For Your Comment: Solar Systems

Author: Phil Trubey

Date: December 07, 2019

The Association promulgated two proposed Regulatory code updates at the 12/5/19 Board meeting. One about roofs, and this one concerning Solar Systems (click to read). Both proposed amendments were accepted by the Board on 7-0 votes and we are now in the 30 day comment period. This article discusses the Solar System amendment and provides comments. You can submit your own comments directly to the Board at memberinput@rsfassociation.org. 

Background

Starting in a few weeks, on January 1st, 2020, California is mandating that all new homes be constructed with PV Solar systems. This mandate was passed by the legislature in early 2018 and specifications were made available in the fall of 2018.

While the Association has had design guidelines for Solar PV systems, they have never had a Regulatory Code section about them. This amendment would add a new regulation on Solar Energy Systems.

The proposed new code section is three pages long, and is linked to above, so I'll dive right into my comments about it.

Massive New Requirement Far in Excess of CA Mandate

"§_ .0402 On new residential construction, a solar energy system shall be of sufficient size to net out the annual kilowatt hour energy usage of the dwelling. (Effective January 1, 2020)."

This is a huge mandate and far in excess of what the new CA law mandates. This article explains the new law and what it mandates. At the very bottom of the article in the Appendix it shows the formula that architects and builders can use to comply with the new CA law. It is a simple formula based on conditioned square footage and what climate zone you are in. Here's a calculator for the same formula. 

Let's do an example of my own home since I know what my annual kilowatt hour electricity energy usage is (I'm ignoring that the Association mandate as written includes all other forms of energy use such as natural gas furnaces). Using the CA mandate calculator, it says I would need an 8.59 kW system for my 13,000 sq ft home, or 6.44 kW if I used storage batteries (there are also other exceptions and carve outs in the CA law with regard to PV solar sizing).

But that wouldn't generate anywhere near my annual kilowatt hour electricity energy usage. To equal my actual usage, I would need an approximately 44 kW array, or over five times as big as what CA law mandates (the top picture shows how big a 44 kW array is). Such a system would be at least 126 panels big (using the expensive high output 350 watt panels), assuming they were perfectly positioned due south at the correct sun angle. Such a system would never fit on a roof and would require, in my case, clear cutting a forest down to allow for sun access.

The CA mandated system size, however, is quite manageable.

Moreover, how does the Association plan on mandating PV system size based on unknown future energy usage? 

I suspect the Association proposed change is simply a summary of what the actual CA law purports to say. However, the law and its associated technical specifications, is very complex and was negotiated between the building industry and politicians such that it would add about $10,000 to the cost of an average home. It was never meant to net out yearly energy usage because that would have been too big a burden on the home building industry. But anything is possible and maybe this is actually what the Association wants, in which case, yipes! 

This section is simply unworkable, is a huge cost mandate, and has a large negative impact on site usage and should be removed. The actual CA PV mandate is regulated via a county building permit.

Why Are We (Incorrectly) Duplicating CA Law?

§_ .0201 All new residential property construction governed by the Rancho Santa Fe Protective Covenant is required to have a solar energy system. (Effective January 1, 2020).

Why is this subsection even being proposed for our Regulatory Code? The reason I ask is that CA law is now mandating PV Solar for new construction, so why do we have to mandate it? There are plenty of CA and County laws regarding building that we stay silent on: Earthquake strapping, the NEC electrical code, the County's new storm water measures that force homeowners to build big catch basins, the list goes on and on. Builders and architects are well aware of what the building codes are, there is no need to replicate mandates here, and make a hash of it while doing so. Is this a me too thing? Burnishing our green credentials? It's redundant, and not consistent as many other rules and regulations, some much more important than the solar mandate, are not similarly duplicated in our Regulatory Code.

Incorrect Definition

"§_.0103 “Solar water heating units” concentrate the suns energy using reflective devices such as troughs or mirror panels to produce heat that is used to generate electricity."

Correction needed here. This sentence is incorrect. The heat is not used to generate electricity, it is used to directly heat water for either household or pool use.

Conclusion

I'll leave it to the rest of the membership to read the other provisions, which mainly have to do with aesthetics. 

If you are planning on installing a PV Solar system, I'd recommend you review it and provide your comments to memberinput@rsfassociation.org