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Solar Energy Permitting Fees in the San Diego Region--

By Katie Franklin,2014-08-09 18:20
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Solar Energy Permitting Fees in the San Diego Region--

    Solar Energy Permitting Fees in the San Diego Region--

    A Comparative Study with Recommendations

    Executive Summary

    While the state spends hundreds of millions of dollars promoting renewable energy and conservation, a number of local cities in San Diego County are impeding customers’ efforts to switch to non-polluting, renewable energy. That is

    the startling findings of UCAN’s survey of the building and permitting departments in San Diego County.

This study highlights the urgent need to standardize most cities’ solar installation

    permitting process and provides ways of accomplishing that goal. In general, UCAN recommends a collaboration of city and state officials, licensing boards, solar component manufacturers, contractors and installers to create a standardized model for the permitting process and pricing. In this way, San Diego Cities can assist the region in becoming energy efficient and energy self-sufficient.

    UCAN’s review of the policies of 17 cities throughout San Diego and the County of San Diego shows a wide discrepancy in the cost of permitting fees and requirements to install photovoltaic (PV) solar panel systems. Permit fees varied from a minimal $22.50 to over $500, with an additional $1,000 Design Review application fee in Del Mar--more than a twenty-fold difference. The variation in type of permits and charges required to install solar panel systems ranged from city to city. Four cities assessed an issuance charge; 12 required plot plans, four required roof & structural plans or a building permit, and six cities had no set requirements for permitting. In fact, no two permitting departments were alike in terms of procedure, costs or required information for installing PV systems. More San Diego residents are turning to solar energy in light of the state’s energy

    crisis. UCAN’s survey reveals that though some permitting agencies have streamlined the process and are prepared to handle the new technology, many lag behind and consumers and contractors are the ones that suffer. Some building and planning departments are currently ill-prepared to handle the task of permitting PV installations because they lack the standards and experience of more seasoned departments. Numerous city building departments previously dealt with a handful of solar permits a year, but as PV becomes more of a solution for California’s energy future, the cities will need to revamp their currently-outdated systems.

    UCAN’s Specific Findings of the Cities Surveyed

    Costs, Exorbitant Fees and Extraneous Requirements

    ; On average, permitting fees cost $218.

    ; Four cities had permit fees under $70

    ; Six cities had permit fees over $200

    ; Costs of permits can vary by 2300% depending on the city in which the

    solar panel system is located

    ; Consumers face excessive charges for permit fees and additional

    requirements compared to neighboring cities

    ; Plan check fees range from no-fee in El Centro and with the County of

    San Diego to as much as $400 in Chula Vista.

    ; Consumers may be charged higher fees for the same service such as

    building permit fees and plot plans.

    Lack of Standardization

    ; Various cities have no standard for determining permit fees: 1 city used a

    design review process, 1 used a performance-based inspection, 8 cities

    used a contract valuation, and 8 cities had a flat fee.

    ; The type of documentation needed for a solar permit is not standardized

    and varies from city to city.

    ; Consumers and contractors may endure long delays caused by

    requirements for both a solar and building inspection or due to not having

    foreknowledge of required documents.

    ; There are a limited number of qualified solar permitting inspectors. I. Introduction

    According to the most recent report from the California Energy Commission, the State of California imports 18% of its power needs. The San Diego region

    produces approximately 2,200 MW of power to serve the area’s projected 2001 demand of 4,376 MW. In other words, customers in SDG&E’s service territory

    are heavily-dependent on importing half of their electricity from outside the region. One way to decrease this dependence is for residents and businesses to invest in on-site, distributed generation such as fuel cells, microturbines, wind generation, co-generation, passive solar water heating and solar energy. Electricity generated in this manner does not need to be transported over long distances from centralized, large power

    plants to the end user, distributed generation technologies could reduce the estimated 6% to 8.6%of electricity that is lost by transporting it through the transmission and distribution system; thus, aiding in reducing the region’s import dependence by upwards of 187 MW. In truth, transmission line upgrades are not only inherently inefficient with line loss factors, but reinforce our dependence on importing power from out-of-state, while increasing the rates of utility consumers to pay for their construction.

