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Are You Ready For Solar?

The legal and regulatory framework in Philadelphia provides a foundation for building a sustainable solar infrastructure. Local rules and regulations help reduce installation costs and significantly improve the market environment for solar energy technologies.

Now that you’ve determined whether solar is right for you, this section describes the solar installation process and discusses the applicable codes and regulations that require implementation for a successful installation. Philadelphia, in conjunction with the Commonwealth, has reviewed its rules and regulations to streamline and improve the process for residential and small commercial installations. This section also describes when a streamlined process may be allowed for electrical and building permits, and outlines the steps contractors must follow for a ―Streamlined Permit‖ and a "Standard Permit."

Solar Installation Process Overview
Figure 4.1 presents a process diagram that identifies the six key steps for the implementation of a solar project. (Note that these are steps that will occur after a property has been thoroughly assessed by a qualified solar contractor and has been identified as a feasible site for a solar PV system. For additional details, see Sections 2 and 3 of this guidebook.) Each step is briefly described below:

  • Step 1. Assembling the Project Team. In order to procure all the necessary permits and approval applications that are required to implement a PV system, a property owner will need to contract with a Pennsylvania Approved Solar Contractor and a licensed Philadelphia Electrical Contractor. Property owners will usually contract with an approved Solar Installer who also provides or subcontracts the licensed electrical contractor.
  • Step 2. Preparation of Design Plan. In this step, the solar contractor prepares a design plan that is specific to the building structure and that meets the energy requirements of the property. The plan should include the safe and orderly handover of the unit from the constructor to the owner, guaranteeing its operability in terms of performance, reliability, safety and information traceability as mentioned in Section 3.6 of this guidebook, System Commissioning. This plan must meet all applicable codes and regulations as further presented in this section of the guidebook.

    During the design phase, the contractor should review and understand PECO requirements to ensure compliance with their interconnection policy. (See Table 4.1 for a summary of potential scenarios that may cause complications with a PECO interconnection.)
  • Step 3. Application Submittals. For residential and small commercial systems, the solar and electrical contractors prepare applications that must be submitted to:
    • - The Philadelphia Department of Licenses and Inspections (L&I) for electrical and building permits. (Note: The contractor should verify zoning permit applicability, as in some cases, a zoning permit may also be required. See Section 4.4 for details.)

      - PECO to assure that capacity is available in the local electrical network and solar installation can be connected to the electrical grid.

      If the project meets certain criteria, it may be possible to have a streamlined review for electrical and building permits. See section 4.4 City of Philadelphia Requirements for details.

      If pursuing a rebate through the Pennsylvania Department of Environmental Protection’s (PA DEP’s) Solar Sunshine Program, the solar/electrical contractor prepares applications that must be submitted to the Program.

  • Step 4. Application Review. Each agency reviews the applications that are submitted, assesses the appropriate fees, and issues a permit or approval. Projects that are eligible for a streamlined review by L&I will take less time than a standard review. Once all the permits/approvals have been obtained, installation can begin.
  • Step 5. Inspection and Meter Installation. The solar contractor arranges for:
    • - building inspection,

      - electrical inspection (through an L&I approved 3rd party electrical inspector), PECO meter installation, and,

      - [If pursuing a rebate and randomly selected], inspection by the State Solar Sunshine Program’s 3rd party inspectors.

  • Step 6. Placing Solar Unit in Operation. Before a PV system can be placed in operation it must pass all inspections and receive documentation indicating such:
    • - L&I’s 3rd party electrical inspector will provide a Third Party Electrical Inspection Certificate of Approval.

      - PECO will provide a Certificate of Completion to the contractor/system owner. Copies of these signed and completed approvals should be provided to the PA DEP Solar Sunshine Program (if applying for a rebate), PECO, the Property Owner and L&I as necessary.

