Leonardo Corbucci

To facilitate the installation of photovoltaic systems on the roofs of buildings serving activities subject to fire prevention controls, given the high number of requests for the ongoing energy emergency, the legislator with the Legislative Decree 144/2022 (GU no. 223 of 23 September 2022), in art. 16 established that in the event that, following the installation of these types of systems, the evaluation of the fire prevention project is necessary, the terms for the binding opinion of the Fire Brigade. are reduced, until 31 December 2024, from sixty to thirty days, in order to streamline the bureaucratic process.

 

Changes to subject activities

 

Photovoltaic systems are not included among the activities subject to fire prevention control as they are not included in the list in Annex 1 of the Presidential Decree. 151/2011.

However, the installation of a photovoltaic system serving an activity subject to fire prevention controls undoubtedly involves a change to the fire risk assessment drawn up by the qualified technician, whose management is regulated by the Ministerial Decree. 7 August 2012, which provides for differentiated obligations depending on whether the changes are:

- « Not substantial » (it is sufficient to declare them when certifying periodic renewal).

- «Without worsening» the pre-existing fire safety conditions (a new certified notification of commencement of activity must be submitted).

- With worsening of the pre-existing fire safety conditions (a new project examination must be submitted).

 

Evaluation of changes

 

The evaluation of the type of modification is carried out by the designer through a risk assessment aimed at identifying the most suitable solutions to achieve the fire safety objectives.

The professional will be able to take into account the technical solutions contained in the DCPREV prot notes. n. 1324 of 7 February 2012 and n. 6334 of 4 May 2012, although they must not be considered as prescriptive indications.

"Photovoltaic system serving an activity subject to fire prevention controls" means a system incorporated into the subject activity, independently of the end user, or a system whose modules fall, even partially, within the volume delimited by the cylindrical surface. vertical having as its generator the plan projection of the building, including overhangs and eaves.

 

 

Fire prevention requirements

 

If the fire risk assessment reveals a worsening of the pre-existing fire safety conditions, examination of the project must be requested (for category B and C activities) from the Provincial Fire Brigade Headquarters and, once the works are completed, it must be presented the certified Report of commencement of activity before the start of the activity.

However, if no worsening of the pre-existing fire safety conditions emerges, the application must be updated with the presentation of the Scia.

In case of presentation of the Scia without prior approval of the project, the documentation must be integrated with the risk assessment.

 

Case of «increased risk»

 

The installation of a photovoltaic system can lead to an increase in the pre-existing level of fire risk for the business served, depending on the electrical and construction characteristics and methods of installation.

In evaluating this possible "increased risk" for the legislator, the following aspects must be taken into consideration to allow the identification of the obligations set out in the art. 4, paragraph 6, of the Presidential Decree. n. 151/2011:

> Interference with the combustion product ventilation system such as, for example, partial/total obstruction of translucent elements, impediments to the opening of the vents.

> Obstacle to cooling or extinguishing operations on combustible roofs.

> How the fire spreads in a building of the flames outside or towards the inside of the building (presence of pipes on the roof of a building divided into several compartments, modification      of the speed of spread of a fire in a single compartment building) .

> Safety of maintenance operators.

> Safety of rescue operations workers.

 

Technical requirements

 

From a safety point of view, it must be taken into account that it is impossible to de-energize the system in the presence of sunlight.

This constitutes an element of attention not only during the construction and maintenance phase of the photovoltaic generator, but also in the event of an emergency intervention.

For the purposes of fire prevention, PV systems must be designed, built and maintained in a workmanlike manner.

Where the systems are carried out according to the technical documents issued by the CEI (standards and guides) and/or by the international standardization bodies, they are considered to have been carried out in a workmanlike manner.

All components must comply with applicable community or national provisions.

The installation must be carried out in such a way as to avoid the spread of a fire from the photovoltaic generator to the building in which it is incorporated.

