In Texas, where land is cheap and sun plentiful, they have a project where they're just laying them out on the ground. No support structure, no expensive clockwork to tip them this way and that. They want to get more watts, they buy more dirt-cheap panels and lay them on the ground too.
See, all that support structure costs more than the panels these days. Way more. You want to spend your money wisely, ditch the supports, buy more panels instead.