Ensuring that an installation is compliant with standards is the installer’s responsibility, regardless of pressure from designers or retailers, writes Nathan Smith.
The smooth operation of the solar industry depends upon the compliance of parties involved with the Renewable Energy (Electricity) Regulations 2001. While most installers will not be intimately familiar with all parts of this document, it governs the requirements for many of the fundamental interactions within the industry. This includes the creation and assignment of Small-scale Technology Certificates (STCs), which for many installers working in the residential rooftop solar industry forms the lifeblood of the sector.
While the Renewable Energy (Electricity) Regulations 2001 have far-reaching effects into generation, transmission and consumption of renewable energy in Australia, there is one regulation within them that impacts the day-to-day work practices of solar installers more than any other – 20AC: Requirements for the Creation of Certificates. This regulation requires installers to declare their compliance with all local, state or territory government requirements, the Clean Energy Council’s Code of Conduct and all relevant Australian Standards, including AS/NZS 1170.2 – Structural Design Actions, Part 2: Wind Actions.
When an accredited installer signs the STC claim after installation, they are declaring that the installation complies with this regulation.
Along with the racking system manufacturer’s instructions, AS/NZS 1170.2 dictates the requirements for the arrangement of solar modules on a roof structure, more specifically “amendment 2, appendix D, paragraph D6”, which will apply to most domestic installations.
The most common noncompliance with these requirements comes from the proximity of modules to the edges of the roof. That is, where modules sit a distance s above the roof surface, they must be at least twice that distance (2s) from the edges of the roof (not gutter). For instance, if a module is installed so that it sits 100mm above the roof surface, the installer must maintain a minimum of 200mm from the edges of the roof structure. In some cases, the manufacturer’s instructions may prescribe larger exclusion zones that need to be observed. As a result, it is vital for installers to have a sound understanding of the products that they are installing.
If a module is installed too close to the edge of the roof, not only does it fail to meet the requirements of the standard and the manufacturer’s instructions, it poses a risk that the module, racking system and structure could be subject to wind loadings they are not designed for. This could result in damage to the modules or structure. In a worst-case scenario, modules could become dislodged from the roof, posing a significant hazard.
With the damage that can be caused by not complying with these requirements, why would an installer not follow them? Unfortunately, this can be caused by a lack of familiarity with AS/NZS 1170.2 or by the installer not following or understanding the racking manufacturer’s instructions. Pressure from a retailer to install a certain number of modules that cannot compliantly fit can also play a role in an installer making a decision to install modules too close to roof edges.
Without physically measuring a roof space, it can be difficult to tell if an array can be installed on a roof with consideration to the available space, the location of structural members and mounting points, and the required clamping zones of the specific module. Due to this, a design that has been completed without attendance to site (that is, by a designer without practical experience with building structures using a design tool with satellite imagery) can often have allowed for more modules than can practically and/or compliantly be installed.
The primary concern
In a situation where an installer finds that the design is not appropriate for the roof space after measuring up, they need to stop and consider alterations to the design that will allow it to be installed compliantly. This could involve re-arranging the modules on the roof or in some situations reducing the number of modules that are to be installed. In either case, once a solution has been found, the changes should be approved with the customer and retailer.
The Clean Energy Council understands the difficult situation that installers can find themselves in when they have been sent to a site and realise that the system design they have been asked to install is not able to be completed in a compliant manner. To protect installers in a situation where they are sub-contracting for a retailer, the Clean Energy Council has created the Solar Sub-Contractor Agreement. This template provides installers with some legal protection against last-minute changes and can be a good start to having these difficult conversations, before you even get to site.
Ultimately, the important thing for installers to remember in this situation is the installation cannot be completed without you, and when you sign off the installation you are stating as per the regulations that the installation complies with the relevant standards.
The industry depends on CEC-accredited people to ensure solar installations are undertaken in a compliant manner. STCs also cannot be generated without someone having your qualification, experience and industry skills. So, make sure that the value of your accreditation is considered in every installation you sign off.
Nathan Smith is a technical support officer at the Clean Energy Council.