HomeMy WebLinkAboutStaff Report 345-09TO: HONORABLE CITY COUNCIL
FROM: CITY MANAGER
DATE: SEPTEMBER 14, 2009
REPORT TYPE: INFORMATIONAL
DEPARTMENT: PLANNING AND
COMMUNITY ENVIRONMENT
CMR: 345:09
SUBJECT: Status Report on Photovoltaic (PV) System Permitting and Inspection Processes
This is an infonnational report only and no Council action is required.
BACKGROUND
The Building Division of the Department of Planning and Community Environment (PCE) has
primary responsibility for the plan review, permitting and inspection of Photo voltaic (PV) systems in
Palo Alto. Since 2006, over 230 commercial and residential PV systems have been installed and
another two dozen or so are in process. Currently, PV systems produce more than 3,750 MWh of the
roughly 1 million MWh of electricity used annually in Palo Alto. Close coordination with Palo Alto
Utilities is required at both the front end and completion of these projects to ensure requirements for
City rebates are met and interconnection of these systems to the City's electric grid occurs properly.
The number ofPV systems installed during this time has increased significantly over prior years due
to a variety of economic (tax incentives and rebates), environmental and other factors. Accordingly,
the Building Division workload has al~ increased. An indication of the level ofPV activity in the
City can be found in the Solar Electric Power Association's recently released 2008 Top Ten Utility
Solar Integration Rankings Report, which identifies Palo Alto as one of the top per-capita generators
ofPV power in the country by several rating criteria. The association's report is available at:
http://www.solarelectricpower.orgidocs/SEPA%20Utility%20Solar%20Integration%20Rankings-
2008 .Pub lic%20release.pdf.
To address the increased workload resulting from PV installations and ensure minimum standards for
PV system safety and reliability, the Building Division established Application Submittal and
Inspection GUidelines for PV Systems in May 2007 that were based on National Electric Code and
industry best practices in place at that time. These Guidelines have evolved since 2007 as a result of
feedback received from PV designers, installers and staff. However, staff and the PV industry agree
that the pennitting and inspection processes can continue to be improved and this report highlights
recent steps taken to reduce processing times and to better conlmunicate standards early in the
process.
DISCUSSION
The primary goal of the Building Division is to ensure safe and reliable PV installations that meet
minimum code and utility system requirements. The Building Division places a high priority on
supporting existing and emerging PV technologies and those who want to install PV systems.
lJltimately, the City's obligations are to protect the interests of end users by ensuring safe and
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reliable PV installations that will not cause fires and/or damage to roof systems. Additionally, the
ratepayers of Palo Alto Utilities have a stake in these systems through the payment of rebates and
issuance of credits to those customers who generate surplus PV power that can be applied towards
the future purchase of electricity from the City.
PV Staffing and Technical Resources
As a rapidly growing industry with emerging technologies, the level ofknowledge and expertise that
exists both within the industry and among regulatory agencies related to PV is neither uniform nor
always up to date. In Palo Alto however, the Building Division is fortunate to have considerable PV
expertise in-house on staff as well as available through consultants. The City's Electrical Inspector
Specialist, who has primary responsibility for performing plan reviews and inspection ofPV systems,
is an appointed member of the State Fire Marshal's PV Task Force and also serves as an appointee
on two Standards Technical Panels (STP) for Underwriters Laboratories STP 1703 (Flat-Plate
Photovoltaic Modules and Panels) and STP 1741 (Inverters, Converters and Controllers for Use in
Independent Power Systems). She has also served as a guest lecturer on PV system design and
installation at the College of San Mateo and recently presented a workshop on proper protocols for
municipal plan review and inspection of PV systems to over one hundred municipal agency staff
from throughout the San Francisco and Monterey Bay areas. Additionally, the City is fortunate to
have a close working relationship with John Wiles, Program Manager at the Southwest Technology
Development Institute at New Mexico State University, who advises City staff on emerging PV
technologies and code requirements applicable to PV system design and installation. Mr. Wiles is
widely regarded as one of the foremost authorities on PV in the nation and assists the PV industry,
electrical contractors and inspectors with understanding of the PV requirements of the National
Electrical Code (NEC). He also serves as Secretary for the PV Industry FOrunl involved with the
drafting of Article 690 of the NEC, which deals with PV systems.
In Palo Alto, the level of PV expertise that is available enables Building Division staff to more
thoroughly examine PV system designs for safety and code compliance prior to issuance of permits,
but this also creates a higher standard than exists in most other jurisdictions. As a result, staff is
sometimes criticized for PV permit and inspection processes that are overly burdensome when
compared to other cities and which reportedly increase the cost of installing PV in Palo Alto.