 

This condition is considered respected if the photovoltaic system is installed on non-combustible structures and roofing elements (Class 0 according to the Ministerial Decree 06/26/1984 or Class A1 according to the Ministerial Decree 03/10/2005).

 

The interposition between the photovoltaic modules and the support surface of a layer of fire-resistant material of at least EI 30 and non-combustible is also equivalent.

Alternatively, a specific assessment of the risk of fire spread may be carried out.

In addition to the risk assessment, other assessments aimed at demonstrating the achievement of the objectives of the guide are eligible.

In the DCPREV note n.6334 of 04/05/2012 the different methods for satisfying the safety requirement relating to the risk of fire spread were summarized.

If it is intended to take into account the external fire resistance class of roofs and roof coverings and the reaction to fire class of the photovoltaic module (case 3/a of Annex B), the following can generally be considered acceptable pairings:

> Roofs classified Froof and PV panel class 1 or equivalent reaction to fire.

> Roofs classified as Broof (T2, T3, T4) and PV panel class 2 or equivalent reaction to fire.

> Final roofing layers (waterproofing and/and insulation packages) classified Froof or F installed on EI 30 roofs and class 2 PV panels or equivalent reaction to fire.

 

 

 

The location of the modules and electrical conduits must also always allow the correct functioning and maintenance of any smoke and heat evacuators (EFC) present, as well as taking into account, based on the fire risk analysis, the existence of possible fire transmission routes (skylights, chimneys, etc.).

In any case, the modules, ducts, inverters, panels and any other equipment must not be installed within a radius of 1 m from the EFCs.

Furthermore, in the presence of vertical fire compartmentation elements, placed inside the activity underneath the support surface of the photovoltaic system, the same must be at least 1 m away from the projection of these elements.

The PV system must also have the following characteristics:

> Be equipped with an emergency control device, located in a marked and accessible position which determines the isolation of the electrical system, inside the compartment in relation to the power sources, including the photovoltaic system.

> In the event of the presence of gases, vapours, flammable mists or combustible dusts, in order to avoid the dangers caused by electrical ignition, it is necessary to install the direct current part of the system, including the inverter, outside the classified areas pursuant to Legislative Decree 81/2008 - annex XLIX.

> In places with danger of explosion due to the presence of explosive material, the photovoltaic generator and all other direct current components constituting potential ignition sources must be installed at the safety distances established by the applicable technical standards.

> The components of the system must not be installed in places defined as "safe places" pursuant to Ministerial Decree 30/11/1983, nor be an obstacle to escape routes.

 

In-depth analysis by the eng. Matteo Pierotti

The full-blown climate changes, the still indispensable use of fossil fuels, such as:

> Oil;

> Natural gases.

They have transformed the priorities of investment-related risks.

ESG (Environment, Social & Governance) sustainability factors have now become an essential factor for every manufacturing and non-manufacturing company.

In recent years, the governments of countries around the world have signed unprecedented global agreements, which will be able to radically change investment policies, pushing the transformation towards a sustainable and environmentally compatible economy, promoting and supporting a "global energy transition", through economic support of various types, in the various industrial sectors.

The European Union, in addition to launching an important Multi-Year Financial Plan in support of the "green deal", has taken the field considerably and has decided to accelerate the energy transition processes, bringing forward important targets to 2035.

Financial markets are also moving in this direction, establishing real regulatory authorities, linking climate risk into the global financial system.

 

 

As? By changing the ratings of financial companies, should they not declare a "green" sustainability and investment policy.

Finally, in this historical and economic period, "sustainability" fortunately goes hand in hand with "ethics", pushing many companies to undertake management and therefore investment paths, focusing on ESG factors, coupled with corporate ETHICAL VALUES and governance.

It is therefore not a question of promoting cheap "green washing" actions; on the contrary, companies are betting heavily on the opportunity for deeper and more rooted growth, a cultural evolution capable of generating true corporate values, which are necessarily reflected both in management and in short/medium and long-term investments.

