Consumer Protection For PV Systems — Finally In The Limelight

May 22nd, 2017 by Guest Contributor

By Peter F. Varadi

More than 1.4 million homes in the U.S.A. are currently powered by solar, and 3 million additional households are estimated to install PV systems by 2021. Therefore, the Solar Energy Industries Association (SIEA) launched a timely educational campaign for consumers to understand the fundamentals of solar, to ask the right questions from the representatives of solar system installation companies, to compare the offers of solar companies, and to know how much electricity to expect from their PV system over the years. These guidelines also help consumers to understand the terms and costs of purchasing or leasing and of purchasing power from a solar electric system. SEIA also developed simple and understandable disclosure forms covering the full spectrum of residential transactions so that consumers would be able to protect themselves from a vendor when ordering a PV system to install on their property or for their community. SEIA’s president and CEO Abigail Ross Hopper said: “Solar is still a new power choice for millions of Americans, and it’s critical that we cultivate a well-informed customer base. By doing their homework and making use of these tools, consumers and stakeholders alike will feel confident and comfortable in the decision to go solar.” With these developed forms, SEIA achieved an excellent and extremely needed step forward in consumer protection for those 3 million additional households installing PV systems in the next 4 years.

The SIEA disclosure forms also advise consumers what information to request about system repair and maintenance, roof warranty and system guaranty. These well-constructed sections are extremely helpful for the consumer to select an installer and to obtain the best and least expensive solar roof for their home. But these sections of the disclosures form do not include what information consumers should ask to protect themselves from the frightening possibility that the guarantor – the installer – goes bankrupt or just simply goes out of business. Unfortunately, this is not a theoretical possibility.

Over the past year the number of home owners obtaining loans to buy their PV roof system has increased, and the business is shifting from large installers to regional and local installers. The financial stability of those is usually not very strong, and some of them may go out of business before their guaranty ends. This can happen not only with small regional or local installers, but also with national installers. Sungevity and Verengo Solar went bankrupt, and the very large NRG Home Solar informed people lately on their web site: “We are not offering new installations at this time, but we continue (for how long?) to serve our existing customers.” From this it is evident that bankruptcy etc. of installers is not a theoretical possibility but a real problem that many of the 3 million households who choose to power their home with solar in the next four years could face.

If the installer becomes bankrupt or goes out of business the guarantees given to the consumer become worthless. If thereafter the PV system develops a problem, the consumer will have to get it repaired on his own money. In general, the repair of the PV system is easy and not too expensive; however, the consumer will face a very big financial expense if the installer used low quality PV modules which stop functioning and must be replaced. As it is well known low quality PV modules are not fiction either.

To protect the consumer, SEIA’s disclosure forms should also include a request that the Installer provide the PV module manufacturer’s name and address and the type of module the installer will use for the solar system. It should also state the life expectancy and the power degradation during the life of the PV modules guaranteed by its manufacturer. Reputable manufacturers guarantee the solar module performance to produce a certain amount of electricity and its yearly degradation for 20 or 25 years. This information is needed to enable the consumer to go directly to the manufacturer if the installer goes out of business.

But to know the name of the manufacturer of the PV module is only one step forward to protect the consumer. Most consumers would not know which PV manufacturer is reputable, so the disclosure should have additional questions: “Was the PV module tested for quality and for safety?” If yes, “To what standards were the PV modules tested?” The answer to both questions is simple. The answer to the first question is either yes or no. This answer is clear to the consumer. The second is also simple to answer: 1) Quality: the PV module quality was tested to: IEC 61215 (or a newer version) and 2) safety: the PV module was tested to UL 1703 standards. This answer for the consumer is like it would be written in the Martian language. However, the PV industry needs to interpret this answer for the consumer as is done in many industries that have made it easy to recognize that a product successfully completed the required testing. These industries for this reason established “Quality Marks” (QM) to be displayed on the qualifying product. The consumer knows those Quality Marks, and seeing the QM displayed on the product indicates to them that the product’s quality and safety was tested according to the standards relevant to that product.

