International Fire Code 3 Rule Dennis Epp Heritage Solar, Inc. 2012 Heritage Solar, Inc. All Rights Reserved.

International Fire Code 3’ Rule

Dennis EppHeritage Solar, Inc.

2012

Heritage Solar, Inc. All Rights Reserved

HERITAGE SOLAR


Our Philosophy

We Believe that locally produced clean energy is good for our environment, our economy, our families and our future

Our goal is to provide our customers with the best equipment, the best installation and the best long term value available on the market today, and we want to do it safely

California—Perfect for Solar Electricity- or at least it was

In order for Solar To be Cost Effective you need: Lots of Sunshine High Electricity Rates Net Metering Interconnection Laws Solar Rights for Consumers (California Civil Code 714) Full Access to the roof for Solar Panels to avoid

shade, vents, chimneys, skylights and upper roof structure shading


Electric Use Residential General Observations Monthly Use Monthly Bill Solar

Panels Condo 500-700 kWhs/month $118 23 2000 sq.ft. home 700-800 kWhs/month $150 27 2500 sq.ft. home 800-1000 kWhs/month $196 33 2500 w/pool 1000-1500 kWhs/month $337 50 3000 + w/pool 1500-5000 kWhs/month $1331 160 McMansions 2500-12,000 kWhs/month $5023 400

Roof Space is almost always the limiting factor Larger Systems are most cost effective Most 20 year savings projections are around $200,000


The Perfect Roof Doesn’t Exist


High Efficiency Sunpower2 Rows of panels 5’2”Total Panel Height 10’4”Perfect 3’ Boundary on topTotal Roof Height 13’4”

9 Columns of panels 32” Wide24 Feet of panels6 Feet of Egress32 Feet Total Width

This roof, essentially, Doesn’t exist

The 3’ Impact in Real Life


High Efficiency Sunpower26 Panels MaximumShading IssuesVent PipesSkylightsChimneys

3’ Rule System Size Loss13 Panels50% Reduction$100,000 20 Yr. Savings Loss



High Efficiency Sunpower39 Panels MaximumShading Issues on West SideVent Pipes

3’ Rule System Size Loss26 Panels66% Reduction$192,520 20Yr. Savings Loss



High Efficiency Sunpower 32014 Panels MaximumShading Issues on West Side Tall TreesSteep West RoofVent Pipes

3’ Rule System Size Loss7 Panels50% Reduction$67,407 20Yr. Savings Loss

Inverters w/Integral DC disconnect

Electrical Service



High Efficiency Sunpower 23027 Panels MaximumShading to the SouthVent Pipes

3’ Rule System Size Loss9 Panels33% Reduction$66,600 Yr. Savings Loss



High Efficiency Sunpower 23042 Panels MaximumChimney to the SouthVent PipesSecond Story Roof Shading




High Efficiency Sunpower 23028 Panels MaximumService Mast to the SouthSecond Story Roof ShadingLower Roof on WestTall Trees and Palms to SouthAnd West




High Efficiency Sunpower 23020 Panels

3’ Rule System Size Loss0 Panels0% Reduction$0 20 Yr. Savings Loss



High Efficiency Sunpower 23056 Panels

3’ Rule System Size Loss0 Panels0% Reduction$0 20 Yr. Savings Loss



High Efficiency Sunpower 23072 Panels MaximumMultiple ChimneysNo Solar on Front of House




High Efficiency Sunpower 23036 Panels MaximumChopped up Roof


Homeowner Economics


Average System Size 27 Panels Average 20 year savings $200,000 Number Installations installed CA/Yr.

25,000 System Size Reduction 3’ Rule 50% Consumer Lost Savings Forward Looking

for 2012 Installations $2.5B

Solar Business Economics


Average System Size 27 Panels Estimated Number of Solar Employees in California >20,000 Impact of a 50% Reduction in Panel Installation 10,000 Impact to the overall economy—Hard to tell—Probably 30,000 What is the fastest growing sector of the American Economy

Solar is the Fastest Growing Sector of the Economy

The Mid Atlantic Region is now Beating California for Solar Installations

CALIFORNIA STATISTICS


85,165 Systems Sold since January 1, 2006

2155 Companies have sold at least 1 project CA

27 Panels Average System Size (Residential)

5.7 kW Average System Size Average Cost per Watt 2006 $9.00/Watt Average Cost per Watt 2012 $6.25/Watt

