Number of participants
Chapter 4: Analysis and Findings Barriers to Adoption
4.2 Thematic Analysis: Barrier Themes Identified
4.2.6 Policy and Regulation
Adoption of BIPV as an energy source, may conflict with established policies particularly in relation to the provision and distribution of power. As an emerging market in the UAE, BIPV directly overlaps the existing power infrastructure; its adoption is thus, potentially influenced by government policies and regulations. As a result, the role of national policies in the UAE is an area of particular interest. Aspects of critical mention relate to the standards or codes for BIPV design, policies or regulations that guide installation and grid integration, as well as issues related to guidelines for approval of BIPV proposals in general. Fifteen participants twelve technical and only three non-technical, reveal aspects of the BIPV market in the UAE impacted by this barrier. Unlike all other themes, one sub-theme clearly categorizes all the comments related to this consideration: the fact that a BIPV policy is yet to be set up in the UAE.
The narrative below explores this barrier further, and presents a crucial check on the status-quo to assess the readiness of the policy framework to guide BIPV diffusion.
a) Technical Participants‘ Opinions
Comments from two architects, four architects with research background, three PV specialists, and three other consultants highlighted certain concerns relating to this barrier. The clear challenge in this regard was that BIPV is not yet included in the present building code (R05AE). Generally, it was mentioned that there are some variations in the different Emirates relating to this issues such as this (R18PVE;
R23PVU), but with BIPV the data collected suggests that the trend is the same. At the time of this investigation, it was mentioned that this was being worked on, but there was no approval possible for BIPV, and grid integration was also not possible (R23PVU;
R24PVU).
“But another issue is that at present, you cannot use building BIPV because the building code does not allow it yet. The code has not evolved with the technology.
There is no code yet. But here at DEWA R&D we are working on this issue.” – R18PVE
“Well, I think that perspectives will different in the various Emirates and it is based on the policies in those areas. With BIPV, you need to know that there is no policy yet.” – R23PVU
“But right now we don‟t have any regulation about that. No approvals from…because whatever we are doing here when we integrate the system to the grid, the plan has to be approved form DEWA and Dubai Municipality.” – R24PVU
It was also reported that the Emirate of Dubai permits residents to generate their own energy, but through an approval process (R31OCE: R32OCE). Solar PV rooftops and carports also exist in other parts of the country like Abu Dhabi and Al Ain city.
Considering that approvals are needed from CD, Municipality, DEWA, and DEWA R&D, some design professionals think that BAPV will be an easier option.
“…and integrating it, you are getting right into issues with Dubai Municipality, you have to actually look into the building regulations, you need to get approved – you
know putting something on the roof, not integrating it, not touching the roof itself is far easier.” – R31OCE
Summarily the concern is that regulatory mechanisms for building integration is not in place, as one professional put it, ―We don‟t see many BIPV projects here, so I assume that it‟s just the regulations haven‟t caught up yet” (R08ARE). In Al Ain, it was reported that there is no policy for BIPV and it is not encouraged (R25PVE). One participant mentioned that in 2011, a resident interested in BIPV had to disconnect completely from the grid or risk disapproval (R12ARE). This comment, however, did not clearly distinguish between BIPV and simple rooftop solar PV or BAPV. Although several years ago, the participant said it was not allowed at the time, and noted with a bit of uncertainty if BIPV would be approved at present. Three other participants seemed to share this same caution regarding the approval of BIPV project proposals;
“The thing is one thing to analyze whether this is going to be cost effective, but it‟s a whole other level when you think, could this actually put my building completion at risk? Will it put my façade compliance at risk?” – R05AE
“We don't have until now in the Emirates the way of connecting our products in- house, for example with the government grid or whatever electrical authorities.” – R17ARE
“The other thing also…I don't know if it's in Al Ain, I'm not quite sure, because even if you produce energy, you cannot sell it to the grid yet.” – R35OCE
Generally, in the UAE, private energy generation and distribution companies are not allowed – with the exception of the Ras Al Khaimah Emirate – and these professionals seem to suggest that, specifically for BIPV, grid connection is not allowed in UAE. Highlighting consequences of this lack of a clear BIPV code or policy directive, some issues raised relate to consequent approval challenges, disinterest by developers, and general uncertainties as explained above. Another example of this relates to approval of solar PV in the building skin in view of skepticism related to fire safety
concerns. Already mentioned under the knowledge theme, the CD is skeptical of solid aluminum which is in fact, used in the frames of BIPV panels. Thus, consultants are nervous to suggest it (BIPV) for fear of non-compliance and risk of rejection by approval authorities. One participant, well-versed in approval process, explained,
“Now CD has decided that this (solid aluminum) is problem…But built –in (integrated) all of a sudden is too much to consider that it might complicate…Is it possible that CD could walk on site one day and go that‟s not allowed and therefore you have to take it all down. All of those things are huge, huge obstacles, like showstopper obstacles.” – R05AE
Another consequence is that there is no obligation on investors or developers to adopt or install BIPV in their buildings. ―Without having it as part of the codes, you are not forcing the investors and the developers to apply it‖ (R10ARE). Also professionals speculate that big companies are allowed to integrate generated power to the grid but not small scale companies use due to fear of market loss. One participant expanded on the vagueness and imbalance of policies and regulations,
“The problem here is that there is no policy, the main problem. They are not encouraging…Only big firms are allowed to integrate with transmission companies, not even distribution companies. So when you talk about building integration in a small scale, there is no policy that encourages people to install them. So why will people install it? First of all, it‟s not allowed.” – R25PVE
Still, some others speculate that Estidama, which guides sustainable building designs, has some restrictions for the use of solar PV.
“I think about the regulations. There are more sustainable buildings which is in some way driven by Estidama. Sometimes, it is based on the client‟s request. We follow a manual, the Estidama regulation, and follow the restrictions for solar panel use in buildings.” – R02AE
b) Non-Technical Participants‘ Opinions
One participant from the Client-Expat group and two from the Policy Makers and Implementers group also considered that this barrier has a significant impact on BIPV adoption (R48CE; R6PMI; R65PMI). Contrary to the technical stakeholder option, a Policy Maker and Implementation sub-group participant asserted that a BIPV Solar PV System was recently approved by their office and they argue that there is no challenge but the concern of the maximum height of the installation (R64PMI). BIPV is, however, a fully integrated component into walls and windows and roofs, thus the issue of height relates more specifically to BAPV installations on roofs. Accordingly, this participant‘s comment suggests there was some confusion between BAPV and BIPV despite the researcher‘s attempt to define and describe the difference. On the flip side, it may mean that the initial technical opinion is flawed. One participant also mentioned that having different regulations in different Emirates and municipalities creates confusion. He added a second point relating to approval; he noted that there are really no issues, but the concern is the poor visual impact of solar PV (R65PMI).
“That's why I'm telling you, you need to simplify… because they will hide there because it's very ugly. That's why they are going to hide them. The regulation comes from this...the regulation wants them but if you see these dishes for TV, it will be like that. They would not allow you.” – R65PMI
To emphasize the strenuous approval process, another participant from the same group noted that designers need to get approvals for materials, and for any changes to cover aspects like sustainability and fire-rating (R64PMI).