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Vermont Enacts First-in-nation Solar Registration

REW.com Editors
May 26, 2011  |  10 Comments

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Vermont has enacted a first-in-the-nation registration process for small solar systems, providing a national model for mitigating costly local solar permitting.

H.56, signed by Vermont Governor Peter Shumlin on May 25, establishes a simple registration process for solar systems 5 kW and smaller. 

The process, which replaces permitting, allows solar customers to install the system 10 days after completing a registration form and certificate of compliance with interconnection requirements. The utility has 10 days to raise any issues concerning the interconnection, otherwise a Certificate of Public Good is granted and the project may be installed.

A recent study earlier this year produced by SunRun found that permitting adds an average cost of $2,500 to each solar installation and that streamlining the often cumbersome process would provide a $1 billion stimulus to the solar industry over the next five years.

The report finds that the additional installation cost — $.50 per watt — is due to wide permitting variations not connected to safety, excessive fees, and an unnecessarily slow process. The report cites that Germany has a 40 percent installation price advantage over the United States. Vermont already has a much more cost-effective, free statewide permitting process than most states.

“Cutting unnecessary red tape and costly permitting for small renewables should be a national model if we are going to meet our energy needs and be competitive worldwide,” said David Blittersdorf, president and CEO of AllEarth Renewables, manufacturer and installer of the AllSun Tracker.  

Mark Sinclair, executive director of Clean Energy States Alliance, says “solar registration is an innovative way to address the high costs and long timeframes that are often associated with installing small-scale renewable energy systems."

The registration process will go into effect January 2012.

Vermont’s legislation also expands the state’s successful net metering program by establishing a statewide solar customer benefit, which gives solar a minimum value of $0.20, increasing the allowable size of net metering projects from 250 kW to 500 kW. This also increases the per utility net metering cap from 2 percent to 4 percent, and improves group net metering billing.


10 Comments

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Robert Riversong
Robert Riversong
January 17, 2012
"code sets the minimum standard" - which means that, if you meet code, you've earned a D- (you are just above failing). No responsible builder builds to code minimum standards.
Gerry Wootton
Gerry Wootton
January 17, 2012
Roof failures are not specific to older buildings at all. The structural engineering studies I refer to are for 'state of the art' wood truss frame construction. One aspect of this is that decking has actually gone downhill in modern times.
'no solar technology should be roof-mounted without a licensed engineer's approval' - I didn't make the rules; however, in most jurisdictions an engineering study must be submitted in order to get approval for the installation. This is probably overkill: I think a building inspector should be sufficient to the task.
The problem with doing it right takes a lot of effort up front which translates into cost. Currently, this adds a substantial cost to an installation - currently around 15-20%. We need to find a better way.
One basic problem is that building codes are regional and can be somewhat agnostic to environmental zone. One interesting thing is that structural damage due to hurricanes is high in spite of the fact that building codes require anchors, tie plates, tie downs, etc. - basically, no one wants to pay for a roof capable of sustaining >110 mph wind in every direction (insurance is cheaper). Another interesting thing is that Colorado seems to be a bit of a hotspot for snow load colapses.
'If there were a way to outlaw incompetence, that would be a far better solution than outlawing custom design and construction' .. I couldn't agree more; unfortunately, code sets the minimum standard which may not always be sufficient.
Robert Riversong
Robert Riversong
January 17, 2012
Your argument leads logically to very different conclusions than you first recommended: eliminating custom builds.

The roof failures you speak of are predominantly older buildings, erected when codes were either non-existent or inadequate or poorly enforced. Current codes are quite strict about wind load requirements, led by Dade County FL after Hurricane Andrew. One interesting sidenote of the Andrew damage is that cookie-cutter homes built by tract builders suffered the most damage while those built one-off by volunteers of Habitat for Humanity survived.

If there were a way to outlaw incompetence, that would be a far better solution than outlawing custom design and construction (i.e. craft and innovation). But the logical conclusion of your points is that either building codes must assume that all roofs may be retrofitted with solar technology or that no solar technology should be roof-mounted without a licensed engineer's approval (or at all).

