Sustainability & Life Cycle Assessment of Photovoltaics:

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1 Sustainability & Life Cycle Assessment of Photovoltaics: Manufacturing and Recycling Processes Kathryn Chang Instructor Werner Lang picture cover page minimum resolution 300 dpi width of the picture not wider than the text blocks height of the picture minimum 0.6 from last text block ideally like this frame no frame for the picture csd Center for Sustainable Development

2 Sustainability & Life Cycle Assessment of Photovoltaics Kathryn Chang main picture of presentation Fig. 1 PV Soundless in Freising, Germany. Isofotón. A 500kWp sound-barrier with ceramic based PV modules installed next to the Munich airport. Ever-increasing fossil fuel prices and depletion of petroleum reserves are renewing the world s focus on alternative energy. Sustainability has become one of the most talked-about topics in the world today and in the past few years the installation of solar panels has exponentially increased on rooftops ranging from city skyscrapers to farm houses. Power from the sun in one day can provide enough energy to meet the world s electricity needs for a whole year. 1 Unlike wind turbines or hydropower stations, PVs are versatile, relatively inexpensive and can harness the sun s energy from anywhere in the world. Aside from the most commercialized silicon wafer technology, a new generation of low-cost PVs based on thin films of semiconducting materials deposited on inexpensive substrates, will drastically increase the prospects of commercialization (i.e. amorphous silicon, copper indium diselenide (CIS), cadmium telluride (CdTe), and film crystalline silicon). 2 However, several factors must be taken into consideration in a product s life cycle assessment in order to assess its overall sustainability such as its emissions, environmental impacts and recyclability. Installing PVs is not a fix-all for the energy crisis if its embodied energy exceeds that of its power generation capacity, or if the raw materials used cannot be efficiently recaptured in the supply chain. Not only are we already witnessing a change in the way our buildings look but also in the materials and technology they are built with. This change occurs not due to choice, but rather due to a lack of choice on the premises of global warming and natural resource depletion. Sustainable architecture needs to demonstrate not only high energy performance but also a level of frugality in its material choice. Environmental materials should address issues of energy conservation, heath hazards, resource management, and waste management. In today s world, it is no longer enough to just fabricate clean and green products but manufacturers need to close the sup-

3 The manufacture of PVs presents risks concerning environmental, health and safety. Brookhaven National Laboratory, under the US Department of Energy s National Photovoltaic Program has been conducting extensive research and studies on PV s true impacts and methods of prevention. The issue with regards to decommissioning of PV modules at the end-oflife is having the necessary system and infrastructure setup for proper disposal and dismantlement, ensuring that the cost of recycling does not escalate the overall cost for the end user. If the total costs of PVs become too high, it would create barriers to market, hindering the transition process from conventional energy to green energy generation. Fig. 2 Industrial Ecology and Completing the Loop ply chain loop and assume responsibility and stewardship of the entire life cycle. The goal is to develop cradle to reincarnation systems 3 that can skip the grave stage entirely (Figure 2). Oftentimes trendy magazines will have a popular article on the Net Zero house, but does that mean those homes are truly sustainable? The true measurement of sustainability can only be determined by looking into embedded energy in all of its industry sectors including its production, operation and recycling processes. The ecological competitive advantages of using PVs include zero operational greenhouse gas emission, short energy-pay-back time, noiseless, an infinite energy source, and a 25+ year low maintenance life span. Of course, the attractiveness of renewable technologies depends not only on their energy paybacks. Too often, energy technologies are discussed solely in terms of their direct monetary costs without taking into account other costs in the life cycle. They must be taken together to define the total cost of renewable energy. Manufacturing PVs One of the most important goals of sustainability is resource management in determining how to get the most from as little as possible. From a materials point of view, the cost of making a solar panel from a recycled one is about the same as from new materials, but on the energy side, it only takes about one third of the energy. Although the quantity need for the recycling of solar panels are relatively low today since solar cells have at least a 25 year life expectancy, it is essential to plan ahead for when they do retire. In effect so that they Fig. 3 Historical Renewable Energy Consumption by Sector and Energy Source, (in 1000 Billion Btu) 14 2

