considering the hundreds of thousands of installations completed before bird mesh became popular, only a very small percentage have had issues with pidgeons nesting under the panels. However, if the birds do decide your solar array is good place to nest, they can be a real nuisance and difficult to get rid of. Pidgeons are very persistent little buggers, they are still checking out my neighbours roof depsite having had mesh installed about 2 years ago. It took them a few years to decide to nest there after he had the solar installed, and it does seem to be becoming a worsening problem. So, if your roof is difficult to access, and you have a lot of pidgeons / neighbours who like feeding birds in your area, I would probably fit bird mesh just in case. NB I live in a city where pidgeons are numerous.