    A Typical Case History:

    Lewis Fry is a consumer who lives in Chula Vista who decided to invest in a solar panel system that would meet his family’s energy needs, allow them to do their part in resolving the energy crisis and produce their own power using a

renewable, non-polluting energy source the sun. He did extensive research and

    finally chose a contractor and equipment that would power his house and reduce his family’s reliance upon imported power. But he was blindsided by a disturbing realization his local municipality was going to make him pay dearly for his good intentions. It was with more than just a little shock that he learned in early June that he would have to pay upwards of $607 to obtain a permit for his new 2.4 kW solar electric system. The City of Chula Vista required $200 for the building permit and $400 to review the plans for the installation. In addition, the City told Mr. Fry’s contractor, a licensed electrician for almost ten years, that it would require 7 to 21 days to review the those plans. To date, Mr. Fry is still waiting for his system’s permit to be approved by the City of Chula Vista. Until the permit is issued, Mr. Fry will not be able to receive his 50% rebate from the California Energy Commission for installing renewable energy.

    Unfortunately, Mr. Fry is not alone. Other consumers throughout San Diego are finding that a municipality can be a friend or an obstacle to "doing the right thing" for the environment and for Southern California’s dependence on importing electricity. UCAN decided to compare the various costs and issues associated with installing solar electric panel systems in the cities and County of San Diego. We found that some cities used a sliding scale for permitting fees and therefore we assumed an average PV system of 3kW, enough to provide approximately 450 kWh per month costing approximately $16,000 after deducting the California Energy Commission’s Buydown rebate.

    II. Solar Permits

    According to data from San Diego Gas & Electric (SDG&E), the local utility that oversees the interconnection of solar electric panels to its transmission and distribution grid, 2001 has already shown a seven-fold increase in the number of PV systems installed compared to the previous year, with hundreds of other installations in the works. Statewide, the California Energy Commission, which doles out the state’s 50% rebate program for installing solar energy and other forms of distributed generation, shows a ten-fold increase in solar energy rebate requests in 2001 compared to 2000. Obviously, the current electricity climate in California and Southern California has led to a substantial increase in the number of consumers who have decided to invest in generating their own power using solar energy. However, though it is evident that solar power is exponentially on the rise, the question remains about whether the agencies in charge of making sure such systems are installed safely, have the resources and expertise to permit these installations in a timely and cost-effective manner. Using solar energy to create electricity necessitates review by various planning agencies. Solar permits are required to insure that new solar electrical systems are safe for homeowners, contractors, electricity grid technicians, firemen and the transmission and distribution grid that serves the community. Connecting any kind of electrical generation into the transmission grid is potentially dangerous and must be done with caution. Therefore, appropriate interconnection standards are required to prevent electrocution and electrical fires, ensure that solar electric panels and the community are safe from power surges during blackouts, and facilitate the safe backflow of power into the transmission and distribution grid. In

    addition, building structures must be inspected for wind sheer and load bearing capabilities before solar electric systems may be installed. In general, permits need to be issued to ensure that solar systems meet current building and electrical code requirements.

    III. Costs

    Though permitting and plan review are a necessary part of solar power installations, the current solar permitting process varies greatly from agency to agency throughout the San Diego region. Some charges are as inexplicably high as Chula Vista’s $519 permitting fees or the $1,000 Design Review application

    fee for inclined arrays in Del Mar, to a low of $22.50 in El Centro. Listed below are the survey results. Where fees are calculated by system size or system cost, UCAN assumed a 3KW system that costs $16,000.

For an UPDATE on the fees listed below, click here.

    Under Permit $115 to Permit fees $70 fees$200

    El Centro $22.50 Lemon Grove $151.00

    Encinitas & $55.00 El Cajon $171.00 Solana Beach

    Imperial Beach $49.90 Escondido $156.00

    La Mesa $69.00 Santee $166.50

    $70 to Permit Over Permit fees $115 fees $200

    Coronado $97.00 Carlsbad $243.00

    County of San $100.00 Oceanside $287.15 Diego

    San Marcos $100.00 National City $375.00

    Poway $113.75 Chula Vista $519.10

    City of San $115.00 Del Mar $1000.00** Diego

    **Permitting for solar panels that lay flat on the roof is done through the San Diego County.

    UCAN's study found that the average price for a solar permit is $171, excluding the City of Del Mar’s application fee, though the deviation from this average is extreme. As mentioned above, permits range from $22.50 in El Centro, $519 in Chula Vista, to approximately $1000 for a design review application in Del Mar if a solar installation does not lay flat and therefore may obstruct another resident’s view. In fact, aesthetics can also be a mitigating factor in other cities where the priority is made between permitting an installation at its optimal orientation or away from perception from adjoining streets. The question remains of how the

    public would accept and view solar energy if installations were permitted to be seen from primary thoroughfares. Ironically, some of the cities with the highest charges have made efforts to promote responsible energy planning. Chula Vista, long a leader in energy efficiency efforts, undermines its own local policy by overcharging for solar installations. The City of Poway, on the other hand, currently has a 25% rebate on permitting fees to encourage solar installations and the City of El Centro and the County of San Diego currently do not charge a plan check fee, though permitting fees do apply.

