Does roofing -- removal and reinstall of an older solar PV system -- trigger rapid shutdown requirements?

[iOne]

My local jurisdiction is requiring an electrical permit to dismount, reroof, and remount an older solar system.
The original system was installed with permits, but the inverter was replaced later without a permit.

The question is what code applies? Is this an "existing building" and we can put it back in kind?
Or is this going to require a full code upgrade to rapid shutdown with extra frosting? What if the inverter and system can't be upgraded?

Jurisdiction: California.

 

[mark handler]

If you remove an item, the replacement item shall meet the current code.
All new work shall meet current code.

If you reinstall a non-code compliant item, and there is a fire, your insurance company may not payout.

 

[iOne]

If you remove an item, the replacement item shall meet the current code.

The absolutist version of that rule is a poor match for solar: solar systems are not completely modular.
In the extreme imagine a roof patch that requires displacement of a single panel, on an older system.
New old stock of the microinverters, or whatever, might not meet the current grid support requirements, or whatever.
Or, roof access isle requirements may result in removal of panels.

There may be no reasonable upgrade path, for equipment that was not at the end of a natural lifespan.

It seems some AHJ's don't care at all and allow the old panels back in the same place.
Others (including my most local one) appear to require a full code upgrade, insensitive to the original manufacturing, permit or install date of the legacy equipment.

But interested if there are examples of an AHJ policy on replacements that strikes a balance between moving the equipment via time machine, and ignoring it completely.

 

[Joe.B]

Many AHJ's in CA mostly ignore the existing building code, but they shouldn't. I think there's a path for you. First, CA treats the scope and application a little different:

101.2 Scope. The provisions of this code shall apply to the repair, alteration, change of occupancy, addition to and relocation of existing buildings.

Exception: Detached one- and two-family dwellings and townhouses not more than three stories above grade plane in height with a separate means of egress, and their accessory structures not more than three stories above grade plane in height, shall comply with this code or the California Residential Code.
That last part in bold is where CA is a bit unique. It gives the applicant the choice of one or the other. Then go to:

406.1 Material. Existing electrical wiring and equipment undergoing repair shall be allowed to be repaired or replaced with like material.

I would hope that a reasonable person would allow this... But hope hasn't proved itself to me yet...

 

[mark handler]

Many AHJ's in CA mostly ignore the existing building code, but they shouldn't. I think there's a path for you. First, CA treats the scope and application a little different:

101.2 Scope. The provisions of this code shall apply to the repair, alteration, change of occupancy, addition to and relocation of existing buildings.

Exception: Detached one- and two-family dwellings and townhouses not more than three stories above grade plane in height with a separate means of egress, and their accessory structures not more than three stories above grade plane in height, shall comply with this code or the California Residential Code.
That last part in bold is where CA is a bit unique. It gives the applicant the choice of one or the other. Then go to:

406.1 Material. Existing electrical wiring and equipment undergoing repair shall be allowed to be repaired or replaced with like material.

I would hope that a reasonable person would allow this... But hope hasn't proved itself to me yet...

CA Existing Building Code​

 

[mark handler]

"...replaced with like material...." STILL NEEDS TO COMPLY WITH THE CODE.

 

[Joe.B]

The matrix adoption tables are non-regulatory and just because one agency or another isn't checked on the table doesn't mean it's not required. The "t" like cross symbol means that agency specifically does not adopt that section. In the case you circled above, OSHPD has identified that those provisions do not apply to projects under the scope of that agency. OSHPD 1, 2, 4, & 5 are not under the authority of local building departments. If section 406 was not a part of code, why would they have to identify specifically that those sections don't apply to their scope?

Further, the new sections of code that were added in the mid-cycle amendments illustrate this point. Take chapter 9 of the CEBC for example, in the original publishing that took effect Jan 1, 2023, it didn't exist. There was only a title page that included "Not adopted by the State of California". The mid-cycle supplement, effective July 1, 2024, included Chapter 9.

My point is, if 406 were not a part of CA code, it wouldn't be there at all.

 

[iOne]

I got this answer from my AHJ

1. An existing PV system can be reinstalled under an electrical permit if
   1. There is an existing approved plan or SOLARAPP+ approval number that would be used as reference under the new permit (the installer would need to provide the drawings and permit number we will not do the research for them); or
   2. The solar company that will remove the existing PV system documents the existing system with pictures and spec sheets of the equipment and provides the permit under which the initial installation of the PV system was performed. We can assume that the initial install was code compliant if it received approved final inspection; and
   3. A solar installer must provide a letter confirming that the existing system is in good working condition.
2. If the system is in the WUI area they would need to confirm the existing system complies with the WUI requirements for Fire Resistive assemblies, If not then new install is required.
3. If an existing permit cannot be found to confirm that the PV system was installed under the benefit of an electrical or building permit then reinstall cannot be approved and the PV system must be new with permits.
4. If the Solar Installer cannot confirm that the existing system is good working condition then a new system must be installed.

(This is a simplified path for no change reroof. Questions like "could I replace the inverter, but keep the old panel layout" layout are not addressed).

 

[Joe.B]

Sounds legit to me.