Permitting + Inspection for Photovoltaic Systems Installation

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GOALS:

  • Understand the role of building codes and code enforcement in electrical installations. Describe the common requirements for permit applications.
  • Identify the applicable articles of the NEC for both general electrical system requirements and PV specific requirements.
  • Describe the labeling requirements for PV systems and components.
  • Understand the function of an inspection checklist in checking a PV system for common installation code compliance issues.

BUILDING CODES and REGULATIONS

Each community has a building code that applies to the installation of electrical equipment on residential and commercial properties. A building code is a set of regulations that pre scribes the materials, standards, and methods to be used in the construction, maintenance, and repair of buildings and other structures. The purposes of building codes are to protect public safety and ensure quality construction projects. Building codes cover all construction trades, including electrical, mechanical, plumbing, structural, fire and life safety, and energy efficiency.

Building codes are applicable to the construction and installation aspects of PV systems, just as for any other electrical system. These regulations may dictate who can install PV systems and the requirements for different system types and sizes. Any designer, contractor, or code official involved with integrating, installing, and inspecting PV systems should be familiar with these requirements.

Building code requirements are both technical and administrative in scope. They affect manufacturers and suppliers of equipment and materials, as well as installers, contractors, code officials, and end users. Building codes are enforced by inspections, the issuance of building permits and certificates of approval or occupancy, and the imposition of fines for violations.



Product safety standards, installation codes, and code enforcement are separate but related components of the electrical safety system. This system depends on a close working relationship among the organizations responsible for the development of product standards and installation codes and the electrical inspection community. All three components must be in place for the electrical safety system to be effective.

Code Adoption

A building code must be adopted by the state or local jurisdiction as law to apply and be enforceable. The jurisdiction may choose to develop its own building code, but this is un common. Most adopt model building codes, sometimes making small modifications to suit their locale. A model building code is a building code that is developed and revised by a standards organization independently of the adopting jurisdictions. The National Electrical Code (NEC ) is an example of a model building code.



Building codes may contain guidance on the administration and enforcement of the code, such as requirements for electrical boards, the responsibilities of code officials, and the processes for plans review, permitting, and inspections. Article 80 in Annex H of the NEC Electrical Safety System

-- 1. Product standards, installation codes, and code enforcement are separate but related functions that result in higher-quality and safer installations. INSTALLATION CODES; PRODUCT STANDARDS and CERTIFICATION; INSPECTION and ENFORCEMENT; HIGHER-QUALITY and SAFER INSTALLATIONS

Each major city in the United States once had its own building code Since building codes are very expensive to develop and maintain, most cities eventually adopted model codes Only a few cities, such as Chicago, continue to maintain local codes is such a guide, though it applies legally only if it has been formally adopted along with the rest of the code by a local jurisdiction. Even when Article 80 is not officially adopted, most jurisdictions follow a similar approach.

Authority Having Jurisdiction

An authority having jurisdiction (AHJ) is an organization, office, or individual designated by local government with legal powers to administer, interpret, and enforce building codes. The AHJ approves equipment, materials, installations, and procedures by issuing permits, conducting inspections, and granting certificates of approval or occupancy.

With respect to electrical construction, the basic responsibility of the AHJ is to verify that electrical installations, including PV systems, comply with the NEC. The AHJ is permitted to waive, in writing, specific requirements of the NEC or to permit alternative methods where it’s assured that equivalent safety objectives are maintained. The AHJ also has the authority to disconnect electrical systems when hazardous conditions exist and until such problems are corrected.

The AHJ delegates powers to qualified plans examiners and electrical inspectors. These electrical officials are typically licensed and certified at the state or local level, and have demonstrated a thorough knowledge of the applicable codes and standard materials and methods used in electrical installations. Responsibilities and requirements for electrical inspectors and plans examiners are established in Article 80 of the NEC , as well as in local building codes or by licensing boards.

Plans Examiners. A plans examiner is a local official qualified to review construction plans and documentation for compliance with applicable codes and standards. Plans examiners evaluate drawings, schematics, specifications, instructions, and equipment manuals, and verify the suitability and proper application of equipment. A plans examiner may specialize in the electrical, mechanical, or structural aspects of construction plans.

Electrical Inspectors. An electrical inspector is a local official qualified to evaluate electrical installations in the field for compliance with applicable codes and standards. Electrical inspectors visually evaluate the safety of electrical installations in accordance with the approved plans and local codes. They identify the suit ability and proper installation of equipment, conductors, overcurrent protection devices, disconnects, and bonding and grounding. Other building inspectors may evaluate PV installations according to mechanical and structural requirements.

