DSA IR 11B-9: Accessibility Requirements for Solar Photovoltaic Systems at School Sites

4. Overhead PV Systems

Overhead PV systems can be attached to, adjacent to or remote from school buildings and accessible outdoor areas. The area beneath an overhead PV system elevated components can be either 1) restricted to operations and service personnel or 2) available to teachers, students, staff and the general public. For purposes of accessibility compliance, overhead PV systems fall into one of the three following types:

4A – Restricted Access: The PV system is located within a secure enclosure. Access to the PV system is limited to operations and service personnel:

1. There are no accessibility requirements in the area of work.⁷

2. The project is not an alteration that would trigger path of travel upgrades.⁸

3. An accessible route to the enclosure’s entrance shall not be required.⁹

4. To qualify for the machinery space and path of travel exceptions, signage must be posted indicating the area is to be entered only by operations and service personnel.

4B - Unrestricted Access with No Change in Use - If access to the area below the PV system is not physically restricted and there is no proposed change of use of the area below the elevated PV system components:

1. The area below the elevated PV system components must be accessible consistent with the CBC accessibility provisions applicable to the current use of that area. ¹⁰

2. If the current use of the area below the elevated PV system components requires that area to be on an accessible route, one shall be provided.

3. The project, including incidental work to implement a) and b) above, is not an alteration that would trigger path of travel upgrades;¹¹

4. When located on sloping ground (running slope exceeds 5%) the area below the elevated PV system components need not be made accessible. 

4C - Unrestricted Access with Change in Use - If access to the area below the PV system elevated components is not physically restricted and there will be a change of use or other alterations to that area:

1. The area under the PV system elevated components must be made accessible consistent with the proposed use of that area and must be on an accessible route to other areas of the facility.

2. Upgrades of path of travel elements serving the area undergoing a change in use or other alterations may be required.

3. See Section 7 - Path of Travel Requirements and Adjusted Construction Cost for policy guidance on the adjusted construction cost for compliance with path of travel requirements.