SIMPLIFYING RESIDENTIAL SOLAR PERMITTING

SIMPLIFYING RESIDENTIAL SOLAR PERMITTING: Cutting a Local Cost Culprit 1

SIMPLIFYING RESIDENTIAL SOLAR PERMITTINGCutting a Local Cost Culprit

WRITTEN BY MONIKA DARWISH


The local permitting process accounts for a significant

portion of the cost of going solar today. Long waits, high

fees, excessive inspections, avoidable paperwork and non-

standard practices across different jurisdictions can all add

unnecessary costs to what should be a simple, transparent

process. By streamlining these processes, local governments

in Los Angeles County can make it easier and more cost-

effective for residents to invest in solar power.

SOFT COSTS AND CURRENT PERMITTING LANDSCAPE

In the past decade, the solar industry has achieved significant

cost reductions that have expanded access to rooftop solar

photovoltaics (PV). The cost of hardware (the PV modules,

racking system, inverters, and other balance-of-system costs)

fell $2.60 per watt from 2008 to 2012.1

In 2013, the State of California added over 2,600 megawatts

(MW) of solar PV; 2,300 MW from wholesale solar PV, and

300 MW from self-generation PV. Solar PV programs, codified

by Senate Bill 1 in 2006 (SB 1, Murray, Chapter 132), which set

a target for 3,000 MW of self-generation solar, are driving

much of the self-generation installation in California.2 Since

the start of the California Solar Initiative (see sidebar at right)

in 2007, the overall cost of a residential PV installation has

fallen from an average of $10.97 per watt CEC-AC to $5.49

per watt CEC-AC. These cost reductions have made it possible

for more Californians to lower their energy bills through clean,

renewable, solar energy. In fact, solar has become so much

more affordable that, in California today, low- and middle-

income consumers constitute over 70 percent of Californians

taking advantage of residential rooftop solar.3

However, to truly bring solar energy to scale and achieve the

goals of SB1, we need to continue to lower costs and remove

barriers to market participation. Given the dramatic drop in

balance of system costs, non-hardware “soft costs” (customer

marketing and acquisition, labor, overhead, and permitting)

represent an area where public policy can encourage continued

cost reductions and increased consumer solar adoption.

Recent analysis shows that in some cases soft costs account

for up to 64 percent of the total system price.4 The National

Renewable Energy Laboratory’s Tracking the Sun report found

that soft costs represent the most significant opportunity for

continued price reduction. Within the soft costs category,

Vote Solar and the Sierra Club have identified rooftop-solar

permitting as the cost culprit that can most effectively be

reduced through direct government intervention.

Unfortunately, the solar-permitting landscape today is

inefficient, as permitting requirements and costs vary

significantly across municipalities, referred to henceforth as

Authorities Having Jurisdiction (AHJs). Over 18,000 AHJs

across the U.S. have established unique solar-permitting

requirements. These nonstandardized processes can add up

to 3.5 weeks of delay to residential solar-project construction

timelines. In fact, a 2012 survey of residential installers

spanning 12 states and representing 90 percent of the

residential solar market found that more than 1 in 3 installers

avoid selling in an average of 3.5 jurisdictions because of

associated permitting difficulties.5

Cutting red tape through standardized permitting, zoning,

metering, and interconnection processes can save an estimated

$0.24 per watt (or between $1,000 to $2,000) off the total cost

of a residential solar energy system, while boosting installer

competition by eliminating inconsistencies and creating a more

time-efficient process. The problem is significant enough that

streamlining permitting processes could boost solar market

growth by over 13 percent, generate 2,000 new jobs, and result

in $5.1 billion of net economic gain in California by 2020.

LOS ANGELES COUNTY: PERMITTING REPORT CARD

Los Angeles has tremendous rooftop solar potential. It is

estimated that over 5,536 MW worth of electricity from

Rooftop Solar Takes Off in CaliforniaCalifornia is the largest rooftop solar market in the

nation. Solar panels are installed on over 200,000

homes, businesses, and schools. The state’s massive

rooftop solar portfolio is to the result of ambitious

policy goals.

In 2010, Governor Jerry Brown launched a Clean

Energy Jobs Plan to realize the tremendous economic

benefits that accompany clean energy development.

