Challenges in landfill solar development often arise from unclear site ownership, unresolved tax liens, steep or unstable terrain, and remediation systems that limit available buildable area. Addressing these risks early through clear title work, property acquisition strategies, and design adjustments can prevent roadblocks later in the process.
By Alex Bazeley
Closed landfills represent a unique category of underused real estate: vast, often centrally located, and, by regulation, off-limits to most traditional forms of redevelopment. The conditions that make them poor candidates for buildings or agriculture鈥攖he capped waste, subsurface instability, and long-term environmental monitoring obligations鈥攁re precisely what make them ideal for certain forms of renewable energy development, particularly solar photovoltaics.
However, landfill-to-solar redevelopment is far from plug-and-play. Each project must reconcile engineering limitations with regulatory requirements, community expectations, and long-term operational needs. Drawing on lessons learned from multiple successful projects, the following best practices outline how landfill owners, municipalities, and developers can navigate the process efficiently and sustainably.’
Understand the Regulatory Status of Your Site
Before design, before financial modeling, before a single conversation with a utility, you need to know exactly what you are standing on. That means going beyond a generic site inspection and into the archival archaeology of the property: closure reports, post-closure care plans, environmental sampling records, settlement monitoring logs, every letter the state ever sent to the operator.
The classification matters. If it is on the National Priorities List, the U.S. EPA will have a say. If it is a hazardous waste landfill, your state鈥檚 environmental agency will be in the room from day one. And no matter where you are, local authorities will weigh in on zoning, site plan review, and special use permits. Knowing the remediation and closure status up front will keep the developer from discovering, halfway through design, that a post-closure plan modification permit or a landfill disruption approval is needed. Incomplete or outdated environmental records can stall a project for months, so early diligence is critical.
Navigating Permitting and Approvals
Stormwater permits, landfill operating permit modifications, and formal environmental impact statements can stack up quickly. In some states you will be navigating SEQR reviews; in others, a cultural resources survey or an FAA glare assessment will pop up when you least expect it. The smart move is to map every possible requirement at the outset and turn it into a living 鈥渃ritical issues鈥� matrix. The even smarter move is to treat regulators like partners, not gatekeepers. Get them involved early, keep them looped in, and you will buy yourself goodwill when, not if, something unexpected shows up.
Design with the Site鈥檚 Limitations in Mind
The engineering constraints of these sites demand specialized design solutions. A capped landfill is a carefully engineered layer cake of waste, soil, membranes, and drainage, designed to keep everything inside from getting out. Penetrate that cap without permission and you are not just risking a fine, you are also risking the integrity of the entire remediation system.
That is why ballasted racking systems are the default for landfill solar. They sit on top, held down by weight rather than driven piles, and leave the cap untouched. Designs should maintain generous setbacks from remedial features such as gas vents, leachate collection systems, and monitoring wells. Electrical conduits are typically installed above grade to minimize disturbance, and array layouts should avoid areas with steep slopes, flood risk, or wetlands. A conceptual site plan that integrates these restrictions from the outset reduces costly redesigns later.
Building the Technical Foundation
Successful landfill solar development rests on thorough engineering and environmental deliverables. A Phase I Environmental Site Assessment is essential to document historical and current site conditions, but it is just the beginning. Geotechnical analyses assess slope stability and settlement potential, while stormwater management plans ensure the project will not interfere with existing drainage or containment systems. Visual impact assessments, glare studies, and wetlands delineations often form part of the permitting record.
Choosing a development partner with landfill-specific experience is critical, as they will know the nuances regulators expect to see in your submissions.
Images courtesy of AC Power.
Coordinating Power Offtake
Solar development on sites with a history of environmental contamination offers a unique way to get land working for its community again. Community solar programs, which allow local residents to subscribe to the power generated, are one of the most effective ways to deliver that benefit. Municipalities benefit from stable revenue streams, while residents gain access to clean, discounted energy without needing to install rooftop systems.
Alternatively, if there is existing energy demand onsite鈥攕ay, a capped landfill within a larger waste complex or a wastewater treatment plant鈥攖he landowner may want to use the power directly from the project via a behind-the-meter arrangement. Typically structured as third-party Power Purchase Agreements, these allow businesses to benefit directly from the solar installation while protecting themselves in the long-term from spikes in energy prices. Finding the right place for the power to go is critical to maximizing its impact.
