Solar energy has "hard costs" -- panels, racking, inverters. But it also has "soft costs", AHJ permits, delay, filing fees, repeat inspections. Solar PV may appear dangerous and complex to jurisdictions; all too often they require extraordinary paperwork and inspections for small and simple home arrays. REIA NM (Renewable Energy Industry Association of New Mexico, a renewable trade group) worked for a year on the definition of a "simple system" for both Solar PV and Solar Thermal, and developed a single page permitting system that covers 80% of installations in New Mexico. I "chaired" this committee: set up the meetings, reminded and guilt-tripped busy CEOs to attend, took minutes, did requested research between meetings, gathered materials, presented the permit design and made the final presentation. This work was done in 2011.

1. EXPEDITED PV PERMITTING
Proposal from the Renewable Energy Industry of New
Mexico

2. WHY STATEWIDE STANDARDS NOW?
 Statewide experience of integrators
 Mature technology
 Increasing consumer interest

3. WHY STATEWIDE STANDARDS NOW?
to03/2010

4. WHY REIA?
 New Mexico Renewable Energy Industry
Association
 25 members
 Majority small New Mexican integrators
 Plumbers and electricians
When you call REIA members they are always on the
roof

5. TOM YOUNG
 Mechanical Engineer, Direct Power and
Water
Rochester Institute of Technology
 Aerospace and vehicular systems
 Drivetrain & wind
 Structural strength and fatigue
 Wind power generation and storage

6. RANDY SADEWIC
 Positive Energy, General Manager, Board of
Directors
 Certificate in Renewable Energy Technology,
San Juan College
 Teaches NMSEA classes on PV
 ER1J, NABCEP-PV

7. ALLAN SINDELAR
 Founder and President, Positive
Energy
 Positive Energy has designed
and installed over 25% of all
grid-tied systems in the PNM
service area.
 EE98, EE98J, NABCEP-PV

8. STEVE HOUSE
 310 Solar
 Civil Engineer, New Mexico
State
 Operations & Business
Development Manager
 P.E. in New Mexico and
Arizona

9. ODES ARMIJO-CASTER
 Co-founder & Principal, Sacred Power
Corporation
• Certified Solar
Energy Instructor for
Siemens
• EE98, NABCEP-PV
and NABCEP-SHW

10. MIKE LAVINE
 All Star Energy • Code development for IAPMO
and Uniform Solar code
• Taught at UNM, CNM, Half Moon
• EE98J
• Inspection Experience
•Federal (electrical)
•Army Corp Engineers (utility water
supply systems)
•US Fish & Wildlife (PV)

11. LARRY MAPES
 Founder Valverde Energy
 Teaches UNM-Taos Campus
EE98, MM98, GB98
Why doesn’t Larry have a NABCEP?

12. KRISTY DYER
 Ph.D. Physics
 Radio Astronomy Escape

13. CONSTITUENCIES
 Consumers
 Integrators
 Inspectors
 Municipalities and other jurisdictions
REIA chooses to make the consumers’
needs primary, in our view of the
permitting process.

14. HOW DOES PERMITTING CURRENTLY WORK?
 Poorly.
 Uncertainty – Damages small businesses
 Geographic inconsistency – Prevents robust
competition
 Ineffective – Consumers are inconvenienced
but not protected

15. UNPREDICTABLE PERMITTING
 Integrators cannot predict:
 Which paperwork will be required
 Number of trips to city hall
“We are a professional organization, if I just knew what was
required we’d have it ready, but we will do 4 or 5 identical
installations and then suddenly be asked for different
paperwork for the 6th.”
“When we bid on a job, we figure we’ll spend one afternoon at city
hall getting permitting. If that turns out to be three trips that’s a
huge loss of time. I’ve been installing for 30 years, I’m an inspector
myself and there’s no correlation between the complexity of the job
and the paperwork.”

