Considerations for Continuing Permitting and Inspection Activities During COVID-19

Building departments across the country are faced with the challenging question, “Do we shut down or do we stay open?” Fortunately, there are options that allow continued safe operation of building department staff while ensuring safety of installations.

SEAC has collaborated with its diverse stakeholders including building officials and solar/storage construction industry professionals to provide options to building departments for continuing the important work of processing permits and inspecting completed projects. 

The options detailed below are suggested for consideration by Authorities Having Jurisdiction (AHJs) to determine the best path forward. 

Background

Large portions of the US population are facing “stay at home” orders. The Department of Homeland Security and most state authorities have classified the construction industry as an essential service allowing for continued AHJ and industry activity. 

There are many AHJs practicing no-touch permitting and a growing number utilizing remote video inspection for a broad range of construction projects. Each AHJ must establish which projects are suitable for this approach. 

As an example, LA County California’s virtual inspection program is available for 14 different types of construction including:

General Considerations 

• Make permitting and inspection information easy to find online 
  • Provide informational guidance on no-touch permitting and remote video inspection processes on your AHJ website.
• Establish a method for posting and keeping records that can be accessed by remote employees
  • Many AHJs have already set this system up for daily operations.

Considerations for Permitting Installations

Permit application drop-off

• Using a physical drop box at the jurisdiction can minimize transmission of COVID-19 compared to in-person drop-off. However, any physical document processing should be managed in a manner that will minimize the risk of virus transmission.
  • Avoid drop-off processes that require lines or congregation of people.
  • Consider a waiting period before handling paper documents after drop-off.

No-touch permitting through electronic permit applications

• Accept permit applications through email or use a web portal. These submission methods are already a common occurrence for many AHJs.
• Use Dropbox or Google Drive for the transfer of large files to AHJ.

Remote permit processing

• Permit Techs and Plan Checkers working from home can review applications and issue permits or corrections via email or their online platform.
• Corrections to plans can be made to PDFs using the “comment” function (a standard feature in Adobe Acrobat) or listed in the body of an email.
• Allow application fees to be paid virtually – flexibility in payment options will help.
• Accept payments via credit card, bank transfer, PayPal, Venmo, etc. online or over the phone – consult your water department or property tax collection department for assistance in setting up these systems.
• Accept checks via mail.

Considerations for Performing Inspections

On-site INTERIOR inspections

• This method may increase the risk of infection, so we encourage consideration of remote inspections for all interior inspections. 
• NOTE: an open garage or open space may be considered for an interior inspection, but enclosed conditioned space might not be sensible at this time.
• When critically necessary on-site interior inspections are performed, the inspector should employ CDC guidelines for minimizing the likelihood of virus transmission.

On-site EXTERIOR inspections

• The inspector must assess the site for compatibility with social distancing guidelines.
• Since most exterior inspections do not require close human interaction, exterior inspections can likely be conducted while maintaining CDC guidelines for minimizing infection transmission.
• Leave the plans and documents in an accessible location for inspector access, and follow CDC guidelines for minimizing virus transmission.

Remote inspection (AKA virtual inspection)

• Allow inspections via live video
  • This can be done using a smartphone or tablet with Zoom, FaceTime, WhatsAPP, Google Hangouts, Google Duo or another video application.
  • Many AHJs have implemented remote inspection. These AHJs include: Arlington County, VA; City of Austin, TX; North Carolina Code Officials Qualification Board; City of North Las Vegas, NV; Los Angeles County, CA; San Bernardino County, CA; City of Glendale, CA; City of Anaheim, CA; City of Cupertino, CA; San Mateo County, CA; City of Sacramento, CA; City of Oceanside, CA; County of Sonoma, CA; City of Irvine, CA; and many more. 
  • Here are some examples of remote inspection information from Los Angeles County, New York State, and North Las Vegas.
  • More information on remote inspection can be found at the International Code Council’s Coronavirus Response Center.
• Establish criteria for determining which projects are suitable for remote inspection and how to perform inspection. Suggested criteria include:
  • The type of inspection should be verified by the inspector to be acceptable for remote video inspection.
  • The applicant should have a valid active permit.
  • Staff should have sufficient skills and knowledge to use remote video inspection; training is important. For more detailed information on this topic, watch the webinar Continuing Safe Permitting and Inspection Practices During COVID-19 hosted by SEAC and its partners. (You will need to register using the link in the upper right corner.)
  • The person onsite needs to show evidence they are at the correct job site address or location during the inspection. 
  • Equipment to help facilitate remote inspections includes: smartphone, iPad or other tablet, or a laptop with a webcam, flashlight, level, tape measure, and any other specialized tools or equipment needed to facilitate a proper inspection (e.g., screwdriver, torque wrench, ladder, etc.).
  • Both the inspector and the person onsite need to have adequate cellular bandwidth and adequate video quality to allow an effective video inspection.
  • Be aware that VPNs (Virtual Private Networks) may dramatically reduce bandwidth. Disabling VPNs during the remote inspection process can improve video quality.
  • An inspection checklist is very helpful.

Additional information that may assist in streamlining solar permitting and inspection processes

• Webinar discussing the no-touch permitting and inspection options: Continuing Safe Permitting and Inspection Practices During COVID-19, jointly hosted by IREC, the Sustainable Energy Action Committee (SEAC), and the International Association of Electrical Inspectors (IAEI) in partnership with the California Solar and Storage Association (CALSSA)
• The International Code Council’s Coronavirus Response Center
• Findings from a survey by the International Code Council of over 1000 building and fire departments on how code officials are coping with the professional challenges brought on by the COVID-19 pandemic, released April 2, 2020
  • Infographic of the survey results 
• Consider a one-page permitting application for permitting smaller residential projects allowing for a simplified and fast online approval. Here’s an example of the residential solar permitting application from the City of Oceanside.
• Guidance For Remote Video Inspection (RVI) from the National Fire Protection Association (NFPA) 
• NFPA Blog Article: Implementing Remote Video Inspections: 12 Key Lessons 
• NFPA 915, the “Standard for Remote Inspections,” is under development
• CA Solar Permitting Guidebook, developed by California’s Solar Permitting Task Force. Streamlined permitting process requirements for California AHJs for residential PV systems including submittal requirements, eligibility checklist, standard plans and inspection guide.
• The Solar Energy Industries Association’s (SEIA) COVID-19: Resources for the Solar Industry,  which includes recommendations for remote building permit approvals, results of a survey on the current status of solar permit processing and inspection around the country, and a survey form where you can submit data on your jurisdiction. 
• The California Solar and Storage Association’s (CALSSA) COVID-19 Resource Center including a blog post, permitting database, and information on upcoming virtual trainings. 
• SolarAPP, a DOE/NREL-funded program to develop an instant, online solar permitting tool for code compliant residential systems. AHJ partners are currently being accepted to test the beta version.

Gwen Brown

Gwen Brown is IREC's Communications Director. She works to promote awareness of IREC’s programs and successes.