Most use a horizontal single axis configuration and could just tilt the panels away from the sun.
The real question that we should be asking, is why nobody can think of what to do with free energy?
Desalination? Mine Bitcoin? Giant space laser?
Or in a pinch: just run big-ass space heaters. Seriously. It’s a stupid way to burn off excess power, but it’s dirt simple and cheap. Just have a big array of resistive heaters out in an empty field somewhere with a high fence around it. Need to burn off an extra GW? Run it through massive heating elements and burn burn it off. It’s a stupid waste of good energy, but as an emergency backup, it’s not a bad option. It’s trivially easy to dispose of huge amounts of excess electricity if you just run the mother-of-all space heaters. Run your stupid giant resistive heater at the bottom of a lake for even better effect.
It’s not a question of ideas, it’s a question of money. Building things to use excess power costs a lot of money.
In some markets, the power price actually goes negative and consumers can be paid to use energy.
https://edition.cnn.com/2024/09/20/energy/three-mile-island-microsoft-ai/index.html
I think there’s plenty of money out there to use excess power, someone just has to connect the dots…