An extract from WindEurope’s Industry Guidance Document, November 2020
Today 34,000 turbines are 15 years or older, representing 36 GW of onshore wind capacity. Out of the 36 GW some 9 GW are 20-24 years old and around 1 GW are 25 years or older. Most of the ageing capacity is in Germany, followed by Spain, Italy and France. This is a significant volume that needs certain logistics in place to proceed with dismantling, collection, transportation, waste management treatment and finally site restoration in a sustainable way.
Source: WindEurope
Source: WindEurope
This creates a big market for decommissioning of onshore wind farms over the next decade. However, an international standard for decommissioning wind turbines does not exist today. WindEurope therefore launched a Task Force for Dismantling and Decommissioning to produce guidelines for sustainable decommissioning. The Task Force identified the main regulations for dismantling onshore wind farms in key European countries – France, Denmark, Germany, Italy, Netherlands, Spain and the UK.
Mapping of Regulations
DISMANTLING
Dismantling of wind turbines is regulated by national legislation as explained below:
Denmark: The municipality typically sets the conditions for decommissioning in the building and operating permit initially issued. Decommissioning must start 1 year after the wind farm has stopped operating at the latest.
France: Decommissioning of wind turbines is regulated by the ‘arrêté du 26 août 2011 relatif à la remise en état et à la constitution des garanties financières pour les installations de production d’électricité utilisant l’énergie mécanique du vent’ and the ‘code de l’environnement’. This regulatory framework has been amended by the ‘arrêté du 22 juin 2020’. Specific provisions are also provided under Article R 515- 107 of the Environmental Code.
Germany: Decommissioning of wind turbines is regulated by the Renewable Energy Sources Act, 2017. Some provisions are also made in the Building Code.
Italy: Decommissioning of wind turbines is regulated by the Ministerial Decree of 10 September 2010 titled “Guidelines for the authorisation of plants powered by renewable sources”.
Netherlands: The dismantling of wind turbines falls under the Building Decree 2012 (https://wetten.overheid.nl/ BWBR0030461/2012-04-01#Hoofdstuk1_Paragraaf1.7).
Spain: There is no regulatory framework on decommissioning of wind turbines in Spain. Any decommissioning requirements are included in the Environmental Impact Assessment (EIA) for each project.
United Kingdom: Decommissioning requirements are set in the planning conditions for each project that has received permission. Most projects will have agreed a ‘decommissioning bond’ with the local planning authority at the point of planning consent to cover the costs of decommissioning, usually in the form of a planning condition.
RESOURCE MANAGEMENT
Concrete: Legislation pertaining to cement as a material: Common cements in Europe are specified by the European standard EN 197-1. Legislation pertaining to recycling cement and concrete: Most European countries don’t have explicit legislation pertaining to wind turbine foundations but concrete waste (EWC-number: 17 01 01) is one waste source in the EU’s construction and demolition waste (CDW) category. Under the EU Waste Framework Directive (2008/98/EC), at least 70% by weight of non-hazardous CDW must be reused or recycled by 2020.
Denmark: Article 2(2) of the Environmental Protection Act, 2016 states that municipalities must adopt regulations on sorting of building and construction waste, allocation of construction and demolition waste and notification of quantities thereof.
France: All demolition waste must be characterised depending on whether it is inert, non-inert but non-hazardous, or non-inert and hazardous, and be treated according to the waste hierarchy (Book V, Title IV Waste of the Environmental Code). According to Article R. 515-106 of the Environmental Code, demolition and dismantling waste must be recovered or disposed of in the sectors duly authorised for this purpose. According to the Arrêté du 26 août 2011 Section 7 Demantelement Article 29:
“The excavation of all the foundations up to the base, with the exception of any piles. By way of derogation, the lower part of the foundations can be kept in the ground on the basis of a study sent to the prefect demonstrating that the environmental balance sheet of the total disbursement is unfavourable, without the excavated depth being less than 2 meters in the land for forest use under the opposable town planning document and 1 m in other cases. Excavated foundations are replaced by earth with characteristics comparable to the land in place near the installation.”
Italy: The most important legislative pieces on CDW management are:
• D.Lgs 152/2006 (and amendements) « Norme in materia di ambiente (Codice ambiente)»;
• D.M. 5/2/98 (amended by Decreto 5/4/06 n. 186) “Individuazione dei rifiuti non pericolosi sottoposti alle procedure semplificate di recupero ai sensi degli articoli 31 e 33 del decreto legislativo 5 febbraio 1997, n. 22”;
Netherlands: Under the Dutch legislation, lap 3, concrete from renovation or demolition of buildings, roads and other infrastructure must be recycled or reused.
Spain: The Royal decree 105/2008 of 1 February regulates the management of construction and demolition waste.
UK: There is no special legislation in place on the disposal of onshore wind turbine foundations in the UK.