(Note: The contractor should submit to PECO the Interconnection Application/Agreement - Part 2 in addition to L&I’s Third Party Electrical Inspection Certificate of Approval. PECO may opt to conduct an inspection, which would include a witness test to assure that the inverter will disconnect form the grid if there is a grid outage. However, PECO may waive this test and approve the system. If the submitted Part 2 – Interconnection form is not challenged by PECO after 10 business days, the witness test is automatically waived and the system is approved for operation.)

Finally, PECO will replace the existing utility meter (IN meter) and install the utility meter (OUT meter). The Contractor should perform the final system commissioning steps and train the property owner on operating and maintaining the system. (See Section 4.3 PECO Coordination for details.)

The following sections explain the permitting and approval process that all solar installations must follow with the City of Philadelphia’s Licensing and Inspection (L&I) Department.

Licensing and Codes Requirements

[Note: Pennsylvania and Philadelphia Electrical Codes are incorporated within the UCCCP and are based on the NEC, with some differing or additional requirements particular for Philadelphia. While there is a specific section (Article 690) of the NEC that is dedicated to PV systems, the majority of the remainder of the NEC is also applicable to PV systems.]

The Commonwealth (through the PA DEP Solar Sunshine Program) develops and maintains the Approved List of Solar Contractors for projects that pursue rebates through the program. (Even if a project does not pursue a rebate, it is highly recommended to use a contractor from this List because it provides some level of assurance to a property owner that the contractor has met certain eligibility requirements and has had proper training and/or certification.).

The Solar Contractor applies for building permits. As part of the building permit application, the City requires the solar contractor to provide evidence that they are on the Approved List and registered with the Attorney General’s Office. (Note: Pennsylvania law requires that all Contractors who perform at least $5,000 worth of home improvements per year are registered with the Pennsylvania Attorney General’s Office.)

The project electrician must be a licensed City of Philadelphia electrician and is responsible for obtaining the electrical permit.

In addition to applying for City permits, the Solar Contractor must also submit an application to PECO for connection approval and meter installations. If pursuing a rebate, the Solar Contractor must also submit an application to the PA DEP Solar Sunshine Program.

PECO Interconnection

It is important that Solar Contractors understand PECO’s interconnection requirements BEFORE the design is finalized. This understanding is essential to ensure that the electric lines serving the home or building can accommodate a customer-sited generating unit. An application must be submitted to PECO before they can identify any potential site limitations for interconnection. Contractors are encouraged to review PECO’s Yellow Book for small generators rated at 50 kW or less [the Yellow Book is a condensed version of the requirements contained in the procedures for 2 million volt amps(MVA) or less].

Even if the system is never anticipated to export power to the grid, PECO must be aware of and understand potential faults in the system that may impact their lines and determine if their lines have enough capacity to accommodate the net flow of energy from a PV system. Failing to coordinate with PECO before the design is finalized may result in additional work or additional costs (if equipment has already been purchased).

There are scenarios seen in an interconnection review that, per The Pennsylvania Code may limit a lot’s ability to have a small generator facility (such as a solar PV system) or that may require upgrades to the electric lines serving the building at the customer’s expense. Some of these scenarios are presented in Table 4.1. (Note: The Pennsylvania Code is an official publication of the Commonwealth of Pennsylvania that contains regulations and other documents filed with the Legislative Reference Bureau including Pennsylvania Interconnection Standards. There are 4 levels of interconnection review per the PA Code. For more information about Levels 1 through 4, see 052 The Pennsylvania Code § 75.34 through § 75.40.15)

