Public Comment for the Addition of PV Modules
SERI, along with the Photovoltaic Industry, has taken a leadership role to develop standards for reuse and recycling of Photovoltaic (PV) Modules to further a circular economy approach promoting sustainable outcomes. This process began as SERI convened a working group in October 2020 to explore adding PV Modules to the R2 Standard. The work group concluded in March 2021 that PV Modules should be added. A formal request was made to the R2 Technical Advisory Committee (R2 TAC) to add PV Modules to the R2 Standard, and the R2 TAC’s Consensus Body voted to include PV Modules into the R2 Standard in May 2021. Subsequently, a call was made for stakeholders of PV Modules to join the R2 TAC. Nine members of the PV Industry were added to the R2 TAC, and then the R2 TAC worked for more than one year to develop these requirements to add PV Modules to the R2 Standard.
There are three sections where new language was added to the R2 Standard to incorporate PV Modules. A definition of Photovoltaic (PV) Modules was added to the Definitions. Also, the Focus Materials definition was updated to include Solar Cells. A new Appendix G was added, and the R2 Equipment Categorization (REC) was updated to include a new table for PV Modules and two new categories of functioning PV Modules for reuse. These are new additions to the R2 Standard, not a change to the existing requirements.
First Public Comment Period: April 28th-June 12th 2023
NOW CLOSED
As an ANSI-accredited standards developer, public comment is part of our standards development process, and one that we believe plays a very important part in what makes R2 a Standard that can be relied on to produce positive results.
In accordance with this process, Draft Appendix G was released for the first round of public comment on April 28th, 2023, and closed 45 days later on June 12th. The comments as well as the TAC’s responses can be viewed below.
Based on the first round of public comment, the R2 TAC made changes to Draft Appendix G and those changes will be released for a second round of public comments. The second public comment period will be 45 days, starting on October 6th and ending on November 20th.
This round of public comments will be limited to the revisions made by the R2 TAC to Draft Appendix G, the definitions, and the R2 Equipment Categorization (REC). These changes have been highlighted in RED in the document below.
Please note that some of the requirements in Appendix G are intentionally redundant to be clear as to how PV Modules are incorporated into the existing requirements of the R2 Standard. The scope of PV Modules could include end-of-life modules that may be 20+ years old, or PV Modules that were taken out of use for upgrades on the grid and still have plenty of useful life, or PV Modules may be modules taken out of use because of severe weather damage, or there may be other scenarios where R2 Facilities are receiving PV Modules for reuse or for materials recovery. These proposed additions to the R2 Standard do not have any effect on existing R2 Facilities that do not receive PV Modules.