Metals
Article 10(2) of the EU Waste Framework Directive (2008/98/EC) states separate collection shall be set up for paper, metal, plastics and glass by 2015. This means that metals that come from the wind turbines should be held separate from other waste streams. Article 11 of the EU Waste Framework Directive 2009/98 states that ‘’members states shall take measures to promote high quality recycling and, to this end, shall set up separate collections of waste where technically, environmentally and economically practicable and appropriate to meet the necessary quality standards for the relevant recycling sectors’’.
Denmark: Article 2(2) of the Environmental Protection Act, 2016 states municipalities must adopt regulations on sorting of building and construction waste, allocation of construction and demolition waste and notification of quantities thereof.
France: It is regulated according to Articles D543-282, R. 541-50 and R. 541-54-1 of the Environmental Code.
Germany: Germany follows the EU Waste Framework Directive (2008/98/EC) for the treatment of metals (Umwelt Bundesamt, 2014). This is transposed in the Commercial Waste Ordinance, 2002. ITALY The Legislative Decree n. 205 of 2 December 2010 transposes the EU Waste Framework Directive.
Netherlands: According to Sectorplannen lap 3, sector plan 12, all metals (ferrous and nonferrous) should be brought to a recycling plant.
Spain: Spain follows the EU Waste Framework Directive (2008/98/ EC) for the treatment of metals. This is transposed in the Law 22/2011 on Waste and Contaminated Land. Regions also have their own legislation.
UK: The UK follows the EU Waste Framework Directive (2008/98/ EC) for the treatment of metals. From 1 January 2015, UK waste regulations require businesses to separate recyclable material from other waste (e.g. the Waste (England and Wales) Regulations 2011 as amended in 2015).
Composites: According to the European classification of wastes, composite blade waste is most often categorised as plastic waste from construction and demolition with the code 17 02 03. To date, few regulatory requirements are in place for the composite waste sector. Nevertheless, there is a clear push towards more circularity in general at the European level as shown by the new EU Circular Economy Action Plan (2020)4 . The European Strategy for Plastics in a Circular Economy (2018)5 stresses that the low reuse and recycling rates (less than 30%) of end-of-life plastics is a key challenge to be addressed. It sets out the vision for ‘circular’ plastics with concrete actions at EU level. The strategy also stresses that the private sector – together with national and regional authorities, cities and citizens – will need to mobilise to fulfil this vision. So far, the focus has been on single-use plastics, microplastics, oxo-plastics and plastic packaging, and not on composite waste.
At the national level, four countries make a clear reference to composite waste in their legislation: Germany, Austria, the Netherlands and Finland. These countries forbid composites from being landfilled or incinerated.
France: Article 20 of the “Arrêté du 22 juin 2020 modifiant l’arrêté du 26 août 2011 relatif aux installations de production d’électricité utilisant l’énergie mécanique du vent […]” sets recycling targets for wind turbines as whole, and rotor blades in particular:
• from 1 July 2022, a minimum of 35% of the rotor mass must be reused or recycled (for existing wind turbines). • after 1 January 2023, 45% of the rotor mass must be reused or recycled (for wind turbines for which a planning application is submitted after this date).
• after 1 January 2025, 55% of the rotor mass must be reused or recycled (for wind turbines for which a planning application is submitted after this date).
Germany: A ban on directly landfilling waste with a total organic content (TOC) higher than 3% came into force in 2009. Considering blades contain an organic part due to the resin that glues together the glass fibres, they cannot be landfilled.
Netherlands: Under the 3rd edition of the National Waste Management Plan, landfilling of composite waste is banned ‘in principle’. However, wind park operators can benefit from an “exemption” if alternative solutions are considered too costly i.e. where the cost of treatment is higher than the benchmark value of €200/t.
Rare earth: Rare earth elements are a group of 17 chemical elements (cerium (Ce), dysprosium (Dy), erbium (Er), europium (Eu), gadolinium (Gd), holmium (Ho), lanthanum (La), lutetium (Lu), neodymium (Nd), praseodymium (Pr), promethium (Pm), samarium (Sm), scandium (Sc), terbium (Tb), thulium (Tm), ytterbium (Yb), and yttrium (Y)), categorised as specialty metals. The rare earth elements used in the production of permanent magnets are neodymium (Nd), terbium (Tb), dysprosium (Dy) and praseodymium (Pr). Neodymium–iron–boron (Nd2Fe14B) magnets are used in wind turbines. These magnets typically contain 29% of Nd and 1-1.5% of Dy. Under the EU Waste Framework Directive (2008/98/ EC), rare earth elements are listed as non-hazardous. To date, there is no specific European or national legislation related to rare earths.
Electric cables: The WEEE Directive 2012/19/EU article 2 section 4(c) states that ‘’this Directive shall not apply to the following EEE: large-scale fixed installations, except any equipment which is not specifically designed and installed as part of those installations”. Under Annex VII of the EU Waste Electrical & Electronic Equipment (WEEE) Directive (2012/19/EU), external electric cables must be removed from any separately collected WEEE and be disposed of or recovered in compliance with the Waste Framework Directive (2008/98/EC).