    Because the current permitting and interconnection process is not standardized, consumers and contractors can experience delays caused by over-worked city officials, red tape and lack of forewarning about requirements, depending on the city. Other consumers are fortunate enough to live within the boundaries of cities that understand the importance of making the installation of solar energy systems easy and inexpensive.

    IV. Exorbitant Fees and Extraneous Requirements

    Variation in the Procedure for Assessing Fees

    In addition to cost variations, the current solar permitting processes of the various cities and County in San Diego also vastly differ. In fact, no two permitting departments are alike. For instance, many cities defer to their City Council to determine which fees are assessed. Where consumers may pay a flat-fee for all solar panel installations, other cities base their pricing structures on the cost, capacity, or size of the system to be installed (called a "Contract Valuation") or on the number of hours staff allocate to the permitting process. Out of the 18 permitting departments surveyed, one city had a design review process, one city had a performance based evaluation, nine cities had a flat fee, and seven cities used a contract evaluation to determine the cost of a permit. Listed below are tables outlining the various methods for determining solar energy system permits. Design Review: In the City of Del Mar if the solar panels lay flat on the roof, permits are issued by the County permitting department. If the system planned is to be inclined above the surface of the roof, a review is required by the Design Review Board.

    Cost City

    $1000.00 Del

    Mar

    Performance-Based: Performance-based inspections are based on the amount

    of time it takes an inspector to issue the permit. The City of El Cajon is the only municipality that uses a performance-based mechanism. El Cajon charges $57 an hour and assumes the permitting process will take approximately three hours. City Cost

    El Cajon $171.00

    Flat Fee versus Contract Valuation: Cities that use a contract evaluation to

    determine permit fees charge consumers almost three times as much as cities

    that use a flat fee. Consumers pay an average of $167.99 for permit fees in cities that use a contract evaluation to determine the permit fee, and an average of $93.62 in cities that use a flat fee. This price discrepancy may be due to permitting officials in cities with contract valuations being forced to improvise with the current standards in place that do not fit the needs of a permit for solar installation. This can cause additional documentation to ensure solar panel systems are installed properly. A minority of cities mentioned to UCAN that they have only issued one or two permits within the last year, and therefore, these cities may feel that they have no reason to revamp their current contract valuation system due to a lack of demand. Those cities that charge a flat fee for installation permits tend to have more experience with the permitting process for solar, defer to manufacturer specifications for installations, and are more standardized with information requirements. If the more experienced cities surveyed can keep the cost of a solar permit under $115, all of the cities should be required to do the same.

    Flat Fee- Average of $102.51 Contract Valuation- Average of $271.60

    Cost City Cost City

    $22.50 El Centro $97.00 Coronado

    $49.90 Imperial Beach $100.00 San Marcos

    $55.00 Encinitas/Solana $243.00 Carlsbad

    Beach

    $69.00 La Mesa $280.00 Escondido

    $100.00 County of San Diego $287.15 Oceanside

    $113.75 Poway City $375.00 National City

    $115.00 City of San Diego $519.10 Chula Vista

     $151.00 Lemon Grove

     $166.50 Santee

    The impetus for our region to become energy independent and the substantial increase in the number of solar installations that have been installed or are slated to be, necessitate all the permitting departments to standardize the process for their own ease and that of consumers and contractors. The current permitting process needs to be revamped and reviewed to encourage the installation of solar power and to protect consumers from paying higher fees because of geographic location and inexperience with solar installations within the various permitting departments. Clearly, we need a standardized system if we want solar to work.

Contract Valuations Hinder Deployment of Solar

    The contract valuation approach, especially when the system costs are used to determine the fees hinders the deployment of solar energy. Solar power is a substantial investment for consumers and additional costs prevent growth in renewable energy.

