Surveying Municipal PV Permit Fees
Background and Objectives

The Global Warming and Energy Committee (GWEC) of the Sierra Club's Loma Prieta Chapter began conducting its study of municipal permit fees for photovoltaic (PV) solar electric installations (a.k.a. solar panels) in the Summer of 2005. The study is ongoing and GWEC is continually expanding its geographic coverage. Other Sierra Club chapters have since contributed to the study.

The ultimate goal of the study is to increase the number of PV installations. GWEC bases this goal on the conviction that solar energy is one solution, perhaps the foremost, to the problem of Global Warming. Solar panels harness the renewable, inexhaustible power of sunlight to generate electricity without emitting any pollutants or greenhouse gases. The only real estate they require is our otherwise unused rooftops.

With this goal in mind, conducting a study on PV permit fees has the following merits:

  • High permit fees make the solar industry less competitive relative to conventional "dirty-energy" industries (e.g. coal, oil and natural gas).
  • Ranking permit fees from highest to lowest by city, and publishing this ranking via the news media, pressures municipalities to reduce their fees.
  • Permit fees are ultimately passed on to consumers. Usually they are a small percentage of the total cost of a PV installation. However, the most expensive permits cost as much as 7% of the total, which could dissuade some consumers whose commitment to the purchase is marginal. In the future, as the cost of the PV hardware declines, permit fees will become a greater part of the total installation cost.
  • GWEC's experience shows that, in the process of re-evaluating their PV permit fees, many towns also re-evaluate their permitting process. Often this results in towns streamlining the process to issue permits quicker, with faster post-installation inspections and fewer bureaucratic barriers to solar contractors. Ultimately, this time factor is even more important than fees in terms of how it affects the solar industry.

Requirements

To perform a study comparable to GWEC's, you need enough volunteers to:

  • Collect the study data—This involves finding contact information and contacting government officials by phone, letter or email.
  • Meet with government officials—This involves following up on the published survey by meeting with building department officials, city council members, or anyone else who can influence PV permit fees in the towns with expensive fees.

You will need volunteers with the following expertise:

  • Spreadsheet experience (e.g. MS Excel)—Once you collect all your data, you must store it in a way that makes it easy to track, update and convert into color charts. It's the charts that will best present the value of your study to news media.
  • Writing for the public—While not a necessity, it helps considerably for the study authors to have experience in writing for the public. Regardless of your study's other merits, journalists will not report it if is difficult, vague or boring.
  • Website creation and maintenance—Publishing your study online is a great way for news media, municipal governments and other interested parties to access it. Ideally, you should give access to the study online as an HTML page (for online reading) and as a PDF (to download and print).

If your volunteers lack expertise in certain areas, GWEC might be able to help.

Methodology

Conducting a survey of PV permit fees involves the following steps.

1. Decide the scope of your survey.

  • Customer base: Residential, business, or both

Considerations—Even within the same jurisdiction, PV installations for businesses vary considerably in terms of permit costs and requirements. Also, they tend to be fewer in number than residential installations (in most jurisdictions). Thus, determining a typical or standard business installation could be difficult, especially in small towns.

Recommendations—Limit your initial survey to residential installations. Consider expanding the survey to include business installations only if you have sufficient resources to pursue that issue and if numerous businesses in your area have such installations.

  • Number of municipalities covered in the survey

Considerations—You should have enough towns in your survey to make meaningful comparisons. If all the towns in your survey have high permit fees, or they all have low fees, a publicized ranking from highest to lowest will not make a great impression (i.e. it won't be a news story). The survey is most effective when you can compare very expensive towns with very cheap towns. However, note that you must start and complete your survey in a reasonable timeframe: the data should reflect a snapshot of what all the towns charge at a particular time (e.g. as of "summer 2007"). Consider whether you have enough volunteers to collect data for all the towns you want to cover in the survey. Some towns will be slow in responding. Moreover, the study is most effective when you can follow it up by meeting with city government officials in person. Officials are usually only willing to meet during regular business hours (9am to 5pm, Monday to Friday). Consider how available your volunteers are for such follow up work.

Recommendations—Be conservative in estimating how many towns you can include in your initial survey. If you find you have sufficient resources, you can always expand the survey later. If you include a particular county in the survey, include all the municipalities in that county, not just the ones with the cheapest or most expensive permit fees.

  • Type of PV installation: rooftop, ground-mount, or both

Considerations—Most PV installations are on rooftops. Ground-mounted installations vary considerably in terms of permit costs and requirements compared to flush-mounted rooftop systems due to wind loads, soil types, ground rack design, steepness of slope, etc. Thus, determining a typical or standard ground-mount installation could be difficult and comparing the permit fee to flush-mounted rooftop systems might not be relevant.