The disclosure form should ask if the UL safety QM is displayed on the utilized PV modules sold in the U.S.A. The answer to this question should be YES. If the answer is NO, obviously, the PV module may not be safe to use. The Underwriters Laboratory QM is well known to consumers, and they can recognize its QM:

It means that the product was successfully tested for safety, and the production was supervised by the Underwriters Laboratory.

The disclosure form should also ask if the PV Quality Mark is displayed on the PV module to be used. In the space for the answer it should be written: “PV QM presently is not available.”

Despite that the PV QM does exist, it is not being used. It will surprise people that SEIA, the European EPIA, and the Japanese JEPA supported the establishment and promotion of the “PV Quality Mark” which was introduced in 1996:

The reason it is not being used now is because several years later, after the year 2000, the PV Quality Mark was abandoned by SEIA, the European EPIA and the Japanese JEPA. Despite this abandonment, surprisingly, the PV Quality Mark still exists and is available, and its reestablishment would be extremely important for consumer protection. As the requirement that a PV module (or product) should be able to display the PV QM does exist, the re-introduction of its use would be simple. The story of its establishment, subsequent abandonment, and that it is still available and could be easily re-established is the following:

The prerequisite for a PV QM is that a PV module quality standard should exist. The PV module quality testing standard was developed in the U.S.A. In 1975, the U.S. government initiated a terrestrial PV research and development project, the aim of which was to help the terrestrial PV industry to reduce prices and produce reliable PV modules. That was the famous “JPL (Jet Propulsion Laboratory) Block program.” Its design and its execution were crucial for the utilization of PV solar energy to become a success. In retrospect, this was one of the most important and useful government-sponsored PV programs, because without this program the expected failure of the PV modules would have destroyed the image and usefulness of PV.

Manufacturers selling PV modules to the JPL program were forced to adapt a “Quality Manufacturing” system which required periodic product retests and inspections, a forerunner of the presently used global ISO 9000 system which was started only 10 years later. This system also required the production of the PV module to a standard established by JPL, which became the basis of the International Electrotechnical Commission (IEC) globally adapted PV module standard used today. The JPL program ended in 1985. The U.S. government never continued it. Furthermore, the U.S. government never instituted buying only products which were manufactured using a quality management system and tested to the JPL PV standard, as it did with the military “MilSpec” program.

The PV industry learned the JPL testing and manufacturing system and during the first decades realized that delivering high quality, reliable PV modules was advantageous for the industry and essential to get the confidence of customers. Failures would be detrimental for PV manufacturers. Therefore, as they did for the JPL program, they tested every module they sold.

In the 1990s the situation changed. Many new PV cell/module manufacturers started, and to compete and sell cheaper, they cut corners. To cut cost they abandoned testing, and the quality of their products became poor. That was the time when the quality manufacturers in the U.S.A. formed PowerMark Corporation to develop a PV certification system that customers should be able to differentiate between PV products manufactured using a quality management system and tested to the existing international standard from those which were not. Shortly after PowerMark started to work on a PV certification standard I had a meeting in 1995 with Charlie Gay who was the head of National Renewable Energy Laboratory (NREL) and supported very much PowerMark’s effort and agreed that PV certification program should be global involving also Europe and Japan. He asked me to try and to arrange this as I had excellent relations with key PV people in those areas. With the help of Wolfgang Palz of the EU Commission and Heinz Ossenbrink head of the PV program at the European Central Research Laboratory in Ispra Italy that PV trade associations SEIA in the U.S.A., the European EPIA, and the Japanese JEPA, supported the development and promotion of the PV certification system and the “Photovoltaic Global approval Program” (PV GAP) was started. The “PV Quality Marks” were established in 1996. This story is described by John Wohlgemuth:

“In 1996 a “PV Quality Mark” system was established which is now operated by International Electrotechnical Commission of Conformity Assessment Schemes for Electrotechnical Equipment and Components (IECEE). The IECEE system for PV modules and components included product certification under IEC 61215 (or other relevant IEC standards) and IECEE certification of the manufacture’s quality management system (e.g., ISO 9000). The system also had requirements for periodic product retests and inspections. PV products qualified under the system could display a “PV Quality Mark” that customers should be able to distinguish them from untested and probably less reliable products. Initially several PV module manufacturers, including Solarex, TATA BP Solar (renamed recently as Tata Power Solar Systems Ltd.), ASE (Applied Solar Energy GmbH) and Websol (India), obtained IECEE certification on their products and displayed the “PV Quality Mark” on the product.”