4 can be properly recycled and waste can be minimized. Solar power is a green energy; it is in our hands to ensure this clean form of energy does not leave a dirty legacy. Most recycled panels so far have been flawed or damaged modules recovered by the manufacturer s warranties. These numbers will trend up as we approach 2015 as the first generation of solar panels will come to their end-of-life. About 16,000 metric tons (35,280 lbs) are expected to be recycled in Europe by 2015, compared to just 2,000 metric tons (4,410 lbs) last year. 4 Potential Risks Currently little attention is paid to the potential risks associated with the scaling up of solar panel production in the near future. The solar power industry must address these questions immediately or risk repeating the mistake of the microelectronics industry with regards to e-waste, which has caused death and injury of factory employees and people living in nearby regions. Fig 4. Two Types of PV Production Process Fig. 5 Life Cycle Emissions from Silicon and CdTe PV Modules 15 Reported in March 2008, one plant in China s Henan province has been dumping a toxic byproduct from its polysilicon manufacturing process on nearby farmlands. The toxin, silicon tetrachloride, makes the soil too acidic for plant life, also causes severe irritation to living tissues and is highly toxic when ingested or inhaled. Regulators suspect that firms in other developing countries are taking similar shortcuts. 5 International regulatory policies need to be set in place to avoid further damage to other parts of the world where local policies are lax. Recycling Initiatives The solar power industry is already taking lessons learned from the microelectronics industry in coming up with similar initiatives to the Extended Producer Responsibility (EPR), which are policies that provide incentives for companies to design and produce cleaner and more easily recyclable products, while discouraging the practice of planned obsolescence (intentionally making products that quickly become out of date or useless). 6 An initial conclusion might be to recycle solar PV panels with toxic metals at existing e-waste recycling facilities or at facilities that recycle batteries containing lead and cad- 3

5 mium. This method will keep toxics out of the municipal incinerators and landfills. Unfortunately, however practical as it may seem initially, most of these low-tech and environmentally heavy foot-printed recycling facilities reclaim metals using smelters, which are known to increase the risk of lung cancer from cadmium exposure in recycling workers and residents in nearby communities. 7 In order to produce a real solution to solving the potential problem of solar cell recycling, we have to look in both directions in the supply chain. Sheila Davis, en executive director of the San Jose nonprofit group that pushes for green practices in the technology sector, suggests that developing benign substitutes for some of the most dangerous materials [is] essential for the solar industry to be truly sustainable. 8 Organic PVs Alternatives to current mainstream PVs are an emergent technology of organic PVs that has spurred the interest of venture capitalists with promise of a much cheaper and more versatile source of solar power. Organ- Fig. 7 PV Section ic PVs employ carbon-based plastics, dyes, and nanostructures and can be manufactured via a printing process. Compared with the high-temperature vacuum processing used for normal PV semiconducting materials, it can be a huge savings along the value chain. This kind of PV is significantly more flexible and lighter than inorganics, leading to a large array of possible uses (i.e. portable battery chargers, Fig. 8 EPBT for Thin-Film Systems 13 power-producing coatings for roof shingles, tents and vehicles). The highest known energy-conversion efficiency of organic PV is in the range of 6.5%. Due to its lower manufacturing cost, organic PV developers are aiming to target lower efficiency demand markets like coatings for rooftop applications. However, until the technology can become robust and powerful enough for full commercialization, we have to concentrate on resolving the issues with proper disposal and recycling of mainstream PVs. 9 Embedded Energy and EPBT The economics of measuring energy consumption in PVs is by means of comparing individual energy payback times. Energy pay-back time is defined by Fig. 6 EPBT for Silicon PV 12 4