    Most contractors charge from 10% to 30% of the total project costs for labor and installation, with the remaining costs attributed to purchasing necessary hardware and materials. One of the conundrums of distributed generation is that the prices for such technologies are still out of reach for most consumers. As with owning a house, who would continue to rent if everyone could afford to purchase and own it outright? Therefore, basing fees on the contracted bid acts as a deterrent in that it is only when technologies increase market penetration, bringing the cost of the hardware down, that the permitting fees will decreases. In other words, basing permitting fees on the system cost punishes consumers who should be encouraged to lead the way in installing renewable technology and self-generation. It is only by keeping permitting fees low that solar and other alternative energy technologies can gain the critical mass that they need to bring their purchase price down and usher in wide-scale adaptation by consumers. The fact that some cities use the dollar amount of the total solar panel bid without making allowances for the California Energy Commission’s (CEC’s) Renewable Buydown rebate of 50% in calculating the permitting fees, acts as an additional obstacle to installing such systems. Rather, all Cities and the County in general should be assisting in promoting and streamlining the installation of distributed generation like solar panel systems to assist our region in meeting its own energy demand.

    Variation in Plan Check Fees

    The plan check fees charged by the permitting departments surveyed range from an affordable $26 plan check fee in Lemon Grove to an exorbitant $343.50 plan check fee charged by the City of Chula Vista. In comparison, the City of El Centro charges a mere $22.50 for the entire permitting process.

    Variation in Electrical and Building Permit Fees

    Of the ten cities that itemize the cost for an electrical permit, the price ranges from $15 in El Centro to $176 in Oceanside and averages $69. Obviously, there is a large difference between what permitting departments are charging for similar services.

    Chula Vista, Escondido, Lemon Grove and Santee charge consumers for a building permit in addition to an electrical permit, at times requiring two different inspectors to view the solar panel system before a permit is issued. In some instances, the contract valuation method for determining fees does not say clearly if the city requires a building permit. Because building officials do not have a set standard to follow, they often require contractors to go to other departments to obtain another permit. Some contractors however believe an electrical permit should be sufficient since panels weigh a mere 3 lbs/ft^2, far under the load limits of 8 lbs/ft^2 that many rooftops are built to sustain.

    Plot Plans

    A plot plan indicates the physical location of the structure with its relationship to

    property boundaries, adjoining buildings, and nearby streets. Most permitting departments require contractors to submit a plot plan, though other cities do not. Variation in Itemized Charges

    Itemized charges differ from city to city. Some cities charge a seismic fee and some have a charge for microfiche. Other cities may have charges that no other city itemized. For instance, Coronado charges a $75 Photovoltaic Permit fee and the City of La Mesa charges a fee of $6.60 for each circuit. In general, additional small charges indicate a lack of standardization from agency to agency. Excessive Document Requirements

    One of the major complaints UCAN analysts received from contractors was a requirement for extraneous information by various jurisdictions. Because each municipality in San Diego has its own requirements, the result is a multitude of documentation that contractors may have to provide. However, it is difficult to determine exactly what type of documentation and requirements are necessary for each city, on account of many cities have either no standards, vague standards, or use a contract valuation, in which documentation and requirements are at the discretion of city officials. Usually, additional information such as septic and holding tank locations and soil impact reports are required for ground-mounted installations. Yet, septic and holding tank plans require the assistance of the County Environmental Health Department which charges an additional $55 for researching their files. If no file is found, a service charge of $450 will be charged for an on-site visit. Septic leach lines and soil impact reports for ground-mounted solar panel systems that can be disassembled and easily moved are excessive. Elevation plans may also be required to determine height constraints and impediments to views that may occur when an installation is completed and in general, a number of requirements may be absolutely necessary for solar permits; yet, additional documentation of a hazardous materials plan check and sprinkler system plans have been required in the past.

    V. A Confusing Lack of Standards

    UCAN analysts not only found huge price gaps between the various cities, but absurd discrepancies in the answers of employees within the cities themselves. UCAN was given prices that later turned out to be incorrect when confirmed by another official, or by a return call correcting the original estimate. In fact, UCAN was informed by the City of Chula Vista that a 3 kW system would cost $519 to permit, though Mr. Lewis Fry who lives in that city, was charged $607 for installing a 2.4 kW system. It is obvious that most city officials are not familiar with the process for issuing solar permits and that consistency in pricing is not the norm.

