Is a parking canopy a "building"

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gadfly56

Senior Member
Location
New Jersey
Occupation
Professional Engineer, Fire & Life Safety
Sorry, the definition of Building in the NEC is so broad that logically, every structure consists of one or more buildings.

If that is not the intent, the definition requires updating.

Cheers, Wayne

OK, I'm confused. Where are the "four walls" and "fire doors" in an open-sided parking canopy???
 

gadfly56

Senior Member
Location
New Jersey
Occupation
Professional Engineer, Fire & Life Safety
Where does the first part of the definition require walls or doors?

OK, I agree with others, the definition is useless. If I put a brick on top of another brick I have a "building". Pointless. Michelangelo's "David" would be a building.
 

GoldDigger

Moderator
Staff member
Location
Placerville, CA, USA
Occupation
Retired PV System Designer
OK, I agree with others, the definition is useless. If I put a brick on top of another brick I have a "building". Pointless. Michelangelo's "David" would be a building.
And the post holding a meter remote from the house would be both a structure and a building.
The only practical difference the rule seems to make is that it allows one structure to be more than one building.
The NEC definition should have been closer to the building code definition.
 

jaggedben

Senior Member
Location
Northern California
Occupation
Solar and Energy Storage Installer
I agree that the definition makes no sense. The question is how it affects the OP's question if you change it.

If it was changed to be like the IBC definition I would probably try to argue that a PV canopy is not a building. But it's certainly still vague.
 

SolarPro

Senior Member
Location
Austin, TX
If you go all the way back to the Cal Fire guidelines, which is basically what starts the ball rolling toward rapid shutdown, you get this:

Modules are mounted on buildings or on ground supported frames. Roof mounted modules, also sometimes known as panels, can be one of these types:

• Directly on a building’s roof
• Integral to the roof system of a building
• On a rack with a space above the roof surface
• On a freestanding structure but not on the habitable structure (such as a trellis or other free-standing support structure)

4.0 NON-HABITABLE BUILDINGS
This guideline does not apply to non-habitable structures. Examples of non-habitable structures include, but are not limited to, parking shade structures, solar trellises, etc.
 

jaggedben

Senior Member
Location
Northern California
Occupation
Solar and Energy Storage Installer
For sure fire access paths are not required in California on a solar canopy. It's certainly confusing that the NEC doesn't exactly meld with that though. Makes you wonder if a proposal to add 'habitable' to 690.12 would pass the CMP.
 

pv_n00b

Senior Member
Location
CA, USA
To reiterate:

  • All buildings are structures
  • Not all structures are buildings

A shade canopy is a structure, but it does not have to be a building, depending on your definition of building. Draw the Venn diagram.

A better definition of building in the codes would be helpful, most likely why there is not one is that a building means so many different things to many people and no code making group could decide on a specific definition that made everyone happy. It's left up to the AHJ to define in their area. In my experience most AHJs would not define a shade structure as a building but there are always going to be a few that do.
 

ggunn

PE (Electrical), NABCEP certified
Location
Austin, TX, USA
Occupation
Electrical Engineer - Photovoltaic Systems
A parking canopy is not a building. I will continue to not consider them as such until an AHJ says different, and then I will only treat them as buildings in his jurisdiction if I choose to continue to do business there.
 

wwhitney

Senior Member
Location
Berkeley, CA
Occupation
Retired
To reiterate:

  • All buildings are structures
  • Not all structures are buildings
Under a reasonable definition of building that is true.

Under the excessively broad NEC definition, every structure is one or more buildings. Either the structure stands alone (one building), or it is divided up via fire walls with fire doors (more than one building).

Regardless, even the IBC definition would recognize a carport or parking canopy as a building. Parking is a use, and a canopy is sheltering it.

Cheers, Wayne
 

jaggedben

Senior Member
Location
Northern California
Occupation
Solar and Energy Storage Installer
Sheltering is debatable if it provides no protection from wind and is not designed to ensure that no water drips from between rows of solar panels when it rains.
 

gadfly56

Senior Member
Location
New Jersey
Occupation
Professional Engineer, Fire & Life Safety
Sheltering is debatable if it provides no protection from wind and is not designed to ensure that no water drips from between rows of solar panels when it rains.

I was under the impression that we were talking about a stand-alone structure for residential use that covers one or maybe two vehicles.
 

jaggedben

Senior Member
Location
Northern California
Occupation
Solar and Energy Storage Installer
I was under the impression that we were talking about a stand-alone structure for residential use that covers one or maybe two vehicles.

That's possible, but somewhat more likely we're talking about about something like this or this. (Just a couple quick results from google images, there are many many more possibilities of all sizes.)