16. HOW MOM AND POP GET PAID
 PV Integrator meets several times with the
homeowner at the office, at the site, names a
price

17. WHAT DOES THE CONSUMER NEED?
 Safe
 Effective
 Affordable
No one gets shocked, scalded
The installation works to reduce utility bills
In regards to permitting:
• predictable
• timely
• complexity of installation
drives
documentation
In developing our permit process we will refer to these three goals

18. SOLAR AMERICA BOARD FOR CODES AND
STANDARDS (SOLAR ABCS)
 2009 DOE commissioned a report from Bill
Brooks: Expedited Permit Process for PV
Systems: A standardized process for the
review of small-scale PV systems
 Qualifications: Brooks wrote portions of the
National Electric Code and IEEE utility
interconnection standards, MS in Mechanical
Engineering, P.E., 30 years of PV experience

19. POLICY, NOT PERMITTING
 What kind of license?
 EE98 for PV
 MM98 for Solar Hot Water
 GB98 for PV or SHW

20. GOAL OF BROOKS’ PROCESS
 “(M)ajority of small, residential-sized PV
systems can be permitted quickly and easily”
 “A key difference between small and large
projects is the inability of small projects to
absorb engineering review costs.”

21. GOAL: 80% OF INSTALLATIONS IN THREE PAGES
 80-20 rule (Pareto’s rule)
 80% of your sales come from 20% of your clients
 Microsoft noted that by fixing the top 20% of the most
reported bugs, 80% of the errors and crashes would
be eliminated.

22. WHAT CAN WE ACHIEVE?
 Formal permitting process cannot cover all
possible installations
 Process will effectively sort out which
installations can be easily permitted – 80%
 Additional 10% of installations can be
effectively permitted by simple supplements

23. DELIVERABLES
 Permitting forms that jurisdictions can adapt
 Adobe PDF fill-in (submit paper or electronically)
 Web forms
 Permitting code that supports the forms
 Inspection checklists

24. REIA’S EXPEDITED PERMIT PACKAGE
 Forms
 Page ii, qualify and document control
 Page iii, purpose built and roof structure
 One-line diagram
 Notes for one-line diagram
 Supplementary Worksheets
 Code
 Commentary

25. WHAT QUALIFIES FOR EXPEDITED PERMIT?
Page ii

26. WHAT QUALIFIES FOR EXPEDITED PERMIT?
 If roof mount, is the array to be mounted on a
defined/permitted roof structure?
C 1.1.1 There is a need to distinguish if a roof has a lightweight
product. Heavier roofing materials (e.g. slate, heavy masonry,)
may not have the assumed dead loading and live loading
capacities that are found with lighter weight roofing materials.
These are much less common roof types and often justify a
further review to clarify whether the roof structure is either in
compliance or needs enhancement.
C 1.1.2 Multiple composition roof layers may be taking a portion or
all of the assumed additional weight allowance found in the 5
lbs/ft2 allowance at the end of the mounting system section.

Page ii

27. WHAT QUALIFIES FOR EXPEDITED PERMIT?
 Is the mounting structure purpose-built
for PV modules?
 C1.2.1 Non-purpose-built racking systems have undefined
capabilities. PV systems should only be mounted using
systems that are purpose-built. If an installer chooses to use
a mounting system of unique design, then the system would
require the design to be reviewed by a design professional.

28. PURPOSE BUILT
 A product specifically built by a reputable
manufacturer or engineering firm for the sole
purpose of mounting photovoltaic or solar
thermal collectors.
 “Purpose-built” means that engineers have
been involved in designing and testing the
systems and, if installed according to
manufacturers specifications, the consumer
gets a high degree of safety.

29. WHAT QUALIFIES FOR EXPEDITED PERMIT?
 PV modules, utility-interactive inverters, and
combiner boxes are identified for use in PV
systems.
 C 1.2.2 Without this specific identification process an unacceptable
amount of review would be necessary to approve an inverter. Inverters
that pass UL1741 and are listed as “utility-interactive” have met the
requirement. Over 500 inverters currently meet this requirement. An
inclusive list of these inverters is available online at
http://gosolarcalifornia.com/equipment/inverter.php. PV modules must
also be listed and identified for use in PV systems (as required by NEC
690.4). PV modules that pass UL1703 and have a 600-Volt maximum
voltage meet the requirement. A list of these modules is available online
at http://gosolarcalifornia.com/equipment/ pvmodule.php.

30. WHAT QUALIFIES FOR EXPEDITED PERMIT?
 The PV array is composed of <4 series
strings or less per inverter.
 C2.1.3 Additional series strings may be viable. However,
calculations must show compliance with series OCPD.

31. WHAT QUALIFIES FOR EXPEDITED PERMIT?
 The total inverter capacity has a continuous
ac power output 13,440 Watts or less.
 This limit is designed to stay within electrical
interconnections that would be considered simple and
possibly able to meet the 120% of busbar rating
allowance in NEC 690.64(B) in a residence (Minimum
breaker for a 13.44 kWac PV system is 70 amps). A 70-
amp breaker is important since a 225-amp busbar in a
200-amp panel will allow a 70-amp PV breaker.

