of PV modules and allowing the whole batch to be considered functional based on the results from testing just the sample. This was suggested because PV module testing can be a time-intensive process.
The counterpoint to allowing batch testing is that the R2 TAC is concerned this method could create a pathway for untested panels to be classified as functional equipment in accordance with the REC and, therefore, not subject to further downstream R2 control. Untested PV modules would be combined with the tested sample, and even if the sample proved to be working properly, non-functional panels could potentially be included. They could then all be sent anywhere without tracking or restriction – including the untested and potentially non-functional panels. Consequently, this could result in illegal transboundary shipments of waste, dumping of broken or non-working panels from the batch in countries that may not have the proper infrastructure to handle the waste or other potentially negative outcomes. Additionally, all other types of electronics in the R2 Standard are required to be individually tested. No batch testing or sampling is allowable under the R2 Standard, and this change would be inconsistent with the rest of the requirements of the R2 Standard.
All public comments are considered one by one, and SERI is compiling a report of comments and the disposition of each comment based on the consensus of the R2 TAC. Public commentors will be notified of the disposition of their comment(s) by August 11th, 2023. After notification, a report with all public comments will also be made available on the SERI website. Please continue to follow the SERI Newsletters and LinkedIn posts for further information on the progress of Appendix G!