 

How does this epochal cultural change in governance happen within a company, focusing on ESG factors?

Many companies, especially public ones and those listed on stock exchanges around the world, have extended ESG policies to social and ethical policies, certifying and publishing short/medium and long-term ESG strategies and defining the targets to be achieved therein.

At the same time, together with the half-yearly reporting on company performance, they have the obligation to publish a specific reporting file on the development of ESG factors.

Generally, large companies lead the way in the markets and therefore this trend must necessarily be read from a "button down" perspective.

It is no coincidence that many small companies have certified themselves and have already published their first sustainability reports, declaring their short/medium and long-term investments.

We are mostly talking about highly energy-intensive manufacturing companies that have implemented their range of products with the use and/or addition of "bio-materials", but also production companies that by strategic choice have opted for a policy of investments aimed at increasing energy efficiency and improving the working environment, adapting production sites and building envelopes, such as: installing systems that generate electricity from renewable sources, general revamping of consumer equipment, changing fixtures, coats thermal, boiler replacement with heat pumps, disposal of asbestos cement and other preparatory activities.

 

But let's go into specifics, what are ESG certifications?

They are a series of operational standards that a company's strategies must comply with.

These certifications evaluate the sustainability of organizations, in particular their ability to align with a series of fundamental requirements for sustainable development from the economic, environmental, social and governance points of view of the company.

 

 

Sustainability has three dimensions.

ESG is an acronym (Environmental, Social & Governance).

> Environmental Area (E), includes environmental factors, i.e. the way in which an organization contributes to the protection and management of the environment.

> Social (S) scope includes services, i.e. the impact in which an organization interacts with the territory and with people, be they employees, suppliers and customers.

> Governance Area (G), includes strategies, i.e. the way in which an organization intends to apply the first two factors within the company.

 

How to obtain ESG certification?

ESG sustainability is becoming a central theme in the corporate world at all levels and dimensions.

Companies that demonstrate a strong commitment to these principles can obtain ESG certification, which is a certificate that certifies and qualifies them for their commitment to sustainability.

Before undertaking the ESG certification process, it is crucial to have a thorough understanding of ESG criteria and key existing standards, such as the Global Reporting Initiative (GRI), the United Nations Global Compact (UNGC) and the Sustainability Accounting Standards Board (SASB). ).

These standards provide guidance on key areas of sustainability and how to measure corporate performance in those areas.

Once you understand ESG criteria, it is important to “conduct an internal assessment” to understand the current state of the company's ESG performance.

 

How? Analyzing financial data, identifying environmental and social risks and planning improvement strategies.

“Strategies play a key role in the certification process”: the strategic definition is necessary to establish the objectives and the investments to be made to achieve them.

Once the strategy has been defined, it is necessary to implement the measures for monitoring the results over time.

This may involve collecting specific data and integrating sustainable processes and procedures within daily business activities.

 

ESG certification

After conducting the internal assessment and measuring the company's ESG performance, the certification process can be started.

There are several organizations offering ESG certification, each with their own requirements and evaluation criteria.

It is important to select a recognized and trusted certification that aligns with industry standards and expectations.

Once ESG certification has been obtained, there is an obligation to communicate the results transparently to the outside world, for example to shareholders, employees, suppliers and customers.

This can be done through the publication of periodic sustainability reports.

By following the steps described above and demonstrating a solid commitment to sustainability and ESG factors, companies can not only contribute to a more sustainable future, but also achieve tangible business benefits recognized by the market.

 

 

ESG Auditors and Certifiers?

ESG certifications are issued by various independent organizations specialized in the sector.

Some of the most internationally recognized are:

> Global Reporting Initiative (GRI)

The GRI is a non-profit organization that promotes the dissemination of information on the environmental, social and governance impact of companies. The GRI provides guidelines and standards for preparing sustainability reports and does not issue certifications, but it helps companies develop and improve their ESG performance.

