Thanks everyone for your comments. Unfortunately, as several of you pointed out, this project is in snow country (NY). It is difficult to minimize the high point loads that snow adds to panels, especially when the spacing of the supports do not line-up nicely with the joist spacing (they rarely do). I have been able to successfully use the 5% limit in the IEBC, as well as the elimination of roof live loads where there are panels on past solar projects- however, this typically involves solar systems that are attached, with no added ballasts.
@JedClampett: a load test is an interesting concept, but being able to successfully execute it with joists that span 30', is quite a challenge, especially at this time of year with snow in the forecast.
At this point, I will require that the solar support placements do not exceed the joist spacing, use attachments at areas that would require high ballasts, and then compare it to the original loading. With a low (1-story) building, not in a high wind zone, it may work. I'll keep you all posted.