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IAEI

The International Association of Electrical Inspectors (IAEI) is a trade organization for the electrical code official community and has thousands of members in over 30 countries. The IAEI is a valuable resource for electrical inspectors and promotes uniform standards and a common interpretation of the NEC and other codes. The IAEI seeks to promote cooperation between inspectors, the electrical industry, and the public, and to collect and disseminate information related to the safe use of electricity.

The IAEI regularly publishes articles on PV systems and the NEC in the IAEI News. These articles address specific areas of PV system installations, their associated code requirements, and solutions to common problems. These articles are a valuable resource for any contractor, code official, or utility representative involved with the installation of PV systems.

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--2. The UL Listing Mark indicates if the product is listed for both the United States and Canada. UI Listing Mark LISTED FOR UNITED STATES US LISTED 2P09 PHOTOVOLTAIC MODULE El 6067 PRODUCT; CONTROL NAME; NUMBER

Approved Equipment

The use of approved equipment is required by the NEC and facilitates the plans review, permitting, and field inspection processes. Approvals are based on examinations of the equipment for safety, installation, and conditions of use. In most cases, equipment is approved for its intended application by a recognized testing laboratory. A nationally recognized testing laboratory (NRTL) is an OSHA-recognized, accredited safety testing organization that certifies equipment or materials to meet applicable standards.

This independent approval process allows AHJs to avoid the time-consuming and potentially inconsistent process of conducting their own equipment evaluations, while assuring AHJs, contractors, and consumers that electrical equipment is safe and appropriate for a given application. Approved equipment is identified with product listing marks on its label. Listing is the process used by an NRTL for certifying that equipment or materials meet applicable standards.

To obtain a product listing, a manufacturer produces a product in accordance with the applicable standards and submits prototypes to an NRTL for evaluation and approval. The NRTL tests the prototypes for compliance with the standards and, if the standards are met, authorizes the manufacturer to use its product certification mark. The manufacturer's production facilities are then periodically inspected by the NRTL to ensure continuing compliance with the standards and conditions of listing.

PV modules, inverters, charge controllers, and other electrical equipment are typically listed by Underwriters Laboratories, though it’s common to see other types of product certification marks on PV components.

Underwriters Laboratories (UL). Underwriters Laboratories is perhaps the most well-known NRTL and provides safety certification services for a variety of products used throughout the world. There are several UL marks, each with specific meaning. These marks may only be used on or in connection with products certified by UL, under the terms of a written agreement between UL and the manufacturer.

The UL Listing Mark is one of the most common UL marks. It signifies that UL has tested representative samples of the product in accordance with UL's safety standards and that the manufacturer's production facilities are routinely inspected by UL for compliance with the standards. Products may be listed to either Canadian or U.S. safety standards, or both. Canadian listing marks appear with a "C" on the left side of the mark, and U.S. listing marks appear with a " US" on the right side. The UL Listing Mark is accepted by the NEC and the Canadian Electrical Code as evidence of approved equipment. The UL Listing Mark includes the UL symbol with the word "LISTED," a control number, and a product name such as "Photovoltaic Module" or "Utility-Interactive Inverter."

Listing requirements for PV modules are established by UL 1703, Standard for Flat-Plate Photovoltaic Modules and Panels. Listing requirements for inverters and charge controllers are governed by UL 1741, Inverters, Converters, Controllers, and Interconnection System Equipment for Use with Distributed Energy Resources.

The UL Classification Mark is used on products that UL has evaluated only with respect to specific properties, a limited range of hazards, or suitability for use under limited or special conditions. Classified products may be tested to the same standards as listed products and may be of equal quality. The difference is that listed products are evaluated for all reasonably foreseeable situations applicable to the standard, while classified products are evaluated for only a certain set of circumstances. Products classified by UL include building materials, protective gear, and fire safety equipment. Roofing products and PV modules may also be classified for fire rating.

Some products may be both listed and classified and use a combination listing! classification mark with the text "Also Classified in Accordance with" and the applicable classification standard. Listed PV modules can be classified in accordance with IEC 61215 or IEC 61646 design qualification standards. These classifications are indicators of the quality of module design and reliability. Design classifications are not required for code compliance, but may be specified when the most reliable PV modules are desired.

The UL Recognized Component Mark indicates that a component is certified to meet the requirements for a limited, specified use as part of a larger product or system and is not intended for separate installation in the field. When products submitted to UL include recognized components, the evaluation and approval process of the overall product is faster. However, equipment composed of recognized components does not automatically constitute approval or listing for the complete equipment. UL Recognized Component Marks are found on a wide range of electrical products, such as switches, power supplies, motors, terminal blocks, and batteries.