6 EPBT = E input /E saved, Fig. 9 Centralized vs. De-centralized Strategies Fig. 10 Projected PV Retirement Rate -Tons/Year vs. Year of Use where E input is the energy input during the module life cycle (which includes the energy required for manufacturing, installation, operation, and energy needed for decommissioning) and E saved the annual energy savings due to electricity generated by the PV module (figure 4). 10 The most commercialized type of PV cells are produced by using crystalline silicon technology capable of energy-conversion efficiencies between 12-17%. A super thin slice of high-purity silicon wafer is used as semiconductor to capture sunlight energy and convert it into useable electricity. EPBT for Silicon PVs are shown in figure 6. There are also thinfilm PVs (figure 8) having comparatively lower efficiencies between 5-13%, which is compensated by also lower production costs. Crystalline silicon can be subdivided into monocrystalline silicon (mono c-si), multicrystalline silicon (multi c-si). Thin-films can be distinguished by the type of the semiconductor layer: amorphous silicon (a-si), cadmium telluride (CdTe) and copper indium diselenide (CIS). 11 The manufacturing stages of silicon PVs and a CdTe thin-film PV are illustrated in figure 3. Centralized vs. De-centralized Strategies The amount of waste generated from manufacturing PVs decreases as the operation of the facility reaches a steady-state level of production (Figure 10). The immediate needs of waste disposal and recycling of PVs can be solved by either centralized or de-centralized approaches, however, as the PV industry begin to scale up, future needs would be more economically solved by centralized strategies. The main differences between the two strategies are scale and method of metal recovery (Figure 9). The centralized scheme targets a much larger scale application in smelting facilities which use glass as a fluxing agent and reclaim most of the metals by incorporating them in their product streams. In the de-centralized dispersed operations, it is more expensive due to the small quantities and high transportation costs. For the long term, it would be more efficient to separate the PV layers from the glass substrate as an initial step to minimize the amount of waste generated, a potential of three orders of magnitude in waste reduction. 17 Battery and Electronics Industry Large electronics and telecommunications companies (i.e. AT&T) recycle a wide range of products through the combination of in-house collection with collection by reverse logistics companies who provide collection, consolidation, pre-processing and transportation services. The collected products go through at least one of three processes of refurbishment for resale, disassembly for spare parts 5

7 or dismantlement for reclaim materials. The driver behind recycling in the electronics industry is the salvage value of the usable components and precious metals. 18 Another industry worth comparing to is the NiCd battery industry. The Portable Rechargeable Battery Association (PRBA), a consortium of industry manufacturers, funds and overseas a non-profit take-back program that utilizes centralized collection and recycling facilities. The PRBA works closely with the International Metals Reclamation Company, Inc. (IN- METCO), an integrated stainless steel recycler, capable of recovering nickel and iron from NiCd batteries and selling Fe-Ni-Cr alloy back to the stainless steel industry. INMETCO can also recover high-purity cadmium which is returned to the NiCd industry. 19 Recycling of solar panels is much more complicated than that of the products mentioned in the industries above. Unlike these other products, PVs have a very long operational life span between its fabrications and recycling stages. The infrastructure for collecting and recycling of used products in similar industries can be accounted for in three generic paradigms: utilities, electronics, and battery paradigms. Applying these paradigms to the PV industry can provide us with a picture for the possibilities of solar cell collection and recycling. In the first scenario, institutional end users (i.e. electric utilities) would be the main owner and servicer for their large PV systems. It is under their responsibility to bring back their spent modules to the recycler. The recycling costs would be embedded in the rates charged by the utility company. The second scenario involves copying the battery industry where manufacturers would be collectively responsible for the consolidation and delivery of spent modules to a collectively supported PV recycler. Parts or materials outputted from the recycling entity would be sent directly to smelters and other specialized recyclers, under a pre-paid transportation agreement. Third scenario mimics the recycling process that of the electronics industry. Each manufacturer would be responsible for the collection, transportation of obsolete modules to recyclers. The manufacturer would have an escrow fund set aside when the PV modules were initially purchased to ensure available funds when those panels reach end-of-life (see First Solar Case Study). Recycling Challenges Fig. 11 Disassmbling PV PV installations are not concentrated in most cases neither by geography nor by component content. Demands for PVs are currently dominated by dispersed installations all over the world. Even large area arrays are not typically centralized in one locale. Small residential applications are far more scattered across the globe. The collection process poses potential challenges and high cost. Unlike the electronics and battery industry where value of reclaimable material are high, PVs lack significant quantities of any key material, which can deter its materials recovery from an economics point of view. For instance, the most costly of the thin-film constituents, indium, accounts for only 2.5-5% of the total value of an CIS PV module. 20 Existing Recycling Technologies According to PV Cycle, there are currently two processes in the market operating at full-scale: the Deutsche Solar treatment process and First Solar s treatment process. The difference is mainly in the types of modules each process targets. Deutsche Solar treats mainly the recycling of crystalline silicon modules and First Solar is mainly used for CdTe modules. In both cases, glass and other metals can be separated and distributed to additional recycling facilities for further extraction. Recycling x-si Modules Fig. 12 Multicrystalline PV Modules First Solar Inc. can also recover crystalline Si wafers from used x-si modules. The process involves heating and removal of the backsheet, and then vaporization of the EVA lamination layer. The solar coupons can then be recovered, this method yields slightly lower electrically efficient solar panels than unused ones from 12.8% to 10.73%. First Solar is optimistic that this can be improved in the 6