Other Observations


The 3’ Rule makes Roof Space much more expensive Solar Installers currently have to deal with Trees, Chimneys, Vents Roof Space is already valuable—Fire Boundaries exacerbate the

issue Sunpower and Sanyo are the highest output but most expensive

panels This will shift almost all solar over to the highest cost panels and

will limit or eliminate most of the polycrystalline panels installed in the US

This will increase the overall cost per watt by at least $2.00 as we shift to smaller systems with the same overhead, and fixed costs

Bad news, we will virtually guarantee that Monocrystalline prices will rise

Firefighters Deserve a Safe Environment


Firefighter Roof Safety is Important Firefighters Should Have 50% of the roof for Egress and Venting without

triggering a Fire Authority Review Emergency Egress—Suitable pathways for Access and Egress Smoke Ventilation

Suitable location for Standard 4’x 4’ hole Suitable location based on wind direction Suitable location based on Roofing Material—Most of Orange County is Concrete Tile

Most Training videos and actual fire videos indicate that firefighters go up the middle of the roof, remove the tile, use 5 cuts to remove surface plywood, and then use a tool to break through the ceiling drywall.

After venting is accomplished, firefighters egress down the middle of the roof to the ladder, avoiding unprotected edges of the roof.

Our Employees Deserve a Safe Environment Too


Solar Employee Safety is Important to Us What are the most dangerous jobs in America—Fatalities/100,000

Fisherman 116/100,000 Logger 92/100,000 Airplane Pilot 71/100,000 Farmer and Rancher 41/100,000 Mining Machine Operator 39/100,000 Roofer 32/100,000 Sanitation Worker 30/100,000 Truck Driver and Deliveryman 22/100,000 Industrial Machine Repairman 20/100,000 Police Officer 18/100,000 Fireman 8/100,000 Note, Driving a car = about 15/100,000

The 3’ Rule Shifts Risk


The 3’ Rule at the peak shifts Low Risk Low Probability from Firefighters to High Risk High Probability for Solar Installers

Solar Installers have a much Higher Probability that we will be on the roof. There is a very low probability that a Fire Fighter will be on the roof and need the 3’ easement all

the way around the solar array Solar Installers have a much Higher Fatality Rate Solar Installers are on the Edge of the Roof for Extended periods

The 3’ boundary at the ridge forces most solar arrays to the very bottom edge To install the bottom stanchions, rails and panels:

• Hook up to a rope• Carefully walk to the very bottom

edge carrying tools and hardware• Sit down on bottom edge of roof• Remove Concrete tile in a downward

direction• With a brush, remove debris• Drill a pilot hole

• Apply adhesive to hardware• Lag bolt hardware to rafters• Drill hole in concrete tile• Replace concrete tile and install final

hardware• Repeat multiple times to get all of the

stanchions in.• Install Rails and Grounds• Install Solar Panels

Fire Statistics Regarding Solar


Fire Statistics Regarding Solar


In Summary, Since 1982 or so, there have been 7 reported fire incidents in the United States involving solar either directly or indirectly

The End of Cheap Oil

Hubbert’s Peak calculations predict worldwide oil production will start to go down—2005

Globalization has increased the number of available consumers by 3 billion

China and India are expanding rapidly and their demand for oil is tremendous


Increasing Electric Grid Loads Cars will become electric or hybrid

electric Plug in Cars will significantly increase the

load on an already strained electric grid Electric prices in California will skyrocket Electric Rationing may occur In order to maintain lifestyle, individuals

will buy solar for their homes


How Can California Improve No Fire Review or boundaries if Solar is

<40% of Entire Roof No Ridge Boundary if roof is 4:12 or less 1 Foot Ridge Boundary if roof is >4:12

for Firefigher ladders with hooks No Egress Boundaries if Solar <40% of

Entire Roof (1) 3’ Boundary if Solar is >40% of Entire

Roof


Conclusion

The Cal Solar Fire Guidelines (3’ rule) are a colossal unwitting error in judgment that will cost the United States, and California in particular, Billions of Dollars in money that could be saved by consumers and reinvested in the economy without (arguably) improving Firefighter Safety.

The Guidelines will have a devastating affect on the Solar Sector and will cause a dramatic reduction in Potential Jobs in the Solar Business.

The Original Solar Representatives who commented on the Guidelines in the first 6 months of meetings were unqualified for the task, did not genuinely represent the needs of the Solar Industry and suffered from a lack of imagination and vision. They did not understand the ramifications of the 3’ rule or that it would be enforced rigidly

The Guidelines neglected to balance installer safety, consumer cost savings, and the greater good to the community, the environment and the economy

The Guidelines neglected to balance personal freedom of individuals to install solar on their homes


International Fire Code 3 Rule Dennis Epp Heritage Solar, Inc. 2012 Heritage Solar, Inc. All Rights Reserved.

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