A major portion of this plan, which is the nation’s most

aggressive, is dedicated to achieving 12,000 MW of

distributed generation, primarily through rooftop solar,

by 2020.

The rooftop solar boom in California has brought

tremendous social benefits to the broader public.

Since 2007, rooftop solar has helped create over

43,000 jobs in the solar industry, $10 billion dollars

in private investment, and the construction of 2,000

MW of clean energy (enough to power 19,877 homes,

businesses, non-profits, and government agencies

statewide) (Wise, 2013), the equivalent of four large

natural gas peaker plants. (CPUC Report)


464,325 rooftop solar sites, of which 70 percent are single-

family homes, could be installed. Now is the time to streamline

the solar-permitting landscape in the county to help AHJs

prepare for what will be a massive solar influx in the near term.

To aid communities in designing effective and efficient solar-

permitting processes, the Interstate Renewable Energy Council,

Inc. (IREC) and Vote Solar have identified nine Residential

Solar Permitting Best Practices. In this report, Vote Solar and

the Sierra Club grade Los Angeles County on six of the best

practices, based on available data from Project Permit. The

Project Permit website (www.projectpermit.org) incorporates

data on current permitting practices from Clean Power

Finance’s (CPF) National Solar Permitting Database (www.

solarpermit.org), and scores municipalities on the nine solar

permitting best practices. Project Permit was developed in

2012 by Vote Solar and funded by the Department of Energy’s

SunShot grant program.

All AHJs require a building permit for residential solar PV

installations. However, some also require separate electrical

and fire permits, each of which can entail separate plan

check review and inspection processes. Presently, the Project

Permit scoring system focuses solely on the building permit

process and does not penalize cities for requiring separate fire

or electrical permits. These separate departmental permits

create redundancies that can result in higher fees and wait

times, which increase a homeowner’s overall cost to install

rooftop solar. We strongly discourage AHJs from requiring

multiple permits, and future reports may penalize cities for

this redundancy.

DATA COLLECTION PROCESS

When collecting data for the Project Permit database in the

cities of Los Angeles County, Sierra Club interns first did an

initial search of the building department websites to obtain

information about permit fees, application requirements, and

process. After this stage, the Sierra Club called each building

department to confirm relevant data. Officials were asked the

following questions regarding residential rooftop solar PV

installations:

• Is information on permit fees, application requirements,

and process posted on the city’s website?

• Can building permit proposals be submitted online?

• What is the turnaround time for each application?

• Is the permitting fee schedule a flat rate or based on the

installation? What is the rate? Can building permits exceed

$400?

• Is there a narrow inspection-appointment window (limited

to a maximum of two hours)?

• How many inspections are required? Are reviews limited to

validating the safe and efficient operation of a proposed

PV system?

Through our data collection process, two special cases arose

that warrant clarification. First, Los Angeles County processes

its permits out of several regional offices, which preside over

the region’s unincorporated areas. These offices were graded

separately and the data is presented in Table 2. The information

gathered presents practical inconsistencies between these

regional branches, despite the presence of countywide

guidelines. The expected turnaround times and inspection

protocol were the most frequent variants between these

offices, highlighting the need for a more-efficient standardized

County permitting process.

Second, although the City of Los Angeles receives a “Good”

grade, we recognize that the city is rapidly overhauling its

permitting system under Mayor Garcetti’s “Sunny Skies”

initiative. The city’s new permitting system, which we expect

to be implemented in the coming months, will dramatically

improve the speed and efficiency of solar installations in Los

Angeles. Though these changes are not included in this version

of the report, we applaud the city’s efforts. We believe the city’s

new process could serve as a national model for permitting.

PERMITTING BEST PRACTICES

The best practices can be grouped into two main categories:

the permit application process and the field inspection

process. Permitting best practices, described in more detail

below, include posting requirements online, enabling online

processing, offering a speedy turnaround time, assessing

reasonable permitting fees, and eliminating community-specific

license requirements. Field inspection best practices include

offering a narrow inspection appointment window and the

elimination of excessive inspections.

The following best practices descriptions are transcribed from

the IREC best practices report.