8 near future. 21 Recycling CdTe Modules Fig. 13 Solar panel in Brooklyn. Cadmium telluride photovoltaics First Solar Inc. starts with disassembly of the module and recovery of lead wires and then the module parts are separated during different times of a milling process. Glass is stripped of metals in successive chemical dissolution steps, mechanical separation, and precipitation or electrodeposition. At end of process First Solar has a recovery of >80% of the tellurium in CdTe PV panels and 100% of the mounts, glass and EVA parts. The leftover metals including Cd, Te, Sn, Ni, Al, Cu are sent to INMETCO for additional recovery. 22 Recycling CIS Modules modules involving a chemical stripping of metals and EVA along with successive steps of electrodeposition and evaporation to recover the rest of the metals. It reports a recovery of 95% of Te and 96% of Pb from the CdTe modules. Drinkard Metalox Inc. also uses a chemical stripping process leaving the SnO2 semi-conducting layer intact on the glass substrate, essentially making the substrates reusable for PVs. 23 The cost of collection and disposal or recycling is directly proportional to the weight of the recycled materials. In order to make PVs more economical and better for the environment, modules need to be easy to disassemble, separate into recyclable materials from its main glass substrate. An important contributor in the research and development of PV recycling is Professor Vasilis Fthenakis, founder and director of the Center for Life Cycle Analysis at Columbia University. He also leads the National PV Environmental Health and Safety (EHS) Research Center operated out of the Brookhaven National Lab (BNL) under the sponsorship of the US Department of Energy. Fthenakis sees that an alternative to consolidated recycling strategies is on-site separation. More research and development needs to go into the industry to create PVs that can be taken apart at the time of dismantlement. 24 Case Study: Dow Corning Although Dow Corning is not a PV manufacturer, it is an important supplier for the PV assembly. Dow Corning supplies companies like Hemlock Semiconductor Group with siliconbased materials for solar applications. In Dow Corning s Wiesbaden site in Germany, employees can witness their own products in solar panels working and helping produce more green and sustainable goods. Over 1,000 m 2 of PVs were installed on the roof and facades of the office and production buildings to replace conventional energy that would otherwise come from coal plants on the grid. The energy generated by these PVs are fed back into the local grid, in return, Dow Corning benefits from subsidies to purchase electricity for its own energy demands. The German subsidiary commits to reinvest 30% of these subsidies every year in sustainable energy project aiming to reduce the plant s total energy consumption. The energy generated by the roof top panels is equivalent to the average annual energy consumption of 35 families of four. 25 Case Study: First Solar Inc. Fig. 14 CdTe PV Panel in Dubai Drinkard Metalox Inc. has developed operations for recycling CdTe and CIS Fig. 15 Dow Corning Facility in Wiesbaden, Germany Fig. 16 First Solar Manufacturing Plant First Solar is one of the frontiers in establishing a cradle to cradle process within their solar module supply chain. First Solar has established industry s first comprehensive, prefunded module collection and recycling programs. In order to maximize 7