Oils: The EU Waste Framework Directive (2008/98/EC) states that waste oils must be collected separately (where this is technically feasible) and treated in accordance with the waste hierarchy and without any harm to human health and the environment. Where feasible, waste oils of different characteristics should not be mixed to enable treatment. Member States may apply additional measures such as technical requirements, producer responsibility, economic instruments or voluntary agreements.
Denmark: Denmark follows the EU Waste Framework Directive (2008/98/EC) for the treatment of waste oil via provisions in the Statutory Orders on Waste. Waste oils are primarily treated by regeneration and/or incineration with energy recovery.
France: Waste oil management is regulated by the Code de l’environnement Articles R543-3 to R.543-15. GERMANY Waste oil management is regulated by the Waste Oil Ordinance of 01.05.2002 and Article 19 of the Federal Water Act.
Italy: The Legislative Decree n. 205 of 2 December 2010 transposes the EU Waste Framework Directive. NETHERLANDS The ‘Sector plan 56 Afgewerkte olie’ states that oil from wind turbines should be primarily treated by regeneration and/or incineration with energy recovery.
Spain: Spain follows the EU Waste Framework Directive (2008/98/ EC) for the treatment of waste oil. This is transposed in the Law 22/2011 on Waste and Contaminated Land. Regions also have their own legislation.
UK: In Scotland, Wales and Northern Ireland waste oil management is regulated by the Pollution Prevention Guide under the section ‘Safe storage and disposal of used oils (PPG8)’. In England waste oil management is regulated by the ‘Control of pollution (oil storage) (England) regulations 2001’. This legislation is similar to that of Scotland, Wales and Northern Ireland.
SITE RESTORATION
Site restoration is regulated by national legislation as explained below:
Denmark: The municipality typically sets the conditions for decommissioning in the building and operating permit initially issued. A common requirement is to remove all equipment, including the foundation, as deep as 1m below the surface and rehabilitate the area.
France: Article 1 of the ‘Arrêté du 26 août 2011’ regulates decommissioning of wind turbines. Proposed amendments to the current legal framework will require total excavation of foundations at the end of life except if an environmental impact assessment recommends not to do it. According to Arrêté du 26 août 2011 Section 7 Demantelement Article 29, excavated foundations are replaced by earth with characteristics comparable to the land in place near the installation. The restoration of the site with the disbursement of the crane areas and access roads to a depth of 40 centimetres and the replacement by land of characteristics comparable to the land near the installation, unless the owner of the land on which is located the installation wishes their maintenance in the state.
Germany: Paragraph 35 (5) of the Building Code has the following provisions: “The operator has to issue a declaration of commitment to dismantle the installation and remove all soil sealing when permanently abandoning the site.” The Federal States Committee for Soil Protection has commissioned the development of guidelines on soil protection measures to be observed when dismantling wind turbines.
Italy: The Ministerial Decree of 10 September 2010 requires producers to return the site to its original conditions.
Netherlands: There is no specific legislation regulating the removal of wind turbine foundations in the Netherlands. Instead, any foundation removal requirements are set in the agreements between the landowner and the operator.
Spain: There is no regulatory framework on decommissioning of wind turbines in Spain. Any decommissioning requirements (including site restoration) are included in the EIA for each project.
UK: Decommissioning requirements are set in the planning conditions for each project that has received permission. The consenting authority can include requirements for restoration of land to an acceptable condition as part of the planning approval process.
Decommissioning Plan
The decommissioning plan is the key document for the decommissioning of a wind farm. A decommissioning plan of a wind farm must reflect national and, in some cases, regional or local legislation. The guidelines elaborated in the below attached report provide key ones using an example of a German decommissioning plan as well as an example of a communication plan in France.
Dismantling
The dismantling of a wind farm is also dependant on different national guidelines for demolition. In the case of Germany, we present an overview of the DIN 18007 against which most common procedures are evaluated in terms of their suitability and impact depending on construction, component and building material. Cutting and separating methods as well as loading and transport steps are addressed in the dismantling chapter, together with the health and safety requirements, which are crucial for a sustainable decommissioning.
Resource Management
Wind turbines are a valuable source of resources that can be reintroduced into the circular economy. The aim should preferably be for use over the long-term, as this is the most sustainable application. However, at some point in time, wind turbines will reach the end of its life and valuable resources must be returned to the material cycle. The resource management chapter of these guidelines presents the key materials that can be found in a turbine (metals, oils, rare earths, composites and concrete) and recycling methods for rare earths, composites and concrete.
Site restoration
If not specified otherwise, once decommissioned, the wind farm will have to restore the site to a greenfield. Due to the residue-free removal of all operating fluids during the preparatory work for the dismantling, as well as the provision of binding agents, emissions into groundwater and soil are not to be expected, or only to a minimal extent. An example of site restoration to a greenfield in Germany is provided in the guidelines as well.
Health and safety requirements should always be a top priority throughout the whole process of decommissioning a wind farm. That, and a solid communication plan with the local authorities, are key factors for a sustainable decommissioning of a wind farm.