PV Process Improvements
Building Division staff remains con1mitted to the continuing examination and improvement ofPV
processes and several steps in that direction have been taken in the past few months:
• Staff met in February with two representatives from Solar-Tech, a regional consortium of
PV designers, installers and industry affiliates to hear concerns about the City's PV
processes and suggestions for process improvements. It was agreed that they would
propose specific ideas in the form of marked-up versions 'of the City's most current
Permitting and Inspection Guidelines, which they did in March. The suggestions, which
were submitted by a retired Deputy Building Official from the City of San Jose who now
consults to Solar-Tech, dealt primarily with the format of these guidance documents and
less with the technical contents therein. Additional suggestions were made about how
the City might make the application submittal and review process more efficient for both
applicants and staff. These included the format and number of submittal materials
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required and consideration of an appointment-based process for subn1itting PV
applications so that applicants might be able to have their plans reviewed over the
counter with staff in real time.
• Since then, staff has implemented most of the Solar-Tech recommendations. . The
Permitting Guidelines have been reformatted and condensed from seven pages to three in
a more user-friendly format (attached). Genetic information applicable to all projects has
been moved to a separate sheet that is attached to the plans at the time of permit issuance.
The revised guidance docun1ents were recently reviewed by the Solar-Tech consultant
who has indicated to staff that they satisfactorily address his (Solar-Tech's) concerns and
should be well received by the PV industry. Staff has also begun to accept permit
applications on an appointment basis, though not to the point where over-the-counter
review and issuance of permits can be guaranteed, due to current staffing constraints. For
applications that cannot be approved over-the-counter, staff commits to provide
comments or issue the permits within five business days, which most installers find
reasonable.
• In May, staff convened a focus group of the six primary PV designers and installers who
work in Palo Alto to discuss the process changes initiated by Solar-Tech and to identify
any additional ideas for further process improvements. Among the suggestions were:
1. Not requiring complete power, current and voltage calculations for system
designs, but just the end results, worst case scenario or the NEC Article 690
calculations only. Alternatively, the City should consider developing maximum
standards for system designs below which calculations and submittals of certain
items would not be required at all.
2. Creating an on-line repository of installation and equipment manuals, product
spec sheets and bulletins so they don't need to be subn1itted and labeled with
each application. Originals would be left with the end users/owners of PV
systems.
3. Providing less scrutiny of the attachn1ent details on the plans since these are
checked in the field during the standoff inspection. Also, consider allowing
photos of the standoffs to be submitted in lieu of inspection to make installations
more tin1e efficient.
4. Developing a strearrllined, self-certification submittal process for systems
designed by NABCEP (North American Board of Certified Energy Practitioners)
certified designers.
At the present time, staff is focusing on implementing the fourth recommendation above
as this will produce the most results towards achieving greater process efficiencies and
streamlining. The goal is to implement this recommendation within the next 30 days and
when it is, staffbelieves that the remaining three recommendations will naturally follow
for the key PV designers and installers who operate in Palo Alto. Staff also plans to
continue an ongoing dialogue with the focus group participants to maintain lines of
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communication and to provide opportunity for continuing feedback and promote further
process improvements. The next meeting will be scheduled for later this month.
• On May 20, the Building Division hosted a "PV Design Workshop" taught by John Wiles
at the Roche campus to discuss the application of the National Electric Code to PV
systems. This was attended by 145 solar designers and installers who work in Palo Alto
and throughout the Bay Area. Throughout the day, many of Palo Alto's PV permitting
and inspection requirements were incorporated into the presentation so the technical
background and justification for them would be better understood by the participants.
• Staffrecommends that Palo Alto become a member of Solar-Tech to become more ofa
partner with the PV industry and to help promote consistency among jurisdictions with
permitting and inspection responsibilities in the region. Membership will be finalized in
the next few weeks.
• Staff will formalize a process for convening quarterly meetings with PV designers and
installers, as was done in early May, to promote improved communication with PV
professionals who work in Palo Alto.
• The Building Division is attempting to increase staff capacity to perform plan reviews
and inspections of PV systems by offering training to all Building Inspectors, though
recent retirements have delayed rapid progress on this front.
• For residential PV systems that involve installation of a new roof, staff is exploring the
possibility of waiving the PV permit fees as a way to incentivize roof system upgrades,
which ultinlately will result in more integrated designs that will perform better over the
longrun.