1. Requirements Posted Online

AHJs should have a website that offers a one-stop location

for residents, businesses, and installers to obtain all

necessary information on obtaining a solar permit in that

municipality or region. In particular, the website should

include a clear description of the requirements and process

for getting a solar permit, including any necessary forms,

and information on fees, approval time, and inspections. The

website could also contain checklists for the application and

inspection requirements for solar.

Making these resources easily accessible to solar installers

will reduce the number of questions that municipal staff have

to answer and will improve the efficiency of the permitting


process for all involved. In addition, it can help to increase

the quality of applications submitted, which in turn shortens

review time. It also decreases the frustrating back-and-forth

that installers and municipal staff may otherwise experience.

Providing these resources can be particularly helpful to

homeowners and to installers who are new to a specific

municipality. If an AHJ has unique or unusual requirements, or

has recently modified its process or requirements, the website

is a good way to inform stakeholders about these differences.

2. Online Processing

Submittal, review, and approval of solar permits should be

possible via email or a website, with no trips to the municipal

office required for most residential permits. Implementation

of this best practice could range from a simple email-based

solution to a fully online permitting system.

An online permitting system offers numerous streamlining

benefits for both installers and municipalities, which vary

depending on the sophistication of the system. Generally

speaking, when an application and supporting materials are

submitted online, municipal staff can immediately access

them and do not need to enter the information manually,

which saves staff time. Likewise, installers save time and

money by not having to submit paper copies or make extra

trips to the AH permitting department. In a more fully

online system, once the application has entered the system,

multiple personnel may work on reviewing the materials at

the same time and track the review progress and comments

made by different departments. If there is an online web

portal that records the path of a permit application through

the review process, then installers can follow the status

of their applications. With some systems, applicants can

also pay their permit fees online and the AHJ can keep

track of the revenue information automatically. While the

more sophisticated online permitting systems can require

significant upfront investment by an AHJ, their benefits are

also significant—for both municipalities and solar installers,

as well as other types of permit applicants.

Enabling online permit processing could be part of the

implementation of an expedited permit process. Similarly,

online permit processing could facilitate faster turnaround

for permits.

3. Rapid Turnaround Time

If clearly defined review requirements are met, the majority

of small residential PV systems can be processed quickly,

ideally over-the-counter or electronically, within one day. Such

expedited treatment can be accomplished in several ways,

including through prequalification for certain systems, plans,

or installers. The Expedited Permit Process for PV Systems,

from the Solar America Board for Codes and Standards (Solar

ABCs), which provides a framework for expedited review

for typical residential PV systems, has proven especially

popular and effective. Regardless of the method chosen, we

recommend that the permitting requirements, including the

permit form itself, be made consistent regionally and, to the

extent possible, statewide.

Expediting the process can save time and money for both

installers and municipalities. Installers receive their permits

2Any leftover energy flows into the grid to help power your neighborhood

3

4

For all the extra power generated during the day, you get a bill credit

At night, your house gets power from the grid and the cost is offset with your bill credits. Just like a cell phone bill, credits that you don’t use roll over month to month

WHAT ARENET METERING/SOLAR CREDITS?

1During the day, your solar panels produce energy to help power your home, school, or business

$$$$-$$

DUE: $$

BILL

THANKS, NEIGHBOR!


more quickly, and can move forward with installing the project

and soliciting additional projects sooner. Municipalities can

redirect valuable staff time to projects that require more-

intensive review. While these procedural improvements are

sometimes specific to solar, all permit applicants may benefit if

they are implemented broadly.

4. Fair Permitting Costs

Fees should fairly reflect the time needed for city staff to

review and issue a permit. They should remain relatively

consistent regardless of system size and are often not

proportional to the materials cost of a solar installation, in

contrast to other types of projects. A flat fee of $400 or less is

reasonable for a residential solar permit.

A common way for AHJs to cover the administrative expense

of providing permits is to assess fees for their issuance.

Therefore, it is critical that permit fees cover the time it takes to

review and issue permits so that AHJs have adequate staff and

resources to meet demand. At the same time, it is important

that AHJs make their permitting processes as efficient as

possible by adopting the other best practices, which in turn

should keep fees reasonable. As far as calculation of the

appropriate fee and fee cap, using a flat-fee method instead

of a value-based method to assess permit fees streamlines the

process and ensures that larger solar energy systems are not

arbitrarily penalized. The typical value-based method, which

relies on the cost of a PV system, often results in an inflated fee

that does not reflect the actual staff time required to review

the permit application. In the end, it is important to recognize

that the role of AHJs in permitting is valuable. Payment of a

reasonable permit fee that compensates the AHJ for its time

and labor may actually aid in the long-term sustainability of the

rooftop solar market.