Recommendations—Limit your survey to flush-mounted rooftop installations or to a standard design for ground mounts, being careful when comparing permit fees for one type of system to the other.

  • Installer: professional (solar contractor), amateur (homeowner), or both.

Considerations—Solar contractors, not homeowners, perform most PV installations. Many building departments are more reluctant to issue permits for installations that the homeowner performs due to safety and other concerns. Those departments might have more stringent requirements, and therefore higher fees, for permits issued to homeowners. Therefore, including amateur installations could skew your data, particularly for towns that have a small number of total installations.

Recommendations—Limit your survey to professionally mounted PV systems.

2. Determine the survey question.

Considerations—Many towns use the valuation method to calculate permit fees. That means they base fees on a percentage of total project costs. Consequently, the fees will vary considerably among installations within the same town. PV systems are measured in terms of kW output: a 6kW system is twice as large as a 3kW system. You should base your survey question on a typical system (i.e. an average-sized system). For accurate comparisons, you must use the same survey question, referring to the same typical system, for each town that you survey. The survey question should also cover any other details that can influence the cost of a system (e.g. the type of roof, the height of the residence, system cost, system size, system weight, type of mounting, rebates, etc.).

Recommendations—Consider polling solar contractors in your area for their estimate of a typical PV system. GWEC used the following survey question.

"What is the total cost for a permit to install a 3kW solar electric system on a composite shingle roof of a single story residence in your jurisdiction (assuming the system cost is $27,000 before the California Energy Commission rebate and $18,600 after the rebate)?" (The system will be professionally installed, 320 square feet in size, and mounted flush to the roof with a weight load of 3 pounds per square foot.)

3. Define the specific fee amounts that you consider ideal, reasonable and expensive.

Considerations—By law, municipalities must base their fees on the costs to process the associated permits: i.e. they should not use permit fees as a means to generate revenue. Some do anyway. Note that costs tend to be lower for large towns, which can process permits using in-house personnel. Small towns often rely on third parties to process permits and inspect PV installations, which might increase their costs.

Recommendations—GWEC defines permit fees of $300 or less as ideal. Generally, GWEC does not try too hard to lobby towns whose fees are $500 or less. GWEC considers fees over $700 to be unreasonably expensive. GWEC gives more leeway to smaller towns that must rely on third-party solar processing/inspection agencies.

4. Collect contact information for the government officials whose towns you are surveying.

Considerations—In California, you can find the contact information of city leaders (e.g. mayors, city managers and head building officials) at the: League of Cities website. Other states might have similar websites. Otherwise, you can find contact information for a particular municipality at its official website. You will use the contact information to deliver the survey question itself and to follow up by meeting with city officials in person after you publish the study.

Recommendations: If possible, collect the name, email address and mailing address for the mayor, city manager and head building department official for each municipality in the survey. Also try to collect the phone number for each city manager and head building official.

5. Conduct the survey.

Considerations—Emails are a convenient way to reach city officials, but phone calls to the building department are more effective in eliciting a response. The survey questionnaire for the interviewee should include the following background information about yourself:

  • Your name, position (e.g. chairman of the Global Warming and Energy Committee of the Sierra Club, Loma Prieta Chapter) and contact information (phone number [daytime, evening and mobile], email address and mailing address).
  • On whose behalf you are conducting the survey (e.g. the Sierra Club, Loma Prieta Chapter). Note that cities might be more receptive if you present yourself as representing a non-profit organization instead of a solar contractor.
  • The survey purpose
  • The survey question
  • The deadline for a response

Recommendations—Begin contacting building departments after July 1st. Many cities revise their permit fees for the year by that date. You can simplify the survey process by using an online survey tool such as Zoomerang: http://info.zoomerang.com/. You can see a PDF file of one of the online surveys GWEC used at: http://www.solarpermitfees.org/SolarFeeSurvey2007July.pdf. As you receive response data, we recommend that you store them in a spreadsheet program (e.g. MS Excel) that you can use to create color charts. Note that if you periodically update your study, it's useful to record the data for each repeat of the survey: to show trends, etc.

6. Conduct the interviews. Pick one of the towns that are most challenging for solar contractors (i.e. high permit fees, lengthy permit process, inexperienced inspectors, etc.). Also pick one of the towns that are most solar friendly. For each town you picked, interview:

  • A building department official: e.g. the head official or the head solar inspector
  • A solar contractor: one who recently installed a PV system in that town
  • A solar customer: one who resides in that town

Considerations—Use the interviews to create a story to give your study a human-interest angle for news consumers. As much as possible, let the interviewees tell the story: quote rather than paraphrase them.