Your argument that mass-produced products, whether manufactured homes or solar systems or widgets are more reliable for that reason is thoroughly undermined by the history of mass production in America. Until very recently (and still to a large extent) manufactured housing is of poor quality and it is for that very reason that people have preferred a custom build.
Gerry Wootton
Gerry Wootton
January 17, 2012
One can commit 10 times as much know how to a product that is sold 1000 times at 2% of the distributed cost compared to a one-off even allowing for significant amounts of design reuse. Equally, all phases of production go through one learning curve independent of quantity up to the point where capacity is replicated.
Buildings, particularly roofs, fail- quite a lot if insurance statistics are accurate. Analysis of standard residential construction shows that the average structural failure point of a roof under wind load (sans additional loads) is between 92 and 107 mph depending on wind direction. In the last decade, the cost of structural roof damage due to hurricanes alone averages ~$3.5B per year with ~$5B in more severe structural damage. Tornado ally can pretty much match that and the northwest comes close as a result of snow loads. Where I grew up snow load is a real threat and many do snow removal on their roofs once or twice a winter. This summer, I looked at a new house built much above code which was pretty much demolished by the worst snow pack in 45 years. Bottom line: standard construction can and does fail due to weather conditions with non-trivial frequency.
When engineering rooftop solar, the resulting structure must meet higher standards for passive and dynamic resistance than without solar panels. This is not just additional static or dynamic load as much as it is about a more stringent standard being applied. This came as a bit of a shock when designing a generic rooftop system. One result was that for certain climate zones, standard construction, even with a weightless solar array, could not be in compliance. There is a slight bit of sense to raising the bar since a solar array adds ~$50/sf to the value of a roof and since flying solar panels represent an additional hazard relative to roofing. Also, solar installations typically apply an unbalanced static load to the structure lowering the breaking point more than a uniformly distributed load.
Robert Riversong
Robert Riversong
January 16, 2012
GeraldR says "let's not go overboard", which is precisely what his previous comment did: a prescription for the outlawing of custom-designed or built solar systems - not just the electrical interface.

GeraldR says "I'm sure you've had a few failed inspections that required rework at the very least. With custom builds, architects and structural engineers always seemed to miss a few details and/or ran afoul of local codes."

Clearly, your experience is much different than my 30 years of building. I've never had a failed inspection, never fun afoul of local codes, and never missed important details since I serve as designer, engineer and construction supervisor and maintain a big-picture perspective with nary a hammer lifted until every detail of the project is thoroughly designed and planned.

That is what a custom project allows. Your mileage obviously varies.
Gerry Wootton
Gerry Wootton
January 16, 2012
@Riversong - let's not go overboard. I have a few years of experience in commercial and MURB construction. Custom means mistakes will be made. I'm sure you've had a few failed inspections that required rework at the very least. With custom builds, architects and structural engineers always seemed to miss a few details and/or ran afoul of local codes. Repeat 'cookie cutter' builds always went much better. I don't recall that we ever assembled a furnace or HVAC unit from piece parts. 40 years experience in product manufacture and engineer to order systems tells me that custom engineering and production is always an adventure. And I own two 100+ homes which have required significant structural re-engineering and complete redesign of plumbing and electrical systems which tends to suggest that custom built isn't foolproof.
In any case, all I am saying is that the safety critical electrical interfaces such as the load center entry - protection, physical disconnect, wiring, etc. - should be standardized and inverters should be standardized around a matching specification. We're way past the time where residential electrical devices are custom made or even custom specified and that's a good thing: economy of scale includes increased safety and value engineering along with better cost certainty.
I fully agree that rooftop mounting is a can of worms exacerbated by custom construction practice, but the primary problem is that buildings are not engineered or even required by code to be compatible with a solar installation. However, I believe it is possible to devise a retrofit installation kit that could be qualified against standard building codes.
I would note that similar issues arise for residential storage systems and it seems that the best solution is an outdoor unit that would sit on an isolated concrete pad several feet from the building in order to minimize the intersection with local electrical code and fire code requirements.
Robert Riversong
Robert Riversong
January 16, 2012
GeraldR,
As a 30-year residential designer/builder and an instructor in residential engineering, I can assure you that current building codes result in roof assemblies that can adequately resist local live and dead loads, including wind uplift. The codes, however, are not designed to include additional point loads such as solar installations and it is the responsibility of a solar designer/installer to determine the additional load capacity of a particular roof.

