New building permit requirement - Class A fire rating?

[ocdave]

Just got word from my installer that there is an issue with obtaining a permit for my PV installation because, as of Jan 1, 2014, my city (Irvine, CA) is requiring all solar panels to have a Class A fire rating. My installer says that such panels are very rare. They said that other cities have adopted the same change so permits are being held up for others as well. Anyone else run into this? If so any thoughts on how this is going to play out? Will I have to change panels? I'm guessing that if the class A panels are that rare, they are also going to be more $$

[silversaver]

Class "A": The highest fire-resistance rating for roofing as per ASTM E-108. Indicates roofing is able to withstand severe exposure to fire originating from sources outside the building.

Class "B": Fire-resistance rating that indicates roofing materials are able to withstand moderate exposure to fire originating from sources outside the building.

Class "C": Fire-resistance rating that indicates roofing materials are able to withstand light exposure to fire originating from sources outside the building.

[J.P.M.]

Just got word from my installer that there is an issue with obtaining a permit for my PV installation because, as of Jan 1, 2014, my city (Irvine, CA) is requiring all solar panels to have a Class A fire rating. My installer says that such panels are very rare. They said that other cities have adopted the same change so permits are being held up for others as well. Anyone else run into this? If so any thoughts on how this is going to play out? Will I have to change panels? I'm guessing that if the class A panels are that rare, they are also going to be more $$

If this is the real deal, it could be a PITA.

[silversaver]

UL1703

For example, Kyocera, LG..etc only class C UL1703C

Most of panel manufactures have UL1703 certified, but not A

[inetdog]

Just got word from my installer that there is an issue with obtaining a permit for my PV installation because, as of Jan 1, 2014, my city (Irvine, CA) is requiring all solar panels to have a Class A fire rating. My installer says that such panels are very rare. They said that other cities have adopted the same change so permits are being held up for others as well. Anyone else run into this? If so any thoughts on how this is going to play out? Will I have to change panels? I'm guessing that if the class A panels are that rare, they are also going to be more $$

If they are not also requiring all roofing to be Class A, they will have a hard time justifying this ordinance as reasonable if it is contested.
Has the city actually gone through the formal process of amending their building code?

[Naptown]

My understanding of this is once you put a collector on a class A roof the roof becomes class C.
In reality there is not much to burn in a PV collector.
A plastic pool collector is another story

[SunEagle]

......

I just realized I responded to this post about PV panel fire rating instead of the post that Sunking put up concerning the new 2014 NEC code requirement for system shutdown. My bad.

[OvertheSun]

Fire rating info from another site - Class A rated panels

From: http://www.homepower.com/articles/so...tions/page/0/1

Frameless & Glass-on-Glass Modules
The 2012 International Building Code, while still not yet widely adopted in the United States, requires that rooftop rack-mounted PV systems have the same fire classification as required of the roof assembly—Class A, B, or C depending on the building type and location. Class A roofing materials or assemblies have a greater ability to resist fire spreading and to resist burning embers. While residential roofs have not generally been required to be Class A, some areas with high fire hazards are moving in that direction for new construction or significant reroofing projects. For example, Colorado Springs, Colorado, and many cities in California have local agency ordinance requirements for residential Class A roofs. Some roofing materials are considered Class A, like slate, clay, concrete roof tiles, and steel, although they must be installed correctly (for example, eliminating gaps between the roof covering and decking where birds could build nests) to earn this rating. Class A fiberglass-reinforced asphalt composition shingles are also available, while other types of asphalt or wood shingles will typically have a lower Class B or C rating.

Most glass-front, plastic-backed modules have a Class C fire rating, but modules with glass on both sides may meet higher Class A rating requirements. Trina’s TSM PDG5 and Silicon Energy’s Cascade Series are both fire Class A-certified, glass-front and glass-backed modules.

Besides their improved fire resistance rating, some glass-on-glass modules have the benefit of allowing dappled light to pass through for structurally integrated arrays like patio or walkway covers. Looking up at the back of a module that is letting light into an atrium and seeing the PV cells instead of an opaque plastic backsheet is considered by many people an aesthetic improvement and architecturally interesting. Another advantage of glass-on-glass modules is superior protection for the back of the module as compared to plastic, and enhanced resistance to sheer stresses.

Frameless versions of glass-on-glass modules are available (including many thin-film modules) that have no metal frames to ground, so the labor and material costs of grounding module frames to racking are eliminated. (Note that the rails still have to be grounded.)

[ocdave]

If they are not also requiring all roofing to be Class A, they will have a hard time justifying this ordinance as reasonable if it is contested.
Has the city actually gone through the formal process of amending their building code?

That's just it. It seems that the building code has been updated as of the new year to state that roof-mounted PV panels must have the same fire rating as the roof itself...which is class A. My installed will not even provide a guesstimate as to when this might be resolved. Ugh!

[SunEagle]

Does anyone know if this new fire rating on the panels a building code for only California or all states?

