[RE-wrenches] Beat your local AHJ's over the head if you have to...

Matt Lafferty gilligan06 at gmail.com
Thu Feb 26 11:42:06 PST 2009


Preluditory Disclaimer: Not advocating physical acts of agression...
Standardized PV Plans 

Hi Bill,

Thanks for your work and dedication to standards development in this
industry. I'm supportive and will be looking forward to seeing what your
hard work results in. No reply necessary, but here are some of my general
thoughts... Observations, hopes, concerns.  Up front, everybody should know
that I sincerely respect and appreciate your work, contribution, and
dedication over the years. The other thing everybody needs to know is, I'm
staunchly in favor of increased quality in both documentation and
installation of PV systems and standardization where possible.

I ABSOLUTELY agree that, as far as a national standardization goes, the
"2007 CEC and any applicable codes" sorta dilutes the value. This, however,
is going to be an ongoing issue due to the way codes are adopted across the
US and the differences therein. Even if there were some federal mandate
regarding building permits and required codes and interpretations, the local
differences are going to be there, because that's just the way it is, solar
or not. Determining the lowest common denominators across various challenge
channels, then adding elements which raise them, is the key to success. 

PV = Psychovoltaics. Psychovoltaics is real. When you add it to the "local
differences" bowl, you sorta get a Goldilocks porridge. Some too hot. Some
too cold. Some just right. None perfect. Short of giving PV some special
status, like a Federal Disaster Zone for example, then redeploying the
military to serve as a National Solar AHJ, it's gonna be a long road...
Shoot, we shoulda had the National Guard guys doing site surveys in Kentucky
after the recent ice storm as they went from house to house like Jehovah's
Witnesses in Hummers and camo. On the local differences topic, one thing
that is missing from your description is harmonization between your work on
the permitting (AHJ) side of Distributed PV vs. the Utility Interconnection
issues. 

I'll be looking forward to observing whether your work raises the bar in
terms of quality (integrity/voracity/accuracy) of documentation that is
submitted vs. the final as-built project. I'll be looking forward to seeing
what direction your efforts move the overall quality of deployed PV systems,
and over what period of time that happens. Will relative permit fees
increase, remain the same, or decrease? Will the new standard/policy improve
the voracity & quality of field inspections? I'll be looking forward to
seeing what levels of detail your recommendation considers to be adequate.
Will side-effects be positive or negative? Positive side effects in my mind
would include seeing stuff like fast-blow 600 VDC fuses, better calibration
of 600 VDC OCP devices overall, better selection of 600 VDC OCP devices
overall, safety and reliability features in DC combiners, remote and local
disconnects for DC combiners, AC service and distribution equipment that is
designed and <maybe someday> specifically listed for parallel connection of
load-side generation, maybe even a wholistic conversation about grounding
<Not holding my breath>... Negative side effects include implementation of
policies that prevent installations altogether due to lack or perceived lack
of suitable products in the market, failure to implement a standardized
approach altogether, implementation of policies that create unreasonably
onerous requirements (I'll volunteer to be the judge of "unreasonable"),
adoption of a standard & policy that had development funding but not the
requisite support to keep up with changes in the industry over time, and a
lot of others that I'm not gonna toss out on this list.  

In particular, I'll be VERY interested to see how your standards
differentiate projects based on occupancy + size + voltages + etc... Not to
mention regional differences. And how the outcome of this aspect affects the
on-the-ground realities... Will the bar move toward the middle? I guess that
depends on where you see the bar right now... I see it as too low, generally
speaking. Way too low, in fact. Will integrators who traditionally have
submitted crappy documentation improve their practices? Or just get out of
the business? Either of these would be another positive side effect. Will
integrators who traditionally have submitted stellar documentation lower
their standards? This would be a negative side effect....

As with all matters related to the diversity in AHJs, it will be interesting
to observe the implementation process. Particularly in areas where "we
already know what we're doing" or "we don't need no stinking solar" are the
attitudes.

Meanwhile and until that proves successful, if there are examples of "better
than what we have now" out there, I advocate using them. I see the TUCC
policy as being just that in many locations across the country. I haven't
had a chance to go through the stuff Ryan referred to in Portland yet, but
will. I don't care what the source is, personally. I only care that we're
collectively doing it a little better each day.  

Peace and Sunshine Wishes to all!

Matt Lafferty

-----Original Message-----
From: re-wrenches-bounces at lists.re-wrenches.org On Behalf Of Bill Brooks
Sent: Wednesday, February 25, 2009 3:59 PM
To: 'RE-wrenches'
Subject: Re: [RE-wrenches] Beat your local AHJ's over the head if youhave
to...

Ryan and Matt,

There are significant efforts underway to standardize permitting. Too many
efforts are going on that will cause a proliferation of different ideas,
rather than standardization. The ICC Tri-Chapter document is good, as it is
based on the SMUD document, but it falls significantly short of providing
standardization. It has the all-encompassing statement, "8) The installation
of the PV system shall conform to the requirements of CEC Article 690 and
any other applicable articles or standards." That makes this document very
nearly worthless since it is not specific.

Solar ABCS (URL www.solarabcs.org) has commissioned me to develop an
Expedited Permitting process that brings together the best of what has been
done up to now. These efforts include not only the ICC Tri-Chapter work, but
also SolarTech, my Inspector Guidelines, and John Wiles checklist. The basis
is to have a process whereby a jurisdiction could do an over-the-counter
permit for single-phase, residential-sized, PV systems. This is the real
need in the PV industry. There are similar needs in the SDHW market.

The draft of this document will be available very soon. It will be going out
for internal review to a few folks this week. The draft version will be
available for comment within a month. The key to this document is a
standardized electrical diagram. This also makes the process easier to
accommodate an on-line permit submittal process.

Bill.





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