Equipment or products that are modified or don’t bear a third-party certification mark may be evaluated by UL in the field at the request of a building owner, manufacturer, or regulator. Products that meet appropriate safety requirements are labeled with a tamper-resistant UL Field Evaluated Product Mark.

Canadian Standards Association. The Canadian Standards Association (CSA) is an OSHA-accredited NRTL that tests using similar processes and to the same industry standards as other NRTLs. The CSA also publishes the Canadian Electrical Code. CSA Marks are recognized and accepted throughout the United States by federal, state, and local authorities. A CSA Mark with the indicator " US" or "NRTL" means that the product is certified for the U.S. market to the applicable U.S. standards.

== Listing and Conformity Marks

POWER CONDITIONING L USE IN PHOTOVOLTAIC P SYSTEMS STANDARD POWER CONVERTERS and CONVERTER SYSTEMS FO' RECREATIONAL VEHICLES STANDARD UL 458 COMMERCIAL and INDUSTRIAL POWER SUPPLIES CERTIFIED TO CHARGE CONTROLLER AMPS; WATTS VOLTS CE MARK CSA MARK (IST 67664 ETL LISTING MARK CE

--- PV equipment may bear the marks of listing and certification organizations other than Underwriters Laboratories.

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FIRE-RATING

Classifications Building codes establish fire-resistance requirements for construction materials, including roofing products. These requirements apply to PV modules because they can be installed on rooftops and in building-integrated applications. Most PV module manufacturers have their products tested by UL and classified for fire-resistance rating. Modules that have not been classified with respect to fire exposure are marked "Not Fire Rated?' The fire-resistance rating is the level of resistance to external fire that a roof covering provides to the roof decking below. Classes A, B, and C represent different levels of fire resistance. All classified products won’t spread fire to the roof deck, slip from position, or produce flying debris under the fire conditions of their classification. The differences are in the severity of fire exposure that the products can withstand.

These classes are defined by ASTM E108, Standard Test Methods for Fire Tests of Roof Coverings, and ANSI/UL 790, Standard Test Methods for Fire Tests of Roof Covering Materials. Class A roofing products are effective against severe fire exposures. Most building codes recognize brick, masonry, slate, clay or concrete tile, exposed concrete, and copper shingles as Class A roofing materials without being tested. Class A roofing products are generally only required for buildings where the roof falls under interior fire rating requirements or for construction in special fire districts. PV modules used for building-integrated installations may be required to have a Class A fire rating.

Class B roof coverings are effective against moderate fire exposure. Building codes recognize aluminum roofing as Class B without testing. Class C roof coverings are effective against light fire exposure. Class C fire ratings are acceptable for PV modules used in most residential and commercial rooftop applications.

MAX SYST. OPEN CKT. VOLTAGE=600V; ICOPPER ONLY, 14 AWG MN, J FOR 90°C MN.

Module fire ratings are included on module labels.

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Many components are certified for more than one market and include multiple listing or certification marks on their labels.

Intertek ETL. Intertek is an OSHA-recognized NRTL and provides testing, inspection, and certification of electrical products for manufacturers and retailers around the world. Among their certification and conformity marks are the ETL Listed Mark for North America and the CE Mark for Europe. ETL Listed Marks are found on some PY inverters, which are tested in accordance with the standard UL 1741.

CE Mark. The CE Mark is a European marking of conformity that indicates that a product complies with the requirements of standards with respect to safety, health, environment, and consumer protection. It’s used on products to facilitate trade between member countries of the European Union (EU). Unlike the UL Mark, the CE Mark is not a safety certification. It’s based on a self-declaration by the manufacturer, as opposed to a third-party independent certification. By itself, it does not indicate compliance to North American safety standards or installation codes. However, quality products may bear the CE Mark in addition to listing marks.

Other Marks. Other listing and certification marks may appear on PV equipment, especially on equipment produced for markets outside of North America. For example, PV products produced for European markets are often certified by TUV Rheinland and are labeled with corresponding TUV Marks. The European Solar Test Installation (ESTI) is another certification body recognized by the European Commission for PY module testing and certification capabilities.

Contractor Licensing

All electrical work should be performed by qualified persons. A qualified person is a person with skills and knowledge of the construction and operation of electrical equipment and installations and is trained in the safety hazards involved. In most cases, local and state contracting laws and regulations require an electrical contractor to be licensed in order to apply for permits and perform electrical work, including work on PV systems. Licenses are granted by state or local governments and are different from trade certifications, which are conferred by nongovernmental organizations such as NABCEP.