What I hear you suggesting is that only solar equipment manufacturers or distributors should be allowed to package systems. I am not a solar designer or installer, but what you suggest is the equivalent of saying that all homes should be manufactured packages and that custom builders should be regulated out of business. If we custom builders have been able to assemble homes from a million individual parts that function well and stand for a hundred years or more, I suspect that competent solar installers can assemble a far simpler system, and perhaps - in their innovation - develop better systems than those that come in a box.
Gerry Wootton
Gerry Wootton
May 27, 2011
Andrew raises a good point. We've got to stop selling PV systems as a bag of bolts and instead sell a complete package with the package as a whole being certified. Every time an installer custom engineers a system in some way, there's added risk. So far, the solar industry (and the standards organizations) are a bit behind at the system level. When you do central air, you don't get a scroll pump, a motor and heat exchangers in separate boxes from different manufacturers (someone has put the whole package together and certified it). The type and even the location of the service disconnect is a specified standard and so on. On the other hand, for solar systems you're stuck with individually certified piece parts. Even though modules should be certified for wind and snow load, that's for an anonymous (almost never documented) zone and classification of terrain and the mounting location and method of attachment used in that certification is rarely disclosed. The typical installation guide is overly vague in that respect but typical racking systems are agnostic to the requirements of the modules anyway so better advice wouldn't necessarily help. Doesn't anyone understand metalurgy and electrolysis?
One serious problem is that building codes for residential construction don't actually meet requirement - roofs collapse, roofs get blown off, etc. - which means that many roofs are not fit to support themselves let alone additional equipment. Most of the small installations I've seen that I'd trust are factory assembled ground-mount systems. Not necessarily what you'd want in the back yard but there's room for solar garden sheds, cabanas, patio awnings, car-ports etc. that would combine form and function in a good and safe way. Any small system that takes more than a few hours to install (properly) should be suspect as every hour of custom work is likely to increase overall risk.
Andrew Truitt
Andrew Truitt
May 27, 2011
I am all for streamlineing the permitting process, but we also need to minimize the risk of poorly designed and unsafely constructed systems being installed. In my 7 years of designing and installing PV I have seen too many unfortunate systems that are at risk of blowing off the roof, springing a leak, or starting a fire. I think the Solar America Board for Codes ans Standards' (SolarABCs.org) Expedited Permitting Process strikes a good balance between responsible oversight and minimizing red tape.
Gerry Wootton
Gerry Wootton
May 27, 2011
Small systems should be treated like appliances. The standard residential interface has a 48 kVA capacity. 5 kW of generating capacity represents up to 10.4% of the interconnect capacity. This is barely a disturbance even if every consumer on a given local distribution transformer were to implement a 5 kW system. There should be no more red tape than what it takes to add a 5 kW load such as an electric water heater. One can assume that any approved appliance - residential solar inverters included - will supply an acceptable level of safety without any further approvals being needed. Technical arguments are just a smoke screen for what's really at stake: distributed generating capacity reduces the revenue stream of utilities and power producers.

Note: there are approved inverters and back-feed panel breakers on the market. Perhaps it should be a code requirement for all new construction to include a 240V / 30 A back-feed service receptacle.

Personal experience: added 4 kVA central air to a 24 kVA service - no permit or registration required. Attempting to add 1.5 kVA of solar: ~$1500 worth of red tape so far.

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