9 recovery of valuable materials for use in new modules and minimize environmental impacts, they have developed a module that is approximately 90% recyclable. The end user can request collection of First Solar s modules at any time during its life at no additional cost to the end user. The prefunded amount paid by the user upfront is estimated based on forecasted recycling costs at the end-of-life after 25 years. Each of their current three global manufacturing facilities have recycling facilities built in so no additional infrastructure is needed to close their supply chain loop. First Solar s prefunded recycling program involves a trust structure established in custodial accounts with the name of a trustee so that the funds will be available regardless of First Solar s future financial status. Only the trustee can distribute the pre-funded amounts and these funds cannot be accessed for any other purpose other than for administering module collection and recycling. To further embed trust in First Solar s customers, the financing arrangement is periodically audited by third-party auditors. 26 Case Study: PV Cycle Fig. 17 Broken Pieces of Multicrystalline Silicon Wafers Founded in 2007, PV Cycle s mission is to implement the photovoltaic industry s commitment to set up a voluntary take back and recycling program for end-of-life-modules and to take Fig. 18 Life Cycle of PV Modules responsibility for PV modules throughout their entire value chain. (Figure 18) With the same goals in mind as the rest of the solar industry in trying to stay ahead of regulators, PV Cycle has teamed up with 79 full members and 14 associate members including Q- Cells, Sanyo, GE Energy, Sharp, Kyocera and First Solar, as well as German solar industry association BSW and the European Photovoltaic Industry Association (EPIA). Together the association represents 85% of Europe s PV market (Figure 20). Through PV Cycle, the solar industry hopes to install an all encompassing waste management and recycling system that can achieve the highest economical feasibility and environmental responsibility. 27 PV Cycle s take-back and recycling program involves a two phase scheme. The first phase is reserved for all the necessary preparatory work to solicit onboard industry participants, design the network and infrastructure, and coming up with program objectives. The latter phase encompasses the implementation of the program and scheduled annual auditing to monitor progress towards achieving the program goals. 28 Conclusion After comparing the emissions from the life cycle of the four major commercial PV technologies (Mono-, Multi-Silcon, CdTe, CIS), the results indicate that their differences are insignificant in comparison to the emissions that they replace. By substituting conventional power generation with PV systems we gain enormous environmental benefits. Centrally installed CdTe PVs alone amount to 89-98% 8

10 reduction of greenhouse gas emissions, pollutants, heavy metals, and other harmful impacts. Residential or commercial dispersed installations, on the other hand, experience an even greater reduction since transmission and distribution network infrastructures are virtually avoided completely. In general, thin-film PVs require less energy in their manufacturing than crystalline Si PVs, which translates to the lower total overall emissions of heavy metals. The solar panel industry is working towards long term strategies in preserving the environmentally friendliness of PVs. Investigations of options to best treat the disposal and recycling of spent solar panels are underway. Research and development has shown that recycling solar panels is technically and economically feasible; however, caution needs to be taken with regards to accounting the environmental effects of the whole life cycle. Emergent solutions and pilot programs are in place already to seek out the best option for resolving the recycling problem of PVs both in Fig. 19 Average Daily Radiation in kwh/sq m per day Fig. 20 Europe and U.S. Other companies not directly part of the PV life cycle are becoming external pioneers joining the loop by taking the first steps, through replacing conventional energy source from the grid with PVs, thus putting truly sustainable and green products on the market. 29 The eventual integration of solar energy generation to the developing concept of the Super Smart Grid is certain. The idea behind this concept originates from the European Union s decision to reduce greenhouse gas emissions by 20-30% and Germany has a target of 40% for The EU aims to reduce emissions by 80% when 2050 comes around. EU has also decided on increasing the use of renewable energies to 20% of total energy consumption in With Europe s current energy policy paradigm, it would be difficult to achieve these targets. One of many possible solutions for Europe s energy would be to utilize the solar and wind energy potential in the desert of North Africa (Figure 19) Renewable electricity from North Africa would be sufficient to satisfy the electricity needs of the Mediterranean and the rest of Europe many times over, according to the Super Smart Grid website. 30 Besides introducing new infrastructure to transmit power over the Mediterranean Sea, the PV industry needs to also collaborate with other power nodes on the grid to plan and establish a feasible integration 9