32. WHAT QUALIFIES FOR EXPEDITED PERMIT?
 The ac interconnection point is on the load
side of service disconnecting means
[690.64(B)].
 Any line-side connection is covered by NEC 690.64(A) and
230.82. Although line side connections can be quite
straightforward, they should require an additional step in the
approval process and require a slightly different electrical
drawing.

33. WHAT QUALIFIES FOR EXPEDITED PERMIT?
 The electrical diagram (E1.1) can be used to
accurately represent the PV system.
 PV systems may vary dramatically in PV array layout and
inverter selection. However, the majority of small-scale,
residential-sized PV systems can be accurately represented
by this diagram.

34. DOCUMENT CHECKLIST

35. DOCUMENT CONTROL
 Manufacturers’ Electrical Specifications
 Manufacturers’ Product Installation Instructions

36. NAME, ADDRESS

37. GROUND MOUNTED/ROOF MOUNTED
 1. This array is to be Ground Mounted? Roof
Mounted?

38. PURPOSE-BUILT MOUNTING
 2. Is the mounting structure purpose-built to
mount PV modules? Yes No
 If No, provide details of mounting structure,
with an accompanying engineering letter.
 Non-purpose-built racking systems have undefined
capabilities. PV systems should only be mounted using
systems that are purpose-built. If an installer chooses to use
a mounting system of unique design, then the system would
require the design to be reviewed by a design professional.

39. WILL THE ROOF HOLD THE PV?
 To be completed for roof mounts:
 5. Is the array to be mounted on a defined, permitted roof
structure? Yes No
 If No submit worksheet WKS1.
 6. Is the roofing type lightweight (e.g. composition,
lightweight masonry, metal) Yes No
 If No, submit worksheet WKS1 (No = heavy masonry, slate, tile).
 7. Does the roof have a single roof covering? Yes No
 If No, submit worksheet WKS1.

40. WEATHERPROOFING
 8. Provide method and type of
weatherproofing roof penetrations: Flashing,
Caulk, other, please specify:

41. WEIGHT CALCULATIONS
 9. Total Weight of PV Modules and Rails ____________lbs
 10. Total Number of Attachment Points_______________
 11. Weight per Attachment Point (b÷c)_______________ lbs (if
greater than 45 lbs, see WKS1)
 12. Maximum Spacing Between Attachment Points on a Rail
_________inches
 (see product manual for maximum spacing allowed based on
maximum design wind speed)
 13. Total Surface Area of PV Modules (square feet)__________
ft2
 14. Distributed Weight of PV Module on Roof (b÷f)__________
lbs/ft2
 If distributed weight of the PV system is greater than 5 lbs/ft2,
submit WKS1.

42. E1.1

43. NOTES FOR ONE LINE DIAGRAM
The American Society of Heating, Refrigerating and Air-Conditioning
Engineers

44. NOTES FOR ONE-LINE DIAGRAM

45. SUPPLEMENTAL WORKSHEET 1: ROOF
 Roof mounted

 This section is for evaluating roof structural members that are site built. This
includes rafter systems and site built trusses. Manufactured truss and roof joist
systems, when installed with proper spacing, meet the roof structure
requirements covered in item 2 below.

 1. Roof construction: Rafters Trusses
Other:_________________________________
 2. Describe site-built rafter or site-built truss system.
 a. Rafter Size: __________ x _________ inches
 b. Rafter Spacing: ________ inches
 c. Maximum unsupported span: _____________ feet, __________________
inches
 d. Are the rafters over-spanned? (see the IRC span tables in B.2.) Yes No
 e. If Yes, complete the rest of this section.

46. SUPPLEMENTAL WORKSHEET 1: ROOF
 e. If Yes, complete the rest of this section.
 3. If the roof system has
 a. over-spanned rafters or trusses,
 b. the array over 5 lbs/ft2 on any roof construction, or
 c. the attachments with a dead load exceeding 45 lbs per attachment;
 the integrator shall provide one of the following:
 i. A framing plan that shows details for how the integrator will strengthen
the rafters using the supplied span tables in B.2.

 OR

 ii. A letter from an engineer that the roof structure will support the array.

