# Photovoltaic shingles and roof access pathways



## eric fried (Apr 23, 2020)

Tesla and a few other companies make a roof shingle that has an integral solar PV module. When you interconnect the shingles and run the appropriate wiring, the whole roof covering works as a solar array. My question is do they need to provide access paths to the ridge and setback from the ridge per 2018 IRC Section R324.6, or (as Tesla reps contend) is this product exempt because there is nothing above the roofline to present a tripping hazard.

PV shingles are called out in Section R324.5, and have to meet the requirements of R905.16 as a roof covering as well as the requirements in 324. R324.6 calls for pathways AROUND modules, but these shingles cover the whole roof and therefore access is THROUGH the module. Even though some shingles are active and some inactive, they are indistinguishable. I see no exception for PV shingles in R324.6.

I believe a change was made to the 2021 IRC that may resolve this problem, but I am not sure what the final code language says. In any case, that will not be in effect until 2022, absent a code modification approval to allow the use of 2021 code provisions now.

I would love to hear from other code officials who have either approved or rejected the installation of this product, and what your reasoning in.

PS - I am aware of the issue of Tesla solar modules catching fire far more often than the average PV module, which is related but distinct from this issue. I'm not sure if Tesla has installed their solar shingles in any states but California, perhaps because of this code issue. Maybe the California Building Code or state law has some workaround that allows this installation.


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## e hilton (Apr 23, 2020)

My guess is that the tesla shingles are designed to be walked on, whereas normal modules are not.  But i can see that it might not be a good idea to be walking on something that produces electricity, could shatter like tempered glass from a just-right strike, and might be slippery as glass when wet.


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## cda (Apr 23, 2020)

eric fried said:


> Tesla and a few other companies make a roof shingle that has an integral solar PV module. When you interconnect the shingles and run the appropriate wiring, the whole roof covering works as a solar array. My question is do they need to provide access paths to the ridge and setback from the ridge per 2018 IRC Section R324.6, or (as Tesla reps contend) is this product exempt because there is nothing above the roofline to present a tripping hazard.
> 
> PV shingles are called out in Section R324.5, and have to meet the requirements of R905.16 as a roof covering as well as the requirements in 324. R324.6 calls for pathways AROUND modules, but these shingles cover the whole roof and therefore access is THROUGH the module. Even though some shingles are active and some inactive, they are indistinguishable. I see no exception for PV shingles in R324.6.
> 
> ...





Welcome

You do know your first question is not supposed to be a brain burner!

How long have you been coding?


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## cda (Apr 23, 2020)

Not seeing any exceptions


https://icc-es.org/wp-content/uploads/report-directory/ESR-4074.pdf


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## cda (Apr 23, 2020)

Under the 2015 and 2012 IBC, installation must comply with the applicable requirements in Section 605.11 of the International Fire Code® (IFC


The out??


Roof access, pathways and spacing requirements need not be provided where the fire code official has determined that rooftop operations will not be employed


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## ADAguy (Apr 24, 2020)

Consider their slip resistance and provide tie-offs for sloped roofs.


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## eric fried (Apr 24, 2020)

cda said:


> Welcome
> 
> You do know your first question is not supposed to be a brain burner!
> 
> How long have you been coding?


cda guy I started as a building inspector trainee in 1992 and am currently am a Building Official in Colorado. I know this is a difficult question: that's why I'm seeking the group's advice.


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## eric fried (Apr 24, 2020)

cda said:


> Under the 2015 and 2012 IBC, installation must comply with the applicable requirements in Section 605.11 of the International Fire Code® (IFC
> 
> 
> The out??
> ...


Yes, the same exception is found at 2018 IRC R324.6. But if the Fire AHJ does employ rooftop ventilation strategies, what then? How does a Tesla roof get installed without leaving 3' on each side and an 18-36" setback from ridge, depending on percentage of roof coverage?


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## cda (Apr 24, 2020)

Maybe this is part of the answer::


*How do solar shingles compare to conventional solar panels?*
Unlike traditional solar panel grids that were mounted a few inches above your roof, solar shingles replace your roof material. They're the same size and shape as normal shingles and can cover as much roof space as your home needs. Solar shingles are typically installed when other asphalt shingles on your roof need replacing.



https://www.solarreviews.com/blog/what-are-the-pros-and-cons-of-solar-shingles


Along with talking to the city about allowing total coverage.

Firefighters should stay off roofs


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## e hilton (Apr 24, 2020)

Surely tesla has non-photo panels than are used when the modular panel size doesn’t work out with the roof dimensions.  Fillers and end pieces.


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## cda (Apr 24, 2020)

Not into solar, except at the beach,,,,

But some houses, not every face might get sun???

So would you waste money on solar there?


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## ICE (Apr 24, 2020)

Solar shingles are a novelty that may never get legs.  It has been around for several years.  I’ve seen one bunch of detached condominiums that had them.  The state of California has enacted legislation that mandates that all new dwellings shall have solar.  That may spur interest in the shingles but, like all novel technology, people are reluctant to jump in until there is a proven history of success.

In the beginning of the solar boom many panel manufacturers went out of business when their panels failed.  As to how much of a roof might have solar shingles.....line side taps are limited to the ampacity of the service equipment...the roofs would be covered with solar.  I don’t know the efficiency but 200 amps coming from the roof is not out of the realm.  Today I had 120 amps of solar panels line side tapped to a 200amp service.

I think the concept of solar shingles is far superior to solar panels.  Every solar array has a beat up roof under it.  The entire system is made from aluminum.  None of the hardware was ever torqued and bare #6 wire is draped with much of it in contact with the aluminum.

If you work for Edison you might consider going back to school.......well next year.....maybe.


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## cda (Apr 26, 2020)

So the real question,,,,,

Has anyone seen a Tesla solar roof?


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## Pcinspector1 (Apr 26, 2020)

A little off topic but I had a solar company tell me you can walk on their solar panel when I asked for a walikway to some skylights. I couldn't believe that, they said they only had 7% tilt and you could walk on them. I requested a new layout with walking space to the skylight to meet the code and they abliged.

I got to believe the Tessa solar tiles will include some dummy tiles on the rakes and ridge to meet code requirements for fire personal and service.


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## ICE (Apr 26, 2020)

The only example that I’ve seen was a patch of solar tiles with Spanish clay tiles.  I’m not sure what brand they were and they didn’t look like Tesla glass roofing tiles.  There was no attempt at making it attractive.


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## Pcinspector1 (Apr 27, 2020)

cda said:


> So the real question,,,,,
> 
> Has anyone seen a Tesla solar roof?



No, haven't seen a Tesla solar roof or even a Solyndra panel.


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## mark handler (Apr 27, 2020)

*Tesla does not recommend customers walking on their roof.
https://www.tesla.com/support/energy/solar-panels/own/maintenance*


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## e hilton (Apr 27, 2020)

Thats a nice looking installation.  Of course they picked a nice one for the picture ... but it can be done.


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## my250r11 (Apr 27, 2020)




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## Pcinspector1 (Apr 27, 2020)

mark handler said:


> Tesla does not recommend customers walking on their roof.



Santa will have to use the front door I suspect.


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## mark handler (Apr 28, 2020)

Just like tile, slate or metal roofs,  firefighters will hate them.


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