5. Narrow Inspection Appointment Windows

Ideally, installers should be able to schedule an appointment for

an inspection at a precise time. When this is not possible, the

window for inspection appointments should be kept to within

two hours or less. We also recommend that inspectors notify

contractors as the inspector nears the site as an additional way

of reducing waiting time for both installers and inspectors.

Shorter windows for inspection appointments benefit both

installers and inspectors. It reduces the amount of costly

installer time spent waiting for inspectors to arrive. In addition,

it lessens the chance that an inspector will arrive and find the

installer unprepared for the inspection. If the inspector provides

a two-hour or shorter time window, and notifies the installer

close to the time of arrival, it can help to ensure that the

installer will be there and ready for the inspection. This avoids

wasting the inspector’s time as well. Taking advantage of the

ubiquity of cellphones and Internet access, jurisdictions have

developed a variety of new methods for scheduling inspections

and enabling shorter windows.

6. Eliminate Excessive Inspections

We recommend requiring only one inspection by the AHJ for

standard rooftop systems on existing homes or businesses.

Numerous AHJs have found that they can safely permit solar

systems without requiring more than one inspection, often by

rolling together electrical, structural, and fire safety inspection.

Eliminating reviews that do little to validate the safe and

efficient operation of a proposed PV system—for example, plan

checks with aesthetic criteria, or certain rough or in-process

inspections—removes unnecessary costs and expedites permit

issuance. For rough or in-process inspections in particular, the

installer’s work crew has to be put on hold while the inspection

is scheduled and completed. This creates scheduling and

staffing challenges for solar installers, who in certain cases

might otherwise be able to complete installation in one day. For

AHJs, requiring only one inspection can free up inspectors to

be more thorough on other job sites and possibly reduce the

need to rely on third-party inspectors in overflow periods.

PRESENTATION OF FINDINGS

In collecting the permitting data on AHJs throughout Los

Angeles County, we found that performance varied widely.

In fact, while cities can take several steps to improve their

individual processes, the biggest problem is the lack of

standardization. Nearly every city has adopted a unique

permit approval process. Thus, while we discuss several steps

that cities can take to improve their own processes, further

state-level action is clearly needed to standardize and simplify

residential solar permitting. In Table 1, we provide our findings

on each AHJ in the county.

Los Angeles County regional offices preside over

unincorporated regions in Los Angeles. Table 2 highlights

that even within these offices, which function from the

same permitting guidelines, discrepancies exist. La Puente

and South Whittier were both able to process permits over

the counter, while all other offices needed more than two

days for processing. The inspection appointment windows

and the number of required inspections also varied,

illustrating the need for county and statewide training to

prevent such inconsistencies.


Jurisdiction Name Elim

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TABLE 1 (ALL CITIES) — LOS ANGELES COUNTY MUNICIPALITIES


TABLE 2 (LA CITY) — LOS ANGELES INCORPORATED AREAS

TABLE 1 (ALL CITIES) — LOS ANGELES COUNTY MUNICIPALITIES CONTINUED


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We would like to recognize and thank Kyle Toliva, Wendy Whitcombe, and Alyssa Young for their invaluable time and support during the data collection process. Their support was critical to the development of this report.

DISCUSSION

Much work remains if the Los Angeles region is going to

realize its full rooftop solar potential. Only eight AHJs across

the region received a “Best” rating, compared with 40 others

that received a “Worst” rating. By far, AHJs have the hardest

time processing applications online, with only 6 out of 90

providing this option to installers.

1. Requirements Posted Online

Many AHJs have posted PV permit-requirement checklists to

their building department websites. Some have developed PV

installation permits that consolidate relevant information and

provide a conclusive review of the project while eliminating

redundant permitting fees. Smaller and more rural cities

were less likely to achieve this best practice, but could often

provide a list of requirements over the phone. Overall, 62

percent of “Best” cities, 41 percent of “Good” cities, and 20

percent of “Worst” cities complied with this best practice.