4.3.1 General PECO Requirements16
  • Inverters must meet IEEE1547/UL1741 standards or equivalent—these are U.S. solar industry accepted standards
  • The system shall include a visible break disconnect switch on the inverter AC output, which can be locked in the open position. The switch shall be located outdoors, next to the PECO ―IN‖ and ―OUT‖ meters (see meter descriptions below). This disconnect switch may be installed in a different location on the property, provided a placard is mounted at the PECO meters indicating the location of the switch. The switch location is negotiable with PECO for institutional, commercial, and industrial installations where service is provided by a dedicated PECO pad mounted transformer or by customer owned primary service equipment. The switch may be installed indoors for installations with indoor PECO meters. Consult your engineer for locations and be sure to include the locations on the site plans that you submit to the City for permits.
  • An interconnection customer may elect to provide PECO access to an isolation device that is contained in a building or area that may be unoccupied and locked or not otherwise readily accessible to PECO, by providing a key in a lockbox installed by PECO that shall provide ready access to the isolation device. The interconnection customer shall permit PECO to install the lockbox in a location that is readily accessible by PECO and the interconnection customer shall permit PECO to affix a placard in a location of its choosing that provides clear instructions PECO operating personnel on access to the isolation device.
  • PECO requires the installation of a second meter at the service address to record excess energy being exported to the grid (OUT meter) if the customer wants to receive billing credit through net metering. However, if there is no expectation of any excess energy being exported, PECO needs to be aware of this at the time of the interconnection application, as PECO may not require the out meter.
  • PECO will install a detented OUT meter and detent the IN meter (prevent the IN meter from recording the flow of electricity back to the grid) when the following has been completed:
    - Contractor has completed the meter installation second or OUT meter socket meter installation. (Note: PECO will reimburse the customer the cost of installing the OUT meter socket in order to comply with the net metering regulation. This is a fixed agreed cost of $400, which should be invoiced to PECO at the time the Part 2 – Interconnection Completion Form is submitted). Reimbursement will only be given to the customer and not to the installer.

    - The system has been inspected by an L&I third party electrical inspector, and
    - PECO has received the ―L&I Third Party Electrical Inspection Certificate‖ (sent to the appropriate PECO New Business Office)

  • Contractor must download a ―PECO Certificate of Completion‖ form from PECO’s Net Metering website. This form must be completed and submitted to PECO with proper signatures after the customer’s PV system and PECO’s meter have been installed.
  • Witness Testing: After PECO receives the completed PECO Certificate of Completion, systems rated greater than 50 kW shall be required to perform a ―witness test‖ to prove the UL1741 listed inverter’s IEEE 1547 over/under voltage and frequency and anti-islanding protection are operating properly. The witness test will require the contractor to monitor the AC inverter output and simultaneously disconnect all inverters from the grid, using the inverter AC disconnect switch. A recording transient power disturbance analyzer shall be used to capture the inverter AC voltage wave forms to prove that the inverters shut down within the required 10 cycles (.167 seconds).
  • After waiving or witnessing a successful ―witness test, "the PECO Certificate of Completion" shall be signed by PECO and returned to the customer when the customer’s PECO account has been properly set up for Net Metering.

City of Philadelphia Requirements

The Philadelphia Department of Licenses and Inspections (L&I) evaluates the need for zoning and grants zoning, electrical and building permitting for PV systems.

Electrical and building permits are required in all installations. For projects that are less than 10 kW and meet certain criteria, a streamlined combination permit for solar PV Installations is an option (See Exhibit C-3, the Streamlined Standards for 1&2 Family Dwellings Solar PV Installations Bulletin). This streamlined combination permit can be granted with a single visit to the electrical permits counter if all application materials are present and correct. Larger projects and projects that do not meet the requirements for streamlined combination permit will have to move through the standard process for both building and electrical permits. The need for zoning permits will be decided upon review (see Section 4.4.2.2 Zoning Requirements for more details) but rooftop solar installations will not require a Zoning permit. Fire Department safety requirements that enable safe emergency response need to be incorporated into the design. The requirements for each permit are discussed separately in this guidebook.

To facilitate the preparation of the various L&I permit applications, this guidebook contains checklists, process flow diagrams and worksheets summarizing the requirements for electrical, building and zoning permits (see Appendices C, D and E, respectively).

