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Jeffrey Quackenbush's avatar

I’ve worked in PV and ESS industry in the US for almost 18 years. I’ve been in the field or in project management roles for projects of all types, all over the country. At one point, in fact, I worked for an Australian company, CBD Energy, that was trying to establish a residential installation business in the US.

The kind of critique you’re making is easy to formulate at a high, rather abstract level, but it’s not helpful at all to spur any real reforms without more specifics. From reading this, I don’t think you’ve spent much time talking to people who actually work on the operations of a developer or installer here, or know much about how the construction industry works here.

A few points of feedback from someone who has:

1) The US is a HUGE country, and we have a long tradition of state and local control over construction work. There isn’t a simple institutional mechanism for nationalizing permitting bureaucracy and construction oversight in local construction, and the scale of attempting something like that is far harder than it would be in Australia, which has a much smaller population and a more centralized government. So any attempt at reform needs to work within existing institutional structures, not imaginary ones plucked from countries that have a different history, geography, demography, etc. I’m not convinced either that a nationalized process would be any more efficient. The US government is good at sending out checks and doing large projects; for good reasons, local implementation is usually left to states, counties, cities, even for national programs, like Medicaid. If permitting remains local, that means that it has be managed and reformed locally.

2) Building construction is radically varied across the US, particularly for residential and smaller commercial buildings. Some areas, like southern CA and AZ, have lots of low-pitched shingled roofed, single story houses and low-profile commercial buildings with outdoor services. These are comparable with Australian building stock and are easy to install on. On the other hand, in the Northeast, small building stock tends to have multiple stories, gables, steep pitches, old structures that pose problems with snow load, service equipment that needs upgrading, etc. Managing this kind of variation poses significant engineering and logistical challenges. I could spend hours telling you all sorts of fucked up stories about individual projects if you want a flavor of it. I suggest you talk to installers in different parts of the country and find out how the different kinds of building stock impact engineering and labor costs, because it can considerable. How do you speed up installation? Solutions are going to be regional and technological. Hand-waving answers here are a sign that you've haven't spent much time in the field.

3) The worst problem in our permitting & engineering regime for PV right now is rapid shutdown. They need to kick Bill Brooks off NEC CMP-4 and stop listening to the fire fighter's lobby; the PV industry needs a new direction on that committee. If you want to criticize stupid American regulatory burdens on PV construction, start with that. For ESSs, I think the UL9540 listing process is too equipment-specific, and some of the siting and hazard mitigation analysis regulations in NFPA 1 and the IFC could be relaxed. If you don’t know what I’m referring to, I suggest you spend more time learning about how the industry works here before writing about it, as your critique then would have relevance.

4) Most jurisdictions have a “quality certification” process for installers — it’s called an electrical license. The licensing scheme varies by state (CA, for instance, has a specialized PV license, C/46), but the intent of these licenses is to set a bar for competency in the trades. Some states (MA and NH for example) put onerous burdens on worker certification and this drives up costs, but many don’t. This is a battle to be fought with state electrical boards and state contracting regulators, if local rules are dysfunctional.

5) I’ve worked in a number of jurisdictions and I’ve never had to do a “pre-inspection” on a PV system. In fact, I’ve never once heard that term used. Some AHJs want rough inspections when you’re doing indoor wiring on new construction, so they can see what is behind the walls. This rarely applies to PV systems. I’d like to know how many jurisdictions have a “pre-inspection” requirement, and which ones. Jurisdictions where I’ve worked that separate building and electrical permits don’t usually have an in-person building inspection. The electrical inspection is the main inspection, and then you may have to file an affidavit for the building inspector from the structural engineer who signed off on the job when you submitted the permit. This mostly has to do with snow loads in northern states or hurricanes in the SE, something that isn't a much of a factor in Australia. Larger systems may have a utility witness test that requires the contractor to show up, but this has to do with interconnection, not with construction permitting.

6) Most of the big electrical supply houses have gotten into the PV equipment distribution game for small to mid size projects. In New England, there are four or five local supply chains I could call tomorrow and equipment would be dropped shipped within a week, for no shipping cost in the big metro areas. I don't know what their markup is, but I can't imagine it is much different than the markup for other kinds of electrical equipment. Large developers often work directly with PV module manufacturers and inverter companies and ESS companies.

7) For anything larger than ~1MW, the US has a significant transformer shortage, and that would be the supply chain problem that probably needs the most attention industry-wide. Specifying and securing a transformer is often the long tent-pole item for mobilization once the interconnection is sorted out.

8) The US has a problem with ESS maintenance and warranties not being easy to coordinate and execute, because legal concepts haven’t been well adapted to the technological reality of batteries, and the SCADA side of the industry needs to mature. I’m not sure how many ESS integrators are going to have staying power either, so there could be a rash of orphaned ESSs out there in the next decade. The framework for ESS maintenance and warranties should be more standardized and that's something the industry could do with internal coordination.

9) I think a fair amount of acquisition cost is tied to financing. Having to finance smaller systems means that developers and installation companies have an extra hoop to jump through, and many prospective clients will be asking for proposals that don’t go anywhere because they weren't sure if the PV system makes financial sense. The variety of building construction adds to the uncertainty (how do I know if my house is a good PV site?). This creates a lot of churn, and it is churn that is costly. Have you spent time talking to sales people here and figuring out how they can sell more effectively? If you have good ideas about how to reduce churn, you could make a killing as sales consultant in the US, and bring down those acquisition costs.

10) As far as liability goes: what are your proposals to reform state-regulated insurance markets and the legal practices that grow out these markets? Remember that these markets are responding not just to the need to build PV on buildings, but to all kinds of construction work happening in each of the 50 states plus DC.

11) I’ve never supported the tariffs on RE equipment, but I am concerned now that if the US and its allies don’t have a supply chain for panels, inverters, transformers, etc. for national security reasons. What happens if China invades Taiwan in three or four years and the escalation of that conflict shuts down access to the usual volume of goods produced in the western Pacific? I really hate (everything) the Trump Administration is doing, but the IRA has been spurring more development of manufacturing capacity in the US and among our allies. If we can get through the next decade without China going to war, then I’m all for 0% tariffs for the rest of time.

12) Interconnection here sucks, but, again, for rooftop systems, that’s a fight that has to play out at each state-jurisdictional PUC. If you want to understand the state of play across the country, talk to the folks at IREC about what might be constructive (https://irecusa.org).

In general, I’ve noticed that people writing about this in the media don’t take the time to talk to practitioners, and I think it creates a significant gap in the discourse. I suggest the next time you write about this, you spend more time getting to know the subject.

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ARD62's avatar

This is great! One interesting thing about the 10,000 jurisdictions is that any US state could solve this permitting and regulation problem for itself and lead the way. Florida has about the same population as Australia. California has around twice that much. State governments are smaller than the Australian national government, but the state’s economy and people have the resources to do the same thing Australia did.

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