SUMMARY
As stated at the outset, Building Division staff remains committed to safe, reliable and cost-effective
PV installations in Palo Alto. Staff believes that proper protocols exist for the plan review,
permitting and inspection ofPV systems, but will continue to seek opportunities for further process
improvements by partnering with the PV industry and maintaining open lines of communication with
the key PV designers and installers who work in Palo Alto. Staff will also continue to avail itself of
expertise that is available in order to explore new ideas and emerging PV technologies, and will
remain active participants on statewide committees charged with developing new regulations, codes
and standards that will govern the PV industry.
POLICY IMPLICATIONS
The City's efforts to provide for safe and reliable design and installation ofPV systems is consistent
with Building and other safety codes, while staff's commitment to improve the review process helps
further the City's goals and policies for green building, reduction of greenhouse gasses, and
enhanced opportunities for use of renewable energy resources.
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RESOURCE IMPACTS
Staff expects to implement the proposed process improvements within the current staffing structure
and budget. The costs of review for PV installations are supported, though not fully recovered, by
permit fees.
ENVIRONMENTAL REVIEW
This report to the City Council is not considered a project pursuant to Section 21065 of the
California Environmental Quality Act.
ATTACHMENTS
Attachment 1: Revised Photovoltaic Submittal Requirements
PREPARED BY: ~i.~
Larry I. Pe lin, P
Chief Building Official
DEPARTMENT HEAD: _Q~ ...... ""","~~~---",_" --"~~<-='",-,,,-~ __
Curtis Williams, Director
Planning and Community Environment
CITY MANAGER APPROVAL: --~~--------~~~~-------
CMR: 345:09 Page 5 of5
CITY OF PALO ALTO
SUBMITTAL REQUIREMENTS
ATTACHMENT A
FOR RESIDENTIAL PHOTOVOLTAIC INSTALLATIONS
PR01ECTADDRESS ______________________________ _
DESIGNER/INS~LLER~~ ______ ~~ ________ ~ __ ~
• Submit Photovoltaic Permit Applications to the Palo Alto Building Division, 285
Hamilton Ave., Palo Alto, CA 94301
• Over the counter plan reviews are available by appointment. Please e-mail Rhonda
Parkhurst at rhonda.parkhurst@cityofpaloalto.org to schedule an appointment.
• Please allow 5 working days for initial plan review of applications submitted without
a counter appointment.
• If a new roofing system will be installed along with the PV system, please note that
a separate Roofing Permit is required.
Documents Required:
Plans
1. Plans must be of adequate size to provide legible details -minimum 11/1 x 17"
sheets are recommended.
2. Submit 3 sets o(complete plans along with 1 complete set of installation
documents.
Site Plan
3. Provide a Site and Roof Plan showing the location of the PV array, all supporting
equipment, the location of sub-panels and the location of the main electrical
service.
4. The Site Plan must show dimensions of required clearances for equipment
servicing.
5. The Site Plan must illustrate where DC wiring will be installed inside and outside
of the building.
Structural Requirements
6. Structural calculations are not required when:
• PV panels and support mounting racks weigh less than 5 #/sf
• PV panels and support mounting racks have less than 40 # point load and are
not elevated more than 18" above the roof
• Existing roof framing members are larger than 2" x 4"
• Existing roof has only a single covering
Otherwise, provide sufficient details on the plans showing structural support load
paths.
7. If the mounting structure was not permitted and/or the roof rafters are
determined to be over-spanned, additional structural support may be required.
Provide structural calculations and details for new PV array to verify existing and
proposed framing is adequate for the new loads.
8. If the building was not permitted or has multiple roof coverings, indicate if the
roof has roof rafters or trusses, pitch of roof and number and types of roof
coverings. If the roof structure is comprised of rafters, identify size and spacing
of rafters, maximum unsupported span and spacing, and type of wood, (Douglas
Fir or Redwood).
Mounting System
9. Details of the rack mounting system must be provided, including attachment
notes, details and how roof penetrations will be made weather-tight. Note:
Proposed flashing must be suitable for the roof type.
Supporting Documents
10. Provide photograph(s) of the main electrical service with the dead front
removed.
11. Provide a completed CPA Utility Photovoltaic Electric Load Sheet.
12. Provide Manufacturer's Installation Instructions and listing approvals of all
relevant equipment being installed.
