Bus Shelter PV System & listed LED lights

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BillK-AZ

Senior Member
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Mesa Arizona
I have a contract with a city in Arizona that has many PV powered bus shelters. The job is to refurbish the lighting system and restore operation. There is a mix of older RV fluorescent 12 VDC fixtures and some newer LED fixtures. The city wants to replace batteries, some PV modules (no problem so far) and install vandal resistant LED lights. None of the shelters were subject to building permits or other approval by the AHJ.

The show stopper now is the AHJ insisting on approving the design and materials. The RFP for the project included a product sheet for a small rugged LED fixture and no claim of any listing for the fixture. The RFP also used the words "or equivalent". No mention in the FRP of any AHJ approval being required and none was involved in past installations. There is also a PE representing the city.

We submitted a list of proposed components including an equivalent 'brick' LED fixture that is simply 36 white LEDs cast into a solid clear acrylic block with wire leads and two mounting holes very similar to the LED fixture illustrated in the RFP and made part of the contract by reference. No ballast is required when operated from a nominal 12-V battery system. The PE approved the LED fixture as equivalent and sent the list on to the city project manager.

The AHJ is now in the loop and has rejected the submitted LED fixture as not meeting Art 411.3 "NEC 411.3, lighting systems operating at 30 volts or less are required to be listed as a system or be an assembly of listed parts."

The problem is a lack of listed suitable fixtures. An updated product sheet by the company referenced by the RFP carries a 'UL' symbol, but when asked for explicit information to support a submission of the DC LED fixture, the company states that the LED is not listed as a DC fixture and is only listed when included with their AC powered shelter lights when used with the included AC power supply that is listed. Some of these LED fixtures have been in service in shelters for years, but the AHJ simply states that they should be replaced.

That set off a search of all available suitable LED fixtures to see if any were listed. A further requirement is 6-watts or less in order to be powered reliably from the existing PV systems. None were found. The only listed light is a complete LED/control/battery/enclosure system that is four+ times the cost and not in a suitable shape for the existing shelters.

There is now an impasse, The AHJ still insisting on a listed LED, the PE and contractor being unable to identify anything that is suitable and listed. In the past when there was a code question and the PE of record made a formal recommendation, the AHJ accepted the PE's decision as that implied assumption of liability.

Any suggestions on resolving the situation or of suitable fixtures?
 
Perhaps an appeal to the City Council? In most places, the City government is the AHJ. Appeal to the City government, presenting the issue as something like: "This solution will be a great thing for the city because the lights are needed for safety, they will be attractive visually, they're strong and will stand up to the abuse of being in a public bus shelter, they're extremely efficient (i.e. "green"), blah, blah, blah. Unfortunately, the City Inspection Department is insisting that the light also has to be listed with UL. There is currently no light on the market which meets all of the requirements of this project and is also UL listed--it doesn't exist. We are asking for the Council to instruct the Inspection Department to waive the UL requirement for this project."

Or, tell the City that if they want a listed fixture for this project, they're going to have to pick a fixture and pay for testing/listing. I've seen customers do that before, when it's something they want badly enough.
 
By AHJ I suspect you really mean inspector. He has no say so in most cases as to what exceptions can be made. The actual AHJ almost always has a process where they can approve a deviation. Find out what entity that is and how you can request such a variance and ask them.

in most cases the PE also has no say in the matter and the inspector has no authority to accept what the PE is offering if it is not compliant.
 
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