[RE-wrenches] Fwd: RE: Solar System Certification

[William Miller]

Colleagues:

I have a good friend that is a licensed electrical engineer.  I forwarded 
to him the background about the Yorba Linda certification 
requirement.  Below is his response, which I think is very pertinent to 
this list.  I redacted his name and contact information because I forgot to 
ask his permission to post his response to the list.  If anyone wishes to 
pose any questions, I can forward.

With any PV system in the field, there are several variables which are 
difficult to quantify:  Insolation, both instantaneous and over time, 
temperature at the module, and wind speed.  When I am looking at a PV 
system to evaluate suitable operation, there is some subjectivity in 
determining acceptable output. I believe it would be difficult to give a go 
or no-go determination to a given system.  As my friend asks below, "who 
sets the standards, and what are they?"

William Miller




>Generally problems in this area come down to legal definitions. You used 
>the word "commission", they use the words "test and approve".  Some of 
>these words have legal meanings that assign risk and liability. This is a 
>common misconception. Engineers design systems and set the parameters that 
>constitute the performance metrics of that system. Like the men and women 
>at Siemens or Square D. Once these metrics are established, they can be 
>used by qualified installers and technicians as benchmarks in the field to 
>determine if the system is performing as designed. So first off, you do 
>not need an engineer to perform tests: The performance parameters are 
>published, the inspector witnesses a field test by the installing 
>contractor or testing agency technician that demonstrates the parameters 
>are met and you're done. Second, most engineers have little or no actual 
>experience field testing electrical equipment. Many wouldn't even know 
>what a megger is or how to use it.  A trained technician is typically far 
>better trained and equipped to perform this task. There are good size 
>companies such as ElectroTest that do this stuff exclusively and there 
>isn't an engineer in the bunch (except in their offices). Finally, the 
>main reason to use a registered engineer is to protect the public 
>concerning life safety issues and so you can assign professional 
>liability. That is why the state requires the license and insurance. My 
>professional liability policy specifically limits any testing and 
>"approval" activities I perform. They typically will not cover any of it. 
>Only systems I design and even then there is a limit of liability 
>concerning the manufactured equipment (tested and listed by others) used 
>within the system. Which is why I said a registered engineer would be 
>foolish to do this. So if the City thinks they are getting something (such 
>as professional responsibility) by requiring this, they are misinformed 
>and I am serious when I recommend they call the state board and ask them 
>about this requirement. I am sure the board will dissuade them from this.
>As far as a business model, I would think a specialty contractor would be 
>the best for this. But really it begs the question: What is it they are 
>thinking you are going to test? Voltage? Output? Grounding safety? Who is 
>publishing testing guidelines that someone can use to constitute an 
>"approved" installation? It is just half baked bureaucratic psychobabble 
>and should be challenged as such. That is my two cents. J
>
>
>G__:
>
>I am curious about you response.  What problems do you see with a 
>registered engineer commissioning a grid-tie system.  The consensus is 
>that there is little to test with one of these systems.  A voltmeter, 
>ammeter, insolation meter and maybe a megger are all that are required.
>
>William
>
>
>
>At 03:14 PM 12/21/2009, you wrote:
>
>Incredible. What "registered engineer" would be foolish enough to "test 
>and approve" something like this? I would recommend the city of Yorba 
>Linda call the state board and ask them what they think of this statement. 
>It is patently misguided.
>
>G___ N___
>
>
>From: William Miller 
>[<mailto:william at millersolar.com>mailto:william at millersolar.com]
>Sent: Friday, December 18, 2009 3:09 PM
>To: g___
>Subject: Fwd: [RE-wrenches] Solar System Certification
>
>G___:
>
>The posting below is from an industry chat list.  I though you might find 
>it interesting.
>
>The ordinance can be found 
>at: 
><http://www.municode.com/resources/gateway.asp?pid=13406&sid=5>http://www.municode.com/resources/gateway.asp?pid=13406&sid=5 
>This requirement is not a bad idea.  It would drive up the cost of PV, but 
>it would protect consumers.  Would be a good line of work for someone with 
>your credentials.
>
>William
>
>
>
>
>I am curious if any of you have had to deal with this issue before.
>
>The following is an item we got back from the City of Yorba Linda for a 
>Plan Check correction:
>
>
>  All electrical solar systems shall be tested and approved by a 
> California Registered Electrical Engineer.  The engineer shall furnish a 
> report stating their name, registration number, its date of expiration, 
> address where the testing occurred and the dates of testing and 
> approval.  Such report shall be presented to the City inspector for 
> approval at the time of final inspection.  (YLMC 15.28.020)  Note on the plans.
>
>All experiences and suggestion are appreciated.
>
>
>
>Best Regards,
>Brian C. White
>Design Engineer - PV Systems
>
>Eagle Roofing Products
>120 North Auburn Street - Suite 212
>Grass Valley, CA  95945
>Phone: 530-273-2948
>Cell: 530-575-5550
>e-mail: brianw at eagleroofing.com 
><<mailto:brianw at eagleroofing.com>mailto:brianw at eagleroofing.com>
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