The German Feed in Tariff (FiT) was first introduced in 2000, but after the second version was established in 2004, the “solar rush” started, and solar cell and module manufacturers and PV installers appeared like mushrooms after rain. The demand for PV modules became so great that some of the installers were buying anything which had only the PV module “look”. The PV Quality Mark system was abandoned because governments did not specify that only “quality” products could be used for government-supported projects. This is especially true in Germany, where the government did not specify that for customer protection only PV products with “Quality Mark” would qualify to participate in the FiT program despite the fact that in 2004 about 25% of the modules offered were untested. Only the World Bank supported the IECEE quality system and recommended that in the programs they supported, IECEE approved PV products should be used. Even in 2012 the situation was not better.

Today the situation is not that bleak. PV certification is taken seriously by the PV industry and government agencies participating in the IEC PV committee, and SEIA is doing what industry associations usually not do, launching a PV consumer protection program.

One of the reasons the “PV Quality Mark” program was not promoted properly because when it was transferred to IEC it was put under its existing IECEE program which was established by IEC for certification of many products, e.g. refrigerators, washing machines etc. The “PV Quality Mark” established by SEIA, EPIA, and JEPA was transferred to IECEE, therefore only very little attention was given to PV certification and QM.

After hard work by the NREL members of the IEC’s PV standards committee (TC-82), finally in 2016 IEC established IECRE, (RE=Renewable Energy) Conformity Assessment Scheme for Renewable Energy (including PV), and the PV certifications were transferred from IECEE to IECRE. It was anticipated that the applications for the first certifications would be made during the second half of 2016. However as of now, the “PV Quality Mark” is not yet transferred to IECRE. At present it is available free of charge still only from IECEE. (http://www.iecee.org/about/photovoltaics/).

The next step would be to also transfer the PV QM to IECRE, and manufacturers could obtain it after they received the PV certification from IECRE.

Conclusions and Recommendations

To protect consumers planning to install a PV system on their home or in their neighborhood from the event the installer becomes bankrupt or goes out of business, the SIEA disclosure forms should be amended:

Provide the PV module manufacturer’s name and address and the type of module the installer will use for the solar system. State the life expectancy and the power degradation during the life of the PV modules guaranteed by its manufacturer. Was the module tested to the quality standard IEC 61215 (or a newer version)? Is the PV Quality Mark displayed on the module? Was the module tested to the safety standard UL 1703? Is the UL quality Mark displayed on the module?

The answer to 4) will be “PV QM presently is not available.” until the PV Quality Mark will be transferred to IECRE and it will establish the procedure by which the PV manufacturer can obtain it. Both of these actions should be accelerated.

For consumer protection it is also important that after the “PV Quality Mark” is available PV modules without the UL and “PV Quality Marks” and proper certification documents could not be imported into or installed in the U.S.A.

http://www.seia.org/news/seia-launches-national-consumer-education-campaign Peter F. Varadi –Sun Above the Horizon – Chapter 27 – Pan Stanford Publisher – 2014 It is reprinted by permission from: Peter F. Varadi – “Sun Towards High Noon” – Pan Stanford Publisher – 2017 Sarah Kurtz (July 2016). Defining bankability for each step of a PV project using IECRE, Intersolar North America.

Peter F. Varadi is the co-founder in 1973 of SOLAREX Corporation, Rockville, MD (USA), which pioneered the utilization of solar cells (PV) for terrestrial applications. By 1978 it had become the largest PV Company in the world. After it was sold to AMOCO in 1983, Varadi continued to work as solar power consultant, first for SOLAREX, later for the European Commission, The World Bank, NREL, and many other organizations. In 2004, Varadi was awarded the European Photovoltaic Industry Association’s (EPIA) John Bonda prize. Varadi is the author of two books, “SUN Above the Horizon – the Meteoric Rise of the Solar Industry” published in 2014 and “SUN Towards High Noon – Solar Power Transforming Our Energy Future” published in 2017 (www.amazon.com).











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