What I see here is a short shrift on overall energy policy. FERC has had its ruling 841 and ruling 2222 in place for a few years now. I would submit this 4% of the grid to be ‘closed’ to new renewables is the place one should be recabling with more efficient transmission lines and installing large local or regional energy storage facilities that will enable a time shift in energy dispatch when it is needed most. There is no “law” that says you can’t take all the energy generated from a wind farm or solar PV farm during the day and store it until night time dispatch is needed.

A solar PV decommissioning policy sounds good as a political sound bite. Building a bureaucracy around this decision would insert so many interlopers, it would not be cost effective. The only real question here is, the labor to decommission a solar PV farm, is it easier than or as hard as decommissioning a coal fired plant, natural gas plant, nuclear plant?