2. Online Processing

This category faces the lowest level of compliance, with 6 out

of 90 AHJs accepting permits online or by email. Budgetary

constraints often make the initial investment in web

development tools that enable online permitting daunting

for smaller AHJs. A state-funded template is recommended

to assist budgetary restricted AHJs. Alternatively, AHJs

could choose to defray costs by collaborating on a multiple-

jurisdiction website. Where this is not possible, simply offering

an email address, to avoid the time and cost of delivering an

application in person, would be suitable.

3. Rapid Turnaround Time

A city’s ability and willingness to process these permits

reflected the efficiency of its overall PV permitting review

process. While wait times varied, all “Best” cities, one-third (12

total) of “Good” cities, but no “Worst” city were able to process

the permit applications over the counter. Only three “Worst”

cities could process the report within one to two days.

4. Fair Permitting Costs

Fee schedules were also indicative of a city’s overall ranking.

All “Best” cities, 60 percent of “Good” cities, but only 10

percent of “Worst” cities had reasonable fees. In total,

more than half the AHJs in Los Angeles County failed to

adhere to the best practice of capping fees at $400. AHJ

representatives were occasionally uncertain of the exact

permitting cost and fee schedule. This ambiguity creates

another hindrance for prospective installers who must exert

further efforts to get a quote.

5. Narrow Inspection Appointment Windows

Only 35 percent of all AHJs offered narrow inspection

appointment windows. Only half of the “Best” cities, 36 percent

of “Good” cities and 28 percent of “Worst” cities offered

narrow appointment windows.

6. Eliminate Excessive Inspections

Only five out of eight “Best” cities (62 percent), 27 of 41 “Good”

cities (65 percent), and 20 of 39 “Worst” cities (51 percent)

have eliminated excessive inspections. Low compliance in this

category indicates a lack of education, familiarity, and priority

for residential solar installations among AHJs. Strengthening

training efforts would better prepare inspectors to assess a

system fully in just one visit.

CONCLUSION

Huge rooftop-solar energy advancements have been made

in California. The California Solar Initiative and industry

technological advancements have set the stage for full

integration of distributed solar energy into the state’s grid.

Reform of the permitting process offers a high return on

investment and would boost solar installations across the

state. Simplifying and standardizing the permitting process

for residential photovoltaic rooftop systems is necessary if

AHJs want solar to help achieve local and statewide renewable

energy goals. The collected data show that all best practices

have been implemented to varying degrees across the county.

The improvements suggested in this report would ease

the process of expanding these practices for AHJs, would

benefit the solar installation community, and would decrease

installation costs for homeowners.

ENDNOTES1 Barbose, Galen, Naim Darghouth, Samantha Weaver, and Ryan Wiser.

Tracking the Sun VI. Rep. Lawrence Berkeley National Laboratory, July 2013.

Web. http://eetd.lbl.gov/sites/all/files/lbnl-6350e.pdf

2 Tong, James. Nationwide Analysis of Solar Permitting and the

Implications for Soft Costs. Rep. Clean Power Finance, Dec. 2012. Web.

http://solarpermit.org/media/upfiles/CPF-DOE%20Permitting%20Study_

Dec2012_Final.pdf

3 Hernandez, Mari. “Solar Power to the People: The Rise of Rooftop Solar

Among the Middle Class.” Center for American Progress, 21 Oct. 2013. Web.

http://www.americanprogress.org/issues/green/report/2013/10/21/76013/

solar-power-to-the-people-the-rise-of-rooftop-solar-among-the-middle-

class/

4 National Renewable Energy Laboratory. Friedman, Barry et al.

“Benchmarking Non-Hardware Balance-of-System (Soft) Costs for U.S.

Photovoltaic Systems, Using a Bottom-Up Approach and Installer Survey –

Second Edition.” October 2013. http://www.nrel.gov/docs/fy14osti/60412.

pdf

5 Tong, James. Nationwide Analysis of Solar Permitting and the

Implications for Soft Costs. Rep. Clean Power Finance, Dec. 2012. Web.

http://solarpermit.org/media/upfiles/CPF-DOE%20Permitting%20Study_

Dec2012_Final.pdf

Documents

SIMPLIFYING RESIDENTIAL SOLAR PERMITTING