Recommendations: GWEC used the following questions for its interviews:

7. Author the study.

Considerations—The longer your study, the less likely people are to finish reading it. Cover all the information you need to but in as little space as possible. Wherever possible, rely on color charts to convey the importance of your data, even if doing so takes more space than presenting the data as numbers in a paragraph.

Recommendations—For an example, see the GWEC study.

8. Publish the study on your website.

Considerations— Once you select an URL for your study website, include that in the study. Note that once you publicize the study (i.e. notify news media and city officials), it is too late to change the URL on any hard copies you distributed.

Recommendations—Make the study available as a single HTML page (for browsing online) and as a PDF (for downloading and printing).

9. Follow up. For the cities with high fees, email the mayor, city manager and chief building department official to request that they review solar permit fees and reduce them to an affordable level (e.g. see our Letter_Requesting_Fee_Reduction). Your correspondence should include the chart ranking what each city in the local area charges for a solar permit. Two weeks later, call the head building official or city manager to request an in-person meeting to discuss the issue.

Considerations— Some city officials will be offended (and therefore harder to persuade) if you notify the news media before notifying them!

In-person meetings are more influential than phone calls. When you meet city officials, try to bring a variety of interested individuals to represent your party: e.g. the study authors, residents (of that town) who might want to buy solar panels, former city officials who are sympathetic to your cause, etc. However, bringing too large a crowd might make the city officials feel beleaguered (and perhaps less likely to negotiate). One to four people are ideal.

Ask what the process is to change the permit fee. The head building official might have the authority (according to California law) to change the fee structure. However, most cities require council approval. We advise against following up with individual council members unless they contact you first. However, if your case will be on the council agenda, it is appropriate to contact each council member a week or two before the council hearing. If possible, present your case in person at the hearing.

Usually building department officials from all the towns in a region meet periodically to discuss professional issues. If you can find the organization that arranges these meetings, it might let you present your study at a meeting. The International Code Council, an organization of building officials http://www.iccsafe.org/ is one such entity that might have a local chapter meeting where you can present your case.

Don't be discouraged if city leaders are initially reluctant to act immediately; that is often the case. Persistent communication and in-person meetings usually get results over a period of weeks (especially if the local newspaper does a story on that city's high permit fee).

Recommendations—When you meet with city officials, bring enough hard copies of the study for each official and each person representing your own party. Highlight those parts of the study that mention the city. Don't try to browbeat or threaten officials into reducing their fees; diplomacy works a lot better! And remember that it can take weeks or months to change a permit fee.

At the meeting, discuss key issues such as:

  • Fixed fees for PV permits: the valuation method is often responsible for the most expensive fees.
  • Over-the-counter permits: the time cities take to process permits (months, in some cases) has an even greater impact on the solar industry than the fee itself.

See the GWEC study for details on these topics: pv_permit_study.pdf.

If other city leaders are unresponsive, consider notifying the city attorney. California law requires cities to have minimal solar permit fees and mandates that these fees be no higher than recovery costs. California cities that base solar permit fees on valuation tend to have fees that are illegally high. If you are targeting a California city, consider attaching Assembly member Lois Wolk’s letter on minimal solar permit fees, sent to all cities in 2006, for extra impact (http://www.solarpermitfees.org/WolkPVFeeLetter.pdf).

10. Notify the news media with a press release a week or two after you notify the cities with high permit fees.

Considerations— In our experience, this type of study works best in the printed media. Put more effort into getting newspaper coverage than TV or radio coverage. Note that a newspaper might be less willing to report your study if another newspaper already has. Therefore, approach newspapers with the largest circulation before petitioning smaller ones.

Personal calls to journalists to pitch the story works best. Then follow up with an email that includes links to the online study and your press release. Do not bother notifying the electronic media. Just focus on big regional papers and local papers that cover the cities with high fees.

Include the ranking chart in the press release to show the wide variance in permit fees. You can find out which papers cover an area via the yahoo website: http://dir.yahoo.com/Regional/U_S__States/California/Metropolitan_Areas/.

You can also use the Sierra Club's local media list.

Recommendations—See an example of GWEC's press release at: Press_Release.pdf.

11. Update the study periodically.

Considerations— When a town reduces its fees in response to your efforts, the city officials really appreciate it if you update your online study (website and PDF versions) as soon as possible.

Recommendations— Consider communicating results to the Global Warming and Energy Committee of the Sierra Club's Loma Prieta Chapter (Kurt Newick is the lead on this: KurtNewick@yahoo.com); GWEC has web expertise and might be able to help generate publicity for your study.