[OvertheSun]

Does anyone know if this new fire rating on the panels a building code for only California or all states?

This is partly a California amendment to model building code (the requirement that PV panels meet certain fire ratings). But the higher standard for class A rating is local and reflects the higher standards for roof structures in fire prone areas.

2103 CA code (effective 1-1-14) added a new subsection 1505.9 stating that: rooftop mounted photovoltaic systems shall be tested, listed and identified with a fire classification in accordance with UL 1703. The fire classification shall comply with Table 1505.1 based on the type of construction of the building.

Table 1505.1 lists various building types and a corresponding minimum roofing fire class rating. All the fire class ratings are B and C. There are several other provisions that require a higher roof fire rating of class A in very high fire severity zones, but only if more than 50% of the roof of an existing building is replaced or in new construction. It isn't clear whether the higher rating would apply to PV systems installed on class A roofs because the PV provision only refers to Table 1505.1, which doesn't list class A as required on any building type.

I think an argument could be made that the intent of the roof fire rating is to prevent burn through to the underlying structure and that a class A roof would serve that purpose even if a class C PV system was installed on top of it - like a fire wall. A code interpretation on this issue could be requested from the state fire marshall. Maybe I'll do that.

That being said, local cities and counties can adopt more stringent requirements than the state, and many around here have done so, at least as applied to previous versions of the building code. I personally thought this was a long time coming since a lot of the houses that burned to the ground in the 2004 and 2007 fires in SD county had wood shake roofs - in the Oakland and other fires, too. Still, the codes didn't require anyone to replace an otherwise intact shake roof with class A.

How this plays out with respect to PV installations, I think, depends on how the local ordinances are amended to be more restrictive. There is no requirement as to how restrictive amendments need to be phrased. In previous code adoptions, some have just amended Table 1505.1 to specify that all roofs on all building types are class A (not a comprehensive analysis). Others have made amendments to the text of the code. If the local ordinance leaves Table 1505.1 intact, then I think PV should be ok (class C or B). But of course the local amendments could also change the language of sec. 1505.9 to directly affect PV systems, or just state that the PV panels have to have the same rating as the roof and the roof has to be A. This may be what happened in Irvine, but it could also be a different amendment that the local building permit department or code enforcement is over-interpreting.

What is the roof in Irvine made of?

[ocdave]

This is partly a California amendment to model building code (the requirement that PV panels meet certain fire ratings). But the higher standard for class A rating is local and reflects the higher standards for roof structures in fire prone areas.

2103 CA code (effective 1-1-14) added a new subsection 1505.9 stating that: rooftop mounted photovoltaic systems shall be tested, listed and identified with a fire classification in accordance with UL 1703. The fire classification shall comply with Table 1505.1 based on the type of construction of the building.

Table 1505.1 lists various building types and a corresponding minimum roofing fire class rating. All the fire class ratings are B and C. There are several other provisions that require a higher roof fire rating of class A in very high fire severity zones, but only if more than 50% of the roof of an existing building is replaced or in new construction. It isn't clear whether the higher rating would apply to PV systems installed on class A roofs because the PV provision only refers to Table 1505.1, which doesn't list class A as required on any building type.

I think an argument could be made that the intent of the roof fire rating is to prevent burn through to the underlying structure and that a class A roof would serve that purpose even if a class C PV system was installed on top of it - like a fire wall. A code interpretation on this issue could be requested from the state fire marshall. Maybe I'll do that.

That being said, local cities and counties can adopt more stringent requirements than the state, and many around here have done so, at least as applied to previous versions of the building code. I personally thought this was a long time coming since a lot of the houses that burned to the ground in the 2004 and 2007 fires in SD county had wood shake roofs - in the Oakland and other fires, too. Still, the codes didn't require anyone to replace an otherwise intact shake roof with class A.

How this plays out with respect to PV installations, I think, depends on how the local ordinances are amended to be more restrictive. There is no requirement as to how restrictive amendments need to be phrased. In previous code adoptions, some have just amended Table 1505.1 to specify that all roofs on all building types are class A (not a comprehensive analysis). Others have made amendments to the text of the code. If the local ordinance leaves Table 1505.1 intact, then I think PV should be ok (class C or B). But of course the local amendments could also change the language of sec. 1505.9 to directly affect PV systems, or just state that the PV panels have to have the same rating as the roof and the roof has to be A. This may be what happened in Irvine, but it could also be a different amendment that the local building permit department or code enforcement is over-interpreting.

What is the roof in Irvine made of?

OvertheSun,
Thanks for the info. Haven't been able to get any details out of my installer as to what is going on.

My roof is concrete tile and as I understand it, Irvine requires Class A roofing. However I did some internet research and it sounds like the experts are saying that just requiring PV panels to be the same rating as the roofing material is not sufficient and that the rating needs to be determined at the PV "system" level. I saw something about the testing standard for UL1703 being modified in 2013 for stand-off mounted roof PV installations to account for this. However, its hard for me to tell when any of these changes will or have gone into effect.