Electrical Permit

  • Electrical Permits are required for all PV installations and must be obtained by a Philadelphia licensed electrical contractor. A streamlined combination permit is available for solar installations that meet all of the criteria listed in Exhibit C-3, the Streamlined Standard for 1 & 2 Family Dwellings Solar PV System Installations Bulletin. This streamlined combination permit can be obtained at the electrical permits counter and a visit to the building permits counter can be avoided. If a project does not meet all of the structural related conditions and installation limitations in the streamlined standard bulletin (Exhibit C-3), the usual standard building permit review will be necessary. Once that building permit is obtained and the project meets all of the electrical limitations listed in the bulletin, the electrical permit portion could still turnaround the same day. Note that the building permit would have to be obtained prior to applying for the streamlined electrical.
  • To prevent multiple trips to the office of L&I, it is highly recommended that a licensed electrician reviews the plans thoroughly before submitting the application. It is also recommended that the electrician is present at the review. In this way, the electrician will understand any non-compliance issue and be able to amend the application quickly and correctly.
  • For all other projects that don’t meet the streamlined criteria, a Standard Electrical Permit will require up to 20 business days, but there are options that include additional fees to expedite. In a standard permit situation, it is wise to apply for both the building and electrical permits simultaneously. Refer to Exhibit C-1 through C-3 for information about this Streamlined Process for Solar PV.

Appendix C contains the following information to assist the electrical permit process:

  • Electrical Permit Flow Diagram (Streamlined and Standard Permit)
  • Electrical Permit Checklist (includes all the documentation that must be submitted to L&I)
  • Bulletin detailing the Streamlined Standards for Solar PV System Installations
  • Sample Site Plan (required for submittal)
  • Standard Electrical Diagram (required for submittal)
  • Notes for Electrical Diagram (required for submittal)

Building Permit
L&I receives applications for building permits for PV installations. Within the review for building permits, zoning and fire requirements are evaluated. The following three subsections discuss these three requirements.

Building Requirements
Building Permits are required for PV installations. Permitting for the building portion of the installation is regulated by the Philadelphia Building Construction and Occupancy Code (BCOC).

If a project meets the criteria listed in Exhibit C-3, then only a visit to the electrical permit counter is needed. A Streamlined Permit can be granted within 1 to 3 business days. If the project does not meet all of the criteria listed on the bulletin in Exhibit C-3, a standard permit is required.

A Standard Permit will require a full plan review and will require 20 to 25 business days. A Standard Permit will also require additional calculations to be submitted for review.

Appendix D contains the following information to assist the building permit process:

  • Building Permit Flow Diagram (Streamlined and Standard Permit)
  • Building Permit Checklist (includes all the documentation that must be submitted to L&I)
  • Structural Submittal for Streamlined Permit
  • Structure Worksheet WKS1

Zoning Requirements
Presently solar installations are allowed in all zones within the City; rooftop systems will not need a zoning permit. However, ground-mounted PV installations may need to obtain a zoning permit. See Appendix E for the Zoning Permit Checklist for ground mounted PV systems. Ground mounted PV systems should comply with the setbacks required in the property base zoning designation as noted in The Philadelphia Code.

If during the building permit review, a PV project triggers a zoning review or is in conflict with the zoning code, then L&I will review the permit application, determine that the limitations are exceeded, issue a refusal, and advise the contractor to obtain a zoning variance. The contractor must then apply for a zoning variance from the Zoning Board of Adjustment (ZBA). A ZBA review includes a public hearing and may range in time from several weeks to several months. Zoning restructuring is currently underway, but won’t be finalized soon. If you would like further direction on zoning your ground mounted system, contact the Program Director for Renewable Projects listed on the Mayor’s Office of Sustainability webpage.

Fire Department Requirements
The Fire Department does not require permits. However, L&I provides comments on PV systems related to the ability of the fire department to respond to emergencies safely as part of the building permit review. PV systems shall meet the following fire department requirements:

  • Provide four (4) foot clearance around fire department connections.
  • Provide three (3) foot clearance around other roof top equipment.