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AB 2188 Assembly Bill-Bill Analysis Page 4 of 7 addressed if solar electricity generation is going to help the state address its growing energy needs. Research indicates that while the hard costs of solar, namely materials and components, have come down in price in recent years, soft costs, including the cost of local agency permitting and inspection process, are preventing solar energy systems from being more affordable to many Californians. The Governor's Office of Planning and Research has called for streamlining the permit process, including the development a checklist with expedited review as a best practice to continue to promote these systems. AB 2188 directs each city and county to adopt an ordinance tailored to the unique needs of their communities, to adopt best practices in the permit application, review and inspection process, to reduce costs, and promote solar electricity generation. 2. Home rule . Solar industry officials report that in recent years cities and counties have become more familiar with roof top solar electricity generation systems and that awareness, along with increased uniformity of those systems, has led to dramatic reductions in permit processing and inspection times. Over time, more cities and counties will adopt best practices based on the needs and experiences of their communities. Those cities and counties that process hundreds of permits each year, and which are familiar with solar electricity generations systems, will realize efficiencies. For them, adopting a best practice ordinance can make sense. But for those local agencies that have yet to receive an application for a rooftop solar generation system, or process very few permit requests, it does not make sense to require them to develop a checklist and ordinance when they know little about these systems and demand for solar permits is low. The Committee may wish to consider whether the state should mandate a solar permit ordinance for local agencies who are fully empowered to adopt best practices on their own. 3. Inspectors and inspections . AB 2188 prohibits cities and counties from requiring more than one inspection to review a permitted solar energy project that meets the requirements for expedited review. Inspections must be scheduled within five days of a request to inspect. Five days may not give cities and counties enough time to schedule all inspections, and it is unclear if all cities and counties can consolidate structural, engineering and AB 2188 -- 6/18/14 -- Page 6 fire safety reviews into a single inspection. The Committee may wish to consider amending the bill to ensure there is sufficient time and opportunity for cities and counties to ensure that rooftop solar generation systems meet health and safety requirements through adequate inspections. 4. Clarity in order . AB 2188 requires each city and county to adopt an ordinance and establish a checklist and states that applications that meet the requirements of the checklist shall be approved. It is not clear that all required elements of review can be reflected in a checklist. In contrast, the ordinance adopted in response to AB 2188 can and should reflect all applicable requirements to approve a solar electricity generation system. The Committee may wish to consider amendments stating that permits shall be issued upon confirmation that the application is consistent with all requirements of the checklist or the ordinance, as determined by the local http://www.eginfo.ca.gov/pub/13-14/bi l Vasm/ab_2151-2200/ab_2188_c fa_20140620_155953_sen_comm.hlm l 7R/2014