11 solution. PV cell developers should also work towards designing better assemblies of PV modules that can be easily disassembled for recycling. PV technology needs to develop further to obtain better efficiencies, in turn increasing its marketability. The PV industry should seek to replace all of its conventional energy sources with solar cells and other more alternative energy. In the future, we will have PVs that are made by the clean energy generated by other PVs. The next step for the solar industry is to convert its full value chain to using green energy to produce a more sustainable life cycle for PV technology. The PV industry should seek to replace all of its conventional energy sources with solar cells and other more alternative energy. In the future, we will have PVs that are made by the clean energy generated by other PVs. The next step for the solar industry is to convert its full value chain to using green energy to produce a more sustainable life cycle for PV technology. Notes 1. Dow Corning helps meet future solar industry needs - Dow Corning. Dow Corning Silicones - Dow Corning. solar/solarworld/solarfuture.aspx (accessed July 7, 2010). 2. Fthenakis, Vasilis M.. End-of-life management and recycling of PV modules. Energy Policy28, no. 14 (2000): Manahan, Stanley E. Environmental Science and Technology: A Sustainable Approach to Green Science and Technology, Second Edition. 2 ed. Boca Raton: CRC, Ibid. 5. Dickerson, Marla. Solar energy s darker side stirs concern - Los Angeles Times. Featured Articles From The Los Angeles Times. latimes.com/2009/jan/14/business/finotsogreen14 (accessed July 7, 2010). 6. A Silicon Valley Toxics Coalition White Paper. Toward a Just and Sustainable Solar Energy Industry. Published January 14, Ibid., p Dickerson, Marla. Solar energy s darker side stirs concern - Los Angeles Times. Featured Articles From The Los Angeles Times. latimes.com/2009/jan/14/business/finotsogreen14 (accessed July 7, 2010). 9. Fairley, Peter. IEEE Spectrum: Solar-Cell Squabble. IEEE Spectrum Online: Technology, Engineering, and Science News. org/energy/renewables/solarcellsquabble (accessed July 6, 2010). 10. Energy Pay-Back Time (EPBT) and CO2 mitigation potential. Ecotopia. pvepbtne.htm (accessed July 7, 2010). 11. Other types of PV technologies are also available with less market share, however, this paper aims to analyze and examine the more widely commercialized PV technologies in regards to possibilities for recycling. 12. Fthenakis, V. and E. Alsema, Photovoltaics Energy Payback Times, Greenhouse Gas Emissions and External Costs: 2004 early 2005 Status. Progress In Photovoltaics: Research and Applications, (3): p Ibid. 14. Wong, Peter. EIA Renewable Energy-Solar Photovoltaic Cell/Module Manufacturing Activities. U.S. Energy Information Administration - EIA - Independent Statistics and Analysis. renewables/page/solarphotv/solarpv. html (accessed July 7, 2010). 15. Emissions from Photovoltaic Life 16. Ibid. 17. Fthenakis, Vasilis M.. End-oflife management and recycling of PV modules. Energy Policy28, no. 14 (2000): Ibid., p Ibid., p Ibid., p Fthenakis, V.M., and P.D. Moskowitz. The Value and Feasibility of Proactive Recycling, National Photovoltaics (PV) Environmental Research Center, Energy Sciences & Technology Department (EST). Brookhaven National Laboratory - A Passion for Discovery. abs_142.asp (accessed July 7, 2010). 22. Ibid., p Ibid., p Center for Life Cycle Analysis (CLCA) at Columbia University. Center for Life Cycle Analysis (CLCA) at Columbia University. 10

12 columbia.edu/people.html (accessed July 7, 2010). 25. Dow Corning helps meet future solar industry needs - Dow Corning. Dow Corning Silicones - Dow Corning. solar/solarworld/solarfuture.aspx (accessed July 7, 2010). 26. First Solar Inc Annual Report PV Cycle: About PV CYCLE. PV Cycle: Home. org/index.php?id=9 (accessed July 7, 2010). 28. PV Cycle: Voluntary Take Back Scheme. PV Cycle: Home. (accessed July 7, 2010). 29. Fthenakis, Vasilis M.. End-oflife management and recycling of PV modules. Energy Policy28, no. 14 (2000): SuperSmart Grid (SSG). SuperSmart Grid (SSG). (accessed July 9, 2010). Figures 1. EPIA Market Publication, Manahan, Stanley E..Environmental Science and Technology. 1 ed. Boca Raton: CRC, Wong, Peter. EIA Renewable Energy-Solar Photovoltaic Cell/Module Manufacturing Activities. U.S. Energy Information Administration - EIA - Independent Statistics and Analysis. renewables/page/solarphotv/solarpv. html (accessed July 7, 2010). 4. Emissions from Photovoltaic Life 5. Emissions from Photovoltaic Life 6. Emissions from Photovoltaic Life Emissions from Photovoltaic Life 9. Emissions from Photovoltaic Life 10. Emissions from Photovoltaic Life solar.renewables/page/solarphotv/ solarpv.html com/2008/02/26/science/26obsola. html?_r=3&ref=science&oref=slogin& oref=slogin profiles_a/pho_profiles_a_44.jpg php?id= References solar/how-free-is-solar-energy php?page=rightforme csp_docs.htm asp index.htm 11

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