Licensing ensures that the contractor understands and complies with the applicable construction laws and regulations. Licensed contractors should complete all installations in a timely manner and to the owner's satisfaction. If there is a problem with a contractor's work, licensing also provides a means of ad dressing the issue, by filing a complaint with the license-issuing authority.

Local electrical contractor licenses that are offered by counties and municipalities limit work to a relatively small area. However, many states have statewide licensing programs that are accepted by every AHJ in the state. Several states also have reciprocity agreements with neighboring states with similar contractor licensing requirements. This means that contractors licensed iii any one of the states in the group may also work in any of the other states in the group through a simplified application process.

Solar Contractors. A few states, including Florida, California, Oregon, and Nevada, have a solar contractor license classification. The scope of work for this licensure may include both PV and solar thermal systems. However, these licenses are controversial in that they generally don’t require rigorous electrical systems training. The solar contractor may be limited to performing only incidental electrical work and may need to hire an electrical subcontractor to install any premise wiring or make connections to the utility grid.

A qualified electrical contractor has extensive knowledge and experience and the license does not limit the scope of the contractor's electrical work on PV systems in any way.

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Qualified Person

A qualified person is trained to recognize potential electrical hazards and can administer first aid and CPA in an emergency. Training must include the use and inspection of personal protective equipment (PPE) and use of insulated tools and test equipment. Persons working on or near exposed energized conductors operating at 50 V or above must be able to identity exposed live parts and their voltage, assess the risks for the type of work to be performed, and determine the appropriate PPE and other safety precautions required. Persons may be considered qualified for certain equipment or methods and still be unqualified for others. Apprentices may be considered qualified if they have demonstrated the applicable knowledge and skills and are under the supervision of a qualified person. OSHA regulations and NFPA 70E, Standard for Electrical Safety in the Workplace, include more information and descriptions of job safety requirements.

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Owners wishing to act as their own contractor face a lot of responsibility They must carefully study the applicable building codes and be prepared to address any questions the inspector may have The owner contractor must schedule inspections and remedy any compliance issues that the inspector finds If they fail an inspection, they may also be charged a fee to cover additional inspection costs.

Owner-Contractors. In some jurisdictions, property owners are allowed to apply for permits and act as their own contractor with out having a license. These owner-contractor exemptions allow owners to install electrical wiring and equipment to their own residence or commercial building, for projects costing up to a certain dollar amount. The owner may be required to occupy the building, and may be restricted from selling or leasing the property for one year after the work is completed. Owner-contractors are not relieved from any normal contractor responsibilities or the requirements of building codes and other regulations. Owner-contractors are also prohibited from hiring unlicensed persons to act as their electrical contractor or employing any unlicensed individuals to perform the work. These provisions are in line with contracting law and are intended to protect public safety.

Construction Bonds. AHJs may require evidence of financial responsibility on the part of the contractor as a condition of licensure. Commonly, this requirement is satisfied by a construction bond. A construction bond is a contract in which a surety company assures that a contractor will complete their work in accordance with contracting laws. If a contractor does not meet their obligations, a claim can be filed against their bond by property owners, employees, subcontractors, or suppliers. As opposed to an insurance policy, a contractor is obligated to reimburse the surety company for any payments from the bond.

Construction bonds represent the amount of money available for claims for all jobs a contractor performs over the life of the bond. Minimum bond amounts for residential contractors are usually $10,000, with higher amounts required for commercial work or if the contractor has been subjected to licensing disciplinary action. Most state laws require the surety company to report claims on a con tractor's bond to licensing boards. The surety may also cancel the bond and the licensing board may suspend the contractor's license until the surety is reimbursed for any claims. Contractors can avoid claims against their bond by using written contracts and communicating openly with their suppliers, customers, and employees to resolve any problems.

Building Restrictions

[PV systems should be installed by licensed contractors or qualified persons.] Building restrictions include easements, covenants, and ordinances, and are imposed by state or local governments or homeowner's associations. These limitations may restrict permanent construction on certain parts of a property, which can affect PV systems. Easements restrict construction within a certain distance of the property lines to allow utility access. Homeowner's association covenants may regulate solar installations for aesthetic reasons. Community ordinances may ban structures and antennas above a certain height, which may affect PV arrays installed on tall racks. Although these concerns are rare for most PV installations, the owner or installer should investigate potential issues in their jurisdiction.

Some regulations, however, benefit a property owner seeking to install a PV system. For example, some regulations protect a property owner's right to solar resources by prohibiting the erection of structures or planting of trees on adjacent properties that blocks the solar resource to a property. Also, some states make it illegal for covenants or deed restrictions to prohibit the installation of renewable energy systems on homes. More states are expected to follow in this trend.

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