[FUN4ME]

I am not sure if you have seen this or not.
I don't even know if it will help.
I only read the summary but it looks to me that their recommendation is more testing should be done before changing codes

http://www.solarabcs.org/about/publications/reports/flammability-testing/index.html

[J.P.M.]

I am not sure if you have seen this or not.
I don't even know if it will help.
I only read the summary but it looks to me that their recommendation is more testing should be done before changing codes

http://www.solarabcs.org/about/publi...ing/index.html

Looks like a pro solar group to me. "Consultants" trying to generate business. I seem to remember Larry Sherwood from my ASES days.

[OvertheSun]

OvertheSun,
Thanks for the info. Haven't been able to get any details out of my installer as to what is going on.

My roof is concrete tile and as I understand it, Irvine requires Class A roofing. However I did some internet research and it sounds like the experts are saying that just requiring PV panels to be the same rating as the roofing material is not sufficient and that the rating needs to be determined at the PV "system" level. I saw something about the testing standard for UL1703 being modified in 2013 for stand-off mounted roof PV installations to account for this. However, its hard for me to tell when any of these changes will or have gone into effect.

As I mentioned before, I don't believe that the state code requires class A for PV systems. I'm sorry if I implied that it was just the panels, becuase the code does refer to "PV systems." But the panels are the starting point. I've looked on the internet a bit, too, and it seems that the overall system rating depends on following the manufacturers guidelines for panel installation and it seems that the fire rating may be dependent on following those guidelines.

In any case, the CA code doesn't link the PV system fire rating to the roof rating, per se. Instead, they are both linked to the type of construction used in the building.

So even if you installed a class A roof (because you like concrete tile better than cedar shake, for example), I don't believe the CA code would necessitate that you also install class A PV system. The requirement is based on what type of building construction is used in the house, and it doesn't require class A. The fire ratings are given in the following table:

TABLE 1505.1
MINIMUM ROOF COVERING
CLASSIFICATION FOR TYPES OF CONSTRUCTION
IA IB IIA IIB IIIA IIIB IV VA VB
B B B C B C B B C

This is taken together with new subsection 1505.9:
1505.9 Photovoltaic panels and modules. Rooftop mounted photovoltaic systems shall be tested, listed and identified with a fire classification in accordance with UL 1703. The fire classification shall comply with Table 1505.1 based on the type of construction of the building.

So if you have type IIB construction, then you only need to have class C rated PV system to satisfy the state code even if you voluntarily have a class A type roof.

But local cites and counties can, and have in many cases in fire prone areas, required higher fire rating for roofing. I did some digging and Irvine did this before with respect to roofing, after all the wildfires. They just followed their previous pattern in adopting the 2013 CA code on October 22, 2013 by amending TABLE 1505.1 as follows:

TABLE 1505.1
MINIMUM ROOF COVERING
CLASSIFICATION FOR TYPES OF CONSTRUCTION
IA IB IIA IIB IIIA IIIB IV VA VB
A A A A A A A A A

The procedure the Irvine city council followed was to adopt the entire CA building code but amend certain sections to be more restrictive, as they had done before. The changes to Table 1505.1 are substantially the only changes to the entirety of Chapter 15. The effect is that section 1505.9 from the CA code (adopted without amendment), which relates to PV systems, now refers to Irvine-amended table 1505.1, which requires Class A fire rating for all building types and therefore sweeps PV systems in under class A rating, too. I'm going to try to attach the amendment, and proposal to adopt. You can also download from the following link by scrolling down to the setion in the meeting agenda

http://www.irvinequickrecords.org/sirepub/mobilemtgviewer.aspx?meetid=4506&doctype=AGENDA#

I'm not sure the City Council thought this through. In fact, I'm pretty sure they didn't because they voted on this item on consent and the amendments were prepared by staff. Consent is usually reserved for administerial types of actions that are thought to be non-controversial and don't require much if any discussion. I've also attached the Power Point presentation from the meeting, which is probably all the council members considered when voting on these amendments. They all probably just thought they had previously required class A roofs, so go with that now, too. Didn't even consider the implications for PV systems.

Eventually, the PV makers will probably work this out because the code will force them to adapt their equipment to class A fire rating in high fire hazard regions like Southern California, which is also prime solar country. But that doesn't do you much good right now. In the meantime, it might be necessary to seek out an exception or delay in implementing the PV provisions in Irvine if no PV equipment out there satisfies the requirement. Or switch to the equipment that is class A rated.

If you want to be an activist about this, you could contact the city council and alert them to the implications for solar in Irvine. They seem to be pretty pro-solar, so maybe they would consider a resolution to delay implementation of section 1505.9. The best way would be to see if you can get on the agenda for one of their meetings and make a presentation. Otherwise,you can just go to a meeting and sign up to speak. You probably would be limited to 2 minutes or less. At least it would put it on the record. I'm kinda surprised that someone in the solar industry or a pro-solar organization didn't pick up on this at the state level during the code adoption process.

Now I'm going to check out what San Diego County is doing.......