    City officials that do not have clear standards to follow must improvise with the current standards in place and a subsequent overkill of documentation and wasted time ensues. Again, this scenario usually occurs in the permitting departments that are not well-versed with solar installations and therefore, do not have set requirements for pricing nor for required documents.At least one contractor that UCAN interviewed, expressed frustration at the fact that every city had a different type of evaluation process for permits and that contractors have

    no way of knowing what to expect. Since every city has different fees and requirements for solar permits, contractors cannot become accustomed to a standardized process, and therefore experience increased delays trying to become acquainted with numerous city requirements that vary from jurisdiction to jurisdiction. Although four of the cities surveyed, Poway, Santee, Encinitas/Solana Beach, and Lemon Grove, have adopted standardized requirements for photovoltaic systems, a wide discrepancy still exists for the cost of a permit. Encinitas/Solana Beach charges $55 for a solar permit compared to Santee, which charges $166.50. The question remains about why Santee is charging $111.50 more for solar permits than Encinitas/Solana Beach, while using the same standards. The disparity between the cities that use a contract valuation is even greater and offers contractors no guidelines at all. Without a clear standard for evaluating solar permits, contractors and consumers are left in the dark, or at least in the light generated from electricity produced somewhere else other than locally.

    VI. Excessive Delays

    The lack of a standardized process for solar permits forces contractors to spend too much time at the permitting office. These requirements delay projects for days, if not weeks. Contractors may wait hours for appointments with over-worked city officials in addition to having to make numerous trips to city offices About half of the permitting departments can provide contractors with their required documentation beforehand. With others, there is no way of knowing ahead of time exactly what documents will be required. Even so, additional required documentation may crop up through the permitting process. Again, those cities that use the contract valuation method for determining permit fees, usually do not have clear guidelines for contractors to follow with the exception of the City of Chula Vista does provide clear cut requirements in its Form 4613. other permitting departments, should also provideclear guidelines for contractors to follow instead of the vague guidelines that are currently in place. UCAN surveyors witnessed first hand how difficult it is to reach city officials. In addition to making countless phone calls and sending numerous emails to unresponsive city officials, UCAN was consistently shuffled between various departments. UCAN analysts endured half-hour wait times and uninformed customer service representatives while trying to get answers to questions on the telephone with the City of San Diego. In fact, many city offices such as

    Oceanside and Del Mar took over a week to return UCAN’s inquiries. Once UCAN analysts finally got through to an actual person, it was an uphill battle to get the information requested. Few city inspectors actually handle consumer requests over the telephone or via email. In the County of San Diego, there is one official that can approve a photovoltaic system and oftentimes, the officials that are able to approve the systems, are typically out in the field performing inspections and are difficult to reach. The delays that UCAN experienced would most likely be analogous to delays that contractors and consumers would have in regards to getting appointments for a plan check or inspection. Our discussions with solar installers verify this fact.

VII. UCAN’s Recommendations

    UCAN recommends that a Countywide set of standard fees and permitting requirements should be developed. Ideally, it can be done through a collaboration of solar contractors, installers, regulatory agencies, manufacturers, city and state officials and building and permitting departments. The standardization process should include discussion of the following:

    ; Solar permitting should be streamlined for all permitting departments

    throughout the San Diego region.

    ; Permitting Departments must trust contractors to successfully and

    safely install systems. This could be accomplished through an additional

    licensing or workshop procedure or through scrutiny of a contractor’s first

    installation, with fast track capabilities for additional installations within the

    permitting departments jurisdiction.

    ; Building officials should be educated about solar power by

    manufacturers and contractors to assist in determining the propriety of

    various fees and inspections required for permitting.

    ; Fees and permitting requirements should be lowered. Fees should not

    exceed $100.

    ; The fees and solar permit processes should be posted on all

    municipality web sites.

    Standardized Process

    City officials should work in collaboration with contractors and consumers to create a cost-efficient standardized permit process for all permitting departments to adopt. In UCAN’s discussions with permitting departments, some expressed

    apprehension about the capabilities of contractors to safely and thoroughly perform an installation. This is analogous to allowing consumers to own guns without having to take a class on how to use one. UCAN feels that additional solar installer workshops should be sponsored by the Contractors State Licensing Board (CSLB) or the California Energy Commission (CEC) in conjunction with inverter and solar panel manufacturers. Therefore, only those contractors with specialized certification would be permitted to install systems. A similar suggestion would be for the permitting departments to thoroughly scrutinize the first solar installation that an unfamiliar contractor installs with a pre-, mid- and post-inspection. When the contractor assures the department of their capabilities, then allow the contractor a fast track permit for installations. Educating permitting officials, especially those in jurisdictions that have not had a large number of requests for solar installations will bring those departments up to speed with other permitting agencies that are more streamlined and expeditious. Contractors and manufacturers should also be included in such educational forums to provide information that will assist those officials in creating a simplified protocol with room for contingency requirements to be outlined.

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