> Carbon Disclosure Project (CDP)

The CDP is an international organization that requires companies to disclose their greenhouse gas emissions and strategies for dealing with climate change.
Companies participating in the CDP receive a transparency and climate action score, but not a specific certification.

> Rating agencies.

Some independent rating agencies, such as Moody's, S&P Global and MSCI, also evaluate companies' ESG performance.
These agencies use specific metrics to score or rate companies based on their ESG engagement and performance.

 

Costs of ESG certification?

The costs for obtaining an ESG certification can vary according to the organization issuing it and above all according to the company size.

Logically, the greater the commitment to sustainability, the higher the costs will be.

It is advisable to contact your chosen ESG certification organization directly to obtain accurate cost information.

 

Long-term benefits and vision.

The corporate world rationally tends to compare COSTS vs BENEFITS.

What benefits could a company have that opts to invest in sustainability by certifying ESG factors?

From our point of view we could consider three types of benefits and economic returns:

> The first is a SHORT-TERM BENEFIT, commercial recognition of customers on individual products. The ESG certified customer recognizes the ESG supplier an extra plus (either economic or in terms of product volumes) compared to the non-ESG certified supplier;

> The second is a MEDIUM/LONG-TERM BENEFIT, economic return on sustainable investments, in terms of economic savings over time.
These investments have an average payback time of 4/5 years and will allow companies to see the first tangible benefits only after this period of time.

> The third is a LONG-TERM BENEFIT, based on the classic hierarchy of the supply chain in the corporate world (Producer OEM, Tier1 supplier and Tier2 supplier), in the long run there will be an increasing tendency to qualify only ESG certified suppliers.
ESG certification is a process that is starting now, and which in fact is mainly involving (OEM producers) and some first-level suppliers (Tier1).
Therefore this selectivity mechanism must necessarily be seen in the long term.

The companies that decide today to invest by certifying ESG factors are mainly those players who have a long-term vision, who do so because they create tangible value for the entire company system and not for an immediate improvement of their economic account.

 

 

The Inveco Group's interest in ESG factors

In recent years, our renewable energy business unit has grown significantly, both in organizational terms and in terms of business volume.

This success was certainly made possible thanks to our experience as a general contractor in the industrial world and careful planning and commercial strategy.

Above all this, however, there was the presence of a strong MARKET DEMAND.

It is precisely the specific analysis of the question that presents us with a more appropriate and in-depth reflection: "the demand encountered in recent years to make industrial building envelopes more efficient, the strong development of renewable energy, primarily the installation of rooftop photovoltaic systems, have they already reached the end of the line”?

“Will the investments of industrial players continue at the current volumes or will they have contractions in the coming months that will send companies like ours into crisis?” – “Has the fear effect of a company that saw the cost of kWh skyrocket in 2022, then return to pre-shock levels, more or less market-level, already over?”

The answer to these simple and obvious questions that many entrepreneurs are certainly asking themselves today is, in our humble opinion: NO.

The ESG certifications are proof of this, because if the corporate world, strongly stimulated by international institutions, has taken this route and undertaken strategic decisions based on instrumental investments, the answer can only be a firm "NO".

It is here that we glimpse our growth opportunity, first of all a "cultural growth" that can conceive and understand the true strengths behind sustainability, factors that are apparently intangible but which create value in the company.

Again from our modest point of view, ESG certifications are an example of how the corporate world is evolving and will not do so in 30 years, it is already doing so and will continue to do so.

 

(plant built in March 2023 for ICSS Group, an ESG certified company)

 

The Inveco Group's commitment will be to implement ISO 9001 with ISO 14000 by 2024, at the same time conducting "an internal assessment" to understand the current state of the company's ESG performance and begin strategically planning business objectives. 'investment.

The Inveco Group is sensitive to issues related to sustainability and sees long-term opportunities in the energy transition supported by corporate cultural growth.