Addressing Liability
The legal and financial risks on a contaminated site do not vanish just because you put solar panels on it. Mitigation often involves securing long-term environmental liability insurance, especially when acquiring a site outright. Your EPC contractor should carry environmental and pollution liability coverage, and every worker onsite should have the training and certifications that come with working in a hazmat-adjacent environment. Addressing these issues early in project planning protects all parties: developers, contractors, landowners, and municipalities.
Leveraging Incentives
Landfill and brownfield projects are tailor-made for federal and state incentives, but those incentives come with strings. The IRA鈥檚 Investment Tax Credit can climb significantly with Energy Community and Brownfield adders, but you will need airtight documentation. Many state programs sweeten the deal for community solar or for siting on disturbed land, but they will not let you in the door without proof of permits, interconnection queue position, or shovel-readiness. Incorporating incentive application timelines into the development plan ensures opportunities are not lost due to process delays.
Managing Interconnection
Interconnection to the electrical grid is often the most unpredictable stage of solar development. Requirements vary between states, between utilities, and even between distribution and transmission systems. Capacity constraints in certain areas can increase costs or limit project size, making early feasibility studies essential.
The only defense is offense: get into the queue as early as possible, run interconnection studies in parallel with permitting, and budget for delays as if they are inevitable鈥攂ecause they are.
Coordinating Post-Closure Care and Solar O&M
A landfill does not stop being a landfill when you put solar on it. It still needs regular inspections, environmental sampling, and cap maintenance. The solar array will need its own inspections, vegetation control, and security. Coordinating these into a single operations plan avoids duplication, reduces site disturbance, and keeps both the remediation and the renewable energy systems in compliance. Plan the decommissioning before you even break ground, as regulators will want to see the financial surety in place.
Engaging Stakeholders
Projects on regulated or formerly contaminated sites succeed most often when stakeholders are engaged from the beginning. This means communicating openly with neighbors and community groups, coordinating closely with regulators, and, when applicable, working with Potentially Responsible Parties to align responsibilities and expectations. Environmental justice organizations can also play a key role in ensuring project benefits reach the places most needed in their communities.
Anticipating and Overcoming Barriers
Challenges in landfill solar development often arise from unclear site ownership, unresolved tax liens, steep or unstable terrain, and remediation systems that limit available buildable area. Wetlands and flood zones can further complicate development and insurance. Addressing these risks early through clear title work, property acquisition strategies, and design adjustments can prevent roadblocks later in the process. | WA
Case Study: The Global Sanitary Landfill, Old Bridge, NJ.
For decades, the Global Sanitary Landfill in Old Bridge Township was an emblem of environmental liability. In operation from 1968 until 1984, the site experienced slope failures and significant contamination, leading to its placement on the EPA鈥檚 Superfund list in 1989. Following a comprehensive remediation effort completed in 2012, the landfill was capped, wetlands were restored, and the property remained off-limits to development.
In 2021, Old Bridge Township partnered with AC Power to transform the 61-acre site into a community solar project. The location鈥檚 inclusion in a designated Energy Community, combined with its capped and remediated status, made it an excellent candidate for a ballasted racking system that would both protect the landfill cap and power the community. The design process mapped array placement around wetlands and maintained setbacks from all remedial features, while above-grade conduits and minimal excavation preserved the site鈥檚 environmental integrity.
Construction, led by CS Energy, moved forward under the close oversight of both the New Jersey Department of Environmental Protection and the U.S. EPA. Owned and operated by NJR Clean Energy Ventures, the project came online in late 2023 and is powering approximately 460 homes, with more than half of the subscriptions reserved for low- to moderate-income households.
The project is generating over $1.2 million in revenue for the township over its lifespan through a Payment-In-Lieu-Of-Taxes agreement, while also serving as an educational resource. Partnerships with Solar One and the County College of Morris provided a renewable energy certification program to students funded by revenue from the project ensuring that the landfill鈥檚 legacy is no longer environmental damage, but community benefit and clean energy leadership.
Alex Bazeley is the Marketing Manager at AC Power LLC, a mission-driven, woman-owned solar development company specializing in the transformation of brownfields, landfills, and other previously disturbed properties into productive clean energy assets. Founded in 2016, AC Power delivers turnkey solar solutions through a collaborative, transparent approach that minimizes risk for landowners and maximizes community benefit. With a 150+ MW development pipeline and projects powering thousands of homes across the Northeast and Midwest, AC Power is committed to environmental stewardship, economic revitalization, and building a resilient clean energy future鈥攐ne brownfield at a time. For more information, call (845) 648-2955 or e-mail [email protected].