Regardless, I think it's debatable, especially if the structure is built primarily to support the solar rather than to provide shelter. Of course, as has been established, this matters only to the IBC definition, so unless the NEC definition were to be changed it's somewhat moot.
 

SolarPro

Senior Member
Location
Austin, TX
Here's another way of looking at this. The goal of rapid shutdown is to allow first responders to respond to a "structure fire"—which in this context means a fire at a residential, commercial or industrial building (look it up)—without having to worry about energized PV system conductors outside the array area. The goal isn't to protect the PV array support structure (the mounting and racking system) but rather the building that hosts the PV system.

Where a structure is only used to support a PV system, compliance with 690.12 provides no real benefit to first responders. Fire fighters will not fight a fire within the area of a PV array. This is fire fighter training 101. Even at night, the array and any metal parts it comes in contact with could be energized simply due to street lights or car lights. Assuming a PV system is built to meet NEC 2014 requirements for dc-arc fault protection and advanced ground-fault detection, an AHJ can't make a PV carport "safer" by requiring rapid shutdown.
 

iwire

Moderator
Staff member
Location
Massachusetts
Here's another way of looking at this. The goal of rapid shutdown is to allow first responders to respond to a "structure fire"—which in this context means a fire at a residential, commercial or industrial building (look it up)—without having to worry about energized PV system conductors outside the array area. The goal isn't to protect the PV array support structure (the mounting and racking system) but rather the building that hosts the PV system.

Understood, but consider this. Car fires are common and do you think firefighters would not want to shut down the power that could very well be supplying equipment (PV or otherwise) mounted to the structure during the fire and the fire fighting?
 

SolarPro

Senior Member
Location
Austin, TX
I've read a lot of fire service reports related to PV systems and attended a lot of training and never seen or heard a reference to the scenario you are describing. Wild fires could burn through a PV power plant, but the fire service isn't asking for rapid shutdown for these ground-mounted systems, some of which shelter goats (in the sense that the have goats on site to keep the weeds down.) Fire fighters want rapid shutdown for roof-mounted systems on homes and businesses.

New Code requirements aren't handed down from some infallible entity. They are developed by industry stakeholders and put through a committee-based sausage grinder. The result is always open to misinterpretation.

In this case, you can learn a lot about the intent of 690.12 by reviewing the CAL FIRE guidelines and then seeing how these recommendations are subsequently codified in the I-Codes as well as NFPA 1 and NFPA 70. This 6-year conversation (starting in 2008 and leading up to NEC 2014) is exceptionally well documented. The scope of the conversation is clearly defined at the outset.

4.0 NON-HABITABLE BUILDINGS
This guideline does not apply to non-habitable structures. Examples of non-habitable structures include, but are not limited to, parking shade structures, solar trellises, etc.

5.0 GROUND MOUNTED PHOTOVOLTIAC ARRAYS

Setback requirements do not apply to ground-mounted, freestanding photovoltaic arrays. A clear brush area of ten feet (10’) is required for ground mounted photovoltaic arrays.

I have never seen or heard anything that suggests the fire service has changed its opinion and now wants rapid shutdown for stand-alone solar carports or ground-mounts.

It seems to me, that if a Fire Marshall or other AHJ wants rapid shutdown at a solar canopy, they should also require complete fire alarm and sprinkler systems. How can you logically apply one set of standards and not the other?
 

Smart $

Esteemed Member
Location
Ohio
Understood, but consider this. Car fires are common and do you think firefighters would not want to shut down the power that could very well be supplying equipment (PV or otherwise) mounted to the structure during the fire and the fire fighting?
Nowadays even possibly charging the cars. :happyyes:
 

Smart $

Esteemed Member
Location
Ohio
I've read a lot of fire service reports...
As I mentioned earlier, we can debate whether a parking canopy is a building. We cannot debate whether RSS is required for a PV System on, or even as a building. For that, a proposed change in Code is required. We can debate text to propose the change all day if you want... but it will not change existing Code.
 

SolarPro

Senior Member
Location
Austin, TX
PV on a building ≠ PV as a building.

If you'd like the code to read differently, take it up with the CMP. You can get that proposed for NEC 2020.
 

wwhitney

Senior Member
Location
Berkeley, CA
Occupation
Retired
If you'd like the code to read differently, take it up with the CMP. You can get that proposed for NEC 2020.
I have no stake in the matter, I'm just pointing out that the 2014 version of 690.12 does not exempt non-habitable buildings from RSS. In fact, it applies to all structures, although the requirements are null for a structure without any wiring "inside" (690.12(1)).

So if the 2017 version of 690.12 still concerns you in this regard, I agree, you should submit a code proposal for 2020.

Cheers, Wayne
 
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