47. SUMMARY
 The REIA permitting system (based on
Brooks) focuses on the needs of the
consumer
 Safe, effective, affordable
 Guides integrators towards simple, proven
solutions by making those systems 4-step
processes.

48. RECALLING EGGS

49. SCENARIO:
 Module is well designed and thoroughly
tested by American Engineers
 Lowest cost manufacturing bid
is from Dilbert’s Elbonia
 Modules made in Elbonia burst
into flame

50. RECALLING DANGEROUS MODULES
 Paper system:
New Permits: Must catch the manufacturers spec
sheets during submittal (5 pages in 500)
Old Permits: Hourly employee must go through
pages and pages of files, trying to find Elbonian
modules

51. RECALLING DANGEROUS MODULES
 Document Control System:
New Permits: In the Document Control Binder
the Elbonian document is stamped “Not
Permitted – Fire Hazard”
Old Permits: The cover sheet is checked for the
Elbonian document control number

52. NORMAL INSTALLATION OF SHW EXCEEDS 6’

53. PV AND BUILDING PERMITS
 1. A literal reading of the NMAC may actually
prohibit requiring a permit
 2. The IBC/IRC provides leeway for
jurisdictions to make intelligent decisions
about required documentation

54. WHAT IS THE HIGHEST MORAL GROUND?
 Since PV and SHW are “new technologies”
the best interests of the consumer (safe,
effective, affordable) will be served if the
juristictions work with REIA to draw up
reasonable guidelines.
 REIA can then promote these as “industry
standards” and for revisions to the NMAC

55. PV AND BUILDING PERMITS
 Jurisdictions are given significant leeway in
the codes:

56. LEEWAY FOR JURISTICTIONS
2006 International Building code

57. PV AND BUILDING PERMITS
 NMAC 14.5.2.9
EXCEPTIONS TO REQUIREMENT FOR
PERMITS: Permits shall not be required
for the following:
 …(14) Any work not otherwise regulated
by the New Mexico construction codes
and the CID rules.

58. PV AND ENGINEERED PLANS
 14.5.2 NMAC
 C. Exceptions: The requirement for plans and specifications to be
prepared by an architect and/or engineer shall not be required in any
of the following instances unless, in the discretion of the building official,
an exception is not in the best interests of public safety or health.
 (1) Multiple dwellings of not more than two (2) stories in height and
containing not more than four
 …
 (2) Garages or other structures not more than two (2) stories in
height which are appurtenant to buildings described in paragraph (a)
of this section.
 …
 (4) Alteration to buildings or structures that present no unusual
conditions or hazards or change in occupancy.
 (5) Single-family dwellings, not more than two (2) stories in height.
In some jurisdictions in New Mexico PV installations are
required to obtain documents that the original house wasn’t
required to have

59. WHAT GOES INTO PRODUCT DEVELOPMENT?
 Direct Power and Water: Racking
manufacturer
 Power Rail P6

60. DIRECT POWER & WATER
 Power Rail P6
 International Building Code (2006 IBC),
 Uniform Building Code (UBC), California Building
Codes (2007 CBC), and
 American Society of Civil Engineers (ASCE) 7-05

61. POWER RAIL P6 WIND LOADING
 Following section 6.5.13 of the ASCE 7-05
code, the velocity induced pressure on an
open structure is calculated by equation 6-
15: Velocity Pressure:
Design Wind Pressure:

62. POWER RAIL P6 WIND LOADING
 The ASCE 7-05 section 6.5 Method II Analytical
Procedure is understood to be a conservative
approach to calculating design wind forces on
open structures such as the Power Rail. For this
reason DPW Solar has performed full-scale
wind tunnel testing per ASCE 7-05 section 6.6,
Method III.
 Please contact DPW for additional information
in utilizing this method in situations where roof
loading or anchorage is of added concern.

63. POWER RAIL P6 SNOW LOADING
 Flat roof:
 Pitched roof:

64. POWER RAIL P6 WORST CASE SCENARIO
 3. D+S
 6. D+0.75(W or 0.7E)+.75S
 7. 0.6D+W
 8. 0.6D+0.7E
Dead load plus Snow
Dead load plus Wind or Earthquake, plus Snow
Dead load plus Wind
Dead load plus Earthquake

65. POWER RAIL P6
 Installation instructions

66. POWER RAIL P6

67. MANUFACTURER’S INSTALLATION INSTRUCTIONS
Pole Mount
Power Fab

68. DP&W: POWER FAB
 Pole Mount
 Power Fab