We have written an open Letter to the Direktoratet for samfunnssikkerhet og beredskap (DSB) or Norwegian Directorate for Civil Protection.
Concerning: Pluggable solar panels involve risks
to whom it may concern,
we are writing to you concerning your article “Pluggable solar panels involve risks”, accessible for us through google translate, at: https://www-dsb-no.translate.goog/elsikkerhet/aktuelt-elsikkerhet2/pluggbare-solcellepaneler-innebarer-risiko/?_x_tr_sl=auto&_x_tr_tl=de&_x_tr_hl=de&_x_tr_pto=wapp
We are passionate balcony solar enthusiasts from German-speaking countries with Freiburg roots. We are a registered non-profit with the purpose to enhance and promote the safe use of Plug-In-PV. We have been active in the promotion but also in the regulatory action around plug in pv in Germany since 2018 and also worked to achieve the legal right to Plug-In-PV for tenants and Co-Owners in 2024. So the new § 554 BGB includes a right to do this. We are also active within the standards and norming discussion in Germany.
We assume there are more than 2 – 3 Mio. Plug-In-PV systems working in Germany right now. We estimate this from more than 800.000 systems installed and registered in the relevant register at the beginning of the year. From our experience only ½ to ⅓ of the systems will be registered, as there is very little benefit for consumers in actually registering their device. So one could guess there are more households with plug in pv in Germany, then households in Norway at this point.
We see with joy that the Norwegian Directorate for Civil Protection has taken a constructive approach towards these systems and not resorted to a blanket ban as other Nordic regulators have.
This position of Nordic Regulators is difficult to understand for us, as we have a large body of experience of safe operations, not only from Germany but also France, Spaing or Lithuania (see recent report from Solar Power Europe: https://www.solarpowereurope.org/press-releases/new-report-a-deep-dive-on-plug-in-solar-pv-a-fast-emerging-solar-segment)
It is especially bewildering because Article Article 15a of the “Directive (EU) 2024/1711 of the European Parliament and of the Council of 13 June 2024 amending Directives (EU) 2018/2001 and (EU) 2019/944 as regards improving the Union’s electricity market design (Text with EEA relevance)” under section 8 encourages “Member States may promote the introduction of plug-in mini-solar systems of up to 800 W capacity in and on buildings.” (see: https://eur-lex.europa.eu/eli/dir/2024/1711/oj/eng).
As Norway is not a member of the European Union does not apply but it does set an aim for countries which are part of the EU.
As far as we understand, there are risks from operating a Plug-In-PV system, as there are from any other electrical equipment and household device. These risks can be reduced by having a technical standard and providing clear guidance for consumers.
We are afraid your article mentions dangers that are negligible but you do not mention possible dangers that exist and should be addressed by consumer education. It is highly likely that systems are already in use in Norway. A situation we used to call “Guerilla PV”, which was widespread in Germany, before the necessary legal preconditions existed.
From our experience we can say: It does not matter if solar is legal or not, people will install ist. But as there exists a social
We believe that systems that conform to the discussed upcoming german Norm “Vornorm” and have two separate switches to power off the inverter one directed by the internal microprocessor the other by a relais, can be safely connected with a standard Schuko Plug to a shared circuit it it adheres to an upper limit of feed in.
We would suggest that you give an upper limit of safe installation of the amount of inverter maximum power (e.g. 800 W) and possibly installed solarpower capacity that a consumer can install safely himself. As far as we understand, even very old (east) German installation can have 800 W Inverter, with 960 WP. And even cables lying inside a thermal insulation can bear this load without danger of overheating.
We are open to participate in a process with Norwegian stakeholders from civil society, industry and citizens to make safe Plug-In-PV easily available for consumers in Norway. We experience the adoption of such systems often leads to a more conscious and grid friendly consumption of electrical energy.
Please feel free to forward this letter to relevant institutions and individuals and contact us as you wish.
Sincerely
Sebastian Müller (Chair)