New rules are now in place that have significant impact on solar projects at California public schools. Effective October 1, the California Division of the State Architect (DSA) did away with some inspection exemptions, and added further restrictions as of November 12th in relation to the October 1 Bulletin. These changes add time and complexity to solar PV planning. Here’s a quick rundown:
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DSA NO LONGER CONSIDERS ANY DISTRICT-OWNED SITE EXEMPT FROM INSPECTION AND PERMITTING FOR SOLAR PV PROJECTS. THIS INCLUDES DISTRICT OFFICES AND ADMINISTRATION BUILDINGS, MAINTENANCE AND OPERATIONS FACILITIES, AND OTHER SITES WHERE STUDENTS ARE NOT TYPICALLY PRESENT.
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These facilities will need full ADA compliant designs to meet DSA approval for solar projects, and additional upgrades may be required.
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Districts should give serious consideration to pursuing a full DSA backcheck review and permit for these sites, rather than an access-only permit. Otherwise, additional ADA designs, implementation, inspections and upgrades may be required if and when any future work is performed at the site.
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Vendors expect this change to have pricing implications for school solar PV projects, given the added time and complexity of installing solar PV on these sites.
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GROUND-MOUNT SOLAR PV SYSTEMS ARE NO LONGER EXEMPT FROM DSA PERMITTING, AS OF OCTOBER 1, 2020. PREVIOUSLY, FENCED IN GROUND-MOUNT PV SYSTEMS WERE NOT SUBJECT TO DSA INSPECTION AND APPROVAL.
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Full DSA backcheck review and approval is now required for all ground mount plan sets, including access, fire, life-safety and structural. Fire approval may require additional setbacks, brush clearing, fire lanes, etc.
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Unlike solar PV canopies, there are currently no ‘pre-check’ ground mount systems that meet DSA requirements for quick, over-the-counter approval. This will add significant time to the DSA permitting process for ground mount PV systems.
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An additional November 12 DSA Bulletin BU 20-03 has also required previously ‘Grandfathered DSA Exempt Ground Mount’ projects that were designed and School Board approved prior to the October 1, 2020 deadline must now begin construction by January 1, 2021, or they will subject to full DSA backcheck review and approval.
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Most, if not all, ground-mount system manufacturers lack the necessary documentation for DSA structural approval. An energy advisor like Sage can work with districts to select vendors and manufacturers who are willing and capable of generating drawings to meet DSA guidelines to ensure that projects move through DSA as quickly as possible.
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ENHANCED SPECIAL INSPECTIONS FOR PV MODULE TO PURLIN TORQUED MECHANICAL CONNECTION FOR PRE-CHECK CANOPIES.
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Specific to each current pre-check canopy design, an updated PV Panel Fastener Installation Procedure requirement has been added to these designs by DSA.
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Based off of the total quantity of PV module to purlin ‘bolt stacks’, a representative from the Laboratory of Record (LOR/Special Inspector) is required to verify minimum torque values for varying statistical samples dictated by a certain % level of confidence vs. % margin of error.
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These new requirements are expected to result in significant increases in district costs for IORs and Special Inspectors on solar PV canopy projects which will need to be accounted for when considering overall project economics.
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