13. Provide 3 copies of a three-line diagram that details system components
including number of total modules, number of strings per array, number of
modules per string, wire sizes, wire types (conductor insulation types), conduit
sizes and types, wire distances between each piece of equipment, eqUipment
specs (size, manufacturer and model #), disconnects, methods of grounding and
bonding, and bus bar ratings of the main service and AC load center.
14. Submit complete calculations, (maximum system voltage, system string current,
wire sizing, fuse/Circuit breaker sizing, conduit fill, terminal check, voltage drop,
and ambient temperature used).
15. Provide a Torque Schedule for all connections.
Additi'onallnformation
• Note: If an inverter with integrated disconnects is proposed, separate
disconnects will be required.
• Note: Where more than three strings are combined, listed combiner boxes are
required.
• An AC disconnect is required within sight (10' max.) of the main electric service.
Disconnect shall be readily accessible, visible-blade, and lockable.
• Photovoltaic installations west of Interstate 280 require PV modules to have a
minimum Class "A" fire rating.
Battery Requirements
16. If batteries are included, show location, type and number of batteries, ventilation
requirements, and details for securing batteries to prevent movement.
17.A disconnect must be installed at the batteries when located in a separate room
or more than 5' away from the inverter.
• Note: Guard all live parts (CEC 690.71(b)(2)
• Conductors between the inverter and battery enclosure must be installed in
conduit.
• Do not install batteries in living areas or at electrical equipment/enclosures
(CEC 110.26)
Generators
lS.A disconnect must be installed within sight and 10' of the generator and inverter
(CEC 240.21)
19. Conductors shall be rated at 115% of the generator set nameplate current rating
(CEC 445.12)
20. Install an automatic transfer switch rated and listed for the use. (CEC 702.6)
Once plans have been approved, all field installation changes will need to
be resubmitted and approved prior to scheduling an inspection.
Please provide the following information for the System Designer/Engineer:
NAME: ______________________________________ __
ADDRESS: ____________________________________ __
PHONE: __________________________________________ _
E-MAIL: _________________________________________ _
UcenseNo. (ifapplicable):~ ____________________________ _
NABCEP Certification No. (if applicable): ___________ __
PHOTOVOLTAIC SIGNAGE REQUIREMENTS
Labels shall be phenolic where exposed to sunlight. Labels required on conduit shall be permanentl weather resistant
and suitable for the environment. Labels shall be red background w/white lettering.
h f II I bib . ded Teo owing a e s must e provi
Article Location of Label Verbiage
690.14 (C) (1) On the main service when DC wiring DC disconnect is located .
is run through the building and the
DC disconnect is located other than
at the main service
690.14 (C) (2) On the AC and DC disconnects DC Photovoltaic Disconnect
AC Photovoltaic Disconnect
690.53 On the DC disconnects Operating current _
Operating voltage
Maximum system voltage _
Short circuit current
690.52 At interactive pOints of Maximum AC operating current _
interconnection, usually the main Operating AC voltage _
service
690.56 (8)/ At the electrical service and at the A directory providing the location of the service
690. 14(D)(4), photovoltaic inverter if not located at disconnecting means and the photovoltaic system
705.10 the same location disconnecting means
690.17 At the electrical service WARNING! 2 SOURCES OF POWER PV/AC @
ADJACENT LOCATION
UTI LmES At the main electrical service when a CAUTION! SUPPLY SIDE TAP. OPEN AND LOCK AC
REQUIREMENT supply side tap is used PV DISCONNECT BEFORE REMOVING METER
SFM -GUIDELINES On dc conduit, raceways, enclosures, CAUTION: SOLAR CIRCUIT
mark every 101
, at turns,
above/below penetrations
On the inverter where PV systems POSmvE GROUNDED SYSTEM
are positively grounded
General Guidelines
• All equipment installed shall be listed by an approved listing agency.
• When transitioning occurs from free air to in-conduit, install a cord grip fitting with a rubber
grommet or a bushing and sealant such as Sikaflex.
• Where conductors are installed underground, Section 300.5 of the CEC must be followed to
ensure proper protection.
Grounding
• Grounding of the system must comply with CEC 690.47 (C). Note where an existing grounding
electrode system is a driven ground rod, an additional ground rod is required per CEC 250.56.
• Each PV system must attach to the grounding electrode with a continuous grounding electrode
conductor. An approved irreversible grounding splice may also be accepted.
• Connection of the grounding electrode conductor to the grounding electrode must be made with
an approved connection that is listed for the application and location.
• Grounding electrode conductors must be sized to comply with article 690.47 of the CEC