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
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.......
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
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.......
IMO, Nicely and professionally done ! Bet this will push some buttons. I intend to read this several times.
Comment