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Introduction
Solar Energy Industries Association (SEIA) is the national trade association for the solar and storage industry. Founded in 1974, SEIA works with its over 1,000 member companies to build a stronger solar industry. Our members represent all aspects of the solar and storage industry, such as residential contractors, manufacturers, and lenders, including contractors in Virginia.
The solar industry is built on the concept that consumers should have a choice about their energy portfolio, and we believe that consumers with complete and accurate information will overwhelmingly choose solar energy. There are over 5 million solar installations in the U.S., and the sector’s success requires a focus on the consumer experience.
SEIA’s efforts are built on the idea that every consumer should have a safe, reliable system that meets the expectations they had when deciding to go solar. SEIA has built a suite of programs and resources to help consumers navigate the solar shopping process, raise awareness amongst industry of their obligations, and develop official national standards in areas such as residential installations and salesperson training.
SEIA appreciates the opportunity to submit comments on guidance on addressing potential unknown costs related to installation of solar energy systems.
Potential Unknown Site Conditions
The Department recommends that contractors “provide a list of potential unknown site conditions to the customer that may increase the cost for roofing and ground-mounted systems.”
The Department should provide a list of common conditions that result in additional work or cost. The draft could be read to require contractors to provide a list of common and rare site conditions. A Commonwealth published guide would facilitate such disclosures.
Roof Age Assessment
Section 1(a)(i) suggests that contractors inspect the roof to assess the “life of the shingles.” The remaining life of the roof depends on many factors, such as weather events, homeowner wear and tear, and the quality of manufacturing. Assessing the impact of these factors on the useful life of the roof is impractical.
There are feasible steps contractors can take to understand the age of the roof, such as asking the customer when the roof was installed. As a result, SEIA suggests that DPOR amend Section 1(a)(i) to read:
a. For systems that will be mounted on a roof, inspection should include:
i. The roofing system, including condition of structure, load, and age of the shingles
Asphalt Shingles
As part of the pre-installation inspection, DPOR recommends that contractors “develop a plan for mounting and drilling to avoid shingle penetration that would void an asphalt shingle warranty.” (Section III(1)(a)(i)(1))
There are usually two separate warranties regarding rooftop work:
Manufacturer's material warranty which normally covers defects in the shingles themselves,; and
Roofing contractor's workmanship warranty covering errors made when installing the roof
As a general rule, attaching a system to a roof does not automatically void every shingle warranty. Many asphalt shingle manufacturers, like GAF and CertainTeed, allow for rooftop solar systems when the installation is conducted in a certain manner.1 For instance, roofing manufacturers require flashing and sealing according to approved roofing practices to preserve the manufacturer’s warranty. Roofing manufacturers may also provide letters to confirm whether solar panel racking systems, which are attached to the roof, are compatible with the manufacturer's products.
Before installation, contractors should ask for the roofing warranty document, review the roof’s condition, and determine the proper flashing and attachment method in accordance with industry and manufacturer standards.
Moreover, installers may wish to consult UL 2703A which addresses flashing materials, devices, and systems to prevent water penetration. While UL 2703A does not address a roof’s structural integrity, it serves as a useful quality assurance resource.
In addition, DPOR should amend Section 1(a)(i)(1) to read:
“The contractor should develop a plan for attaching a system in a manner that would not void relevant roof warranties.”
Other Guidance
DPOR may wish to point contractors to the ANSI/SEIA 201 standard which addresses residential and small commercial installations, including system design and site assessments.2
This national standard was developed under the American National Standards Institute’s (ANSI) mandated processes and approved by ANSI in 2025.
Thank you for the opportunity to comment on this draft guidance document.