July 17, 2018

ESA Contributes to Updating Fire Codes on Battery Energy Storage

This week, ESA filed comments advocating for safe, fair and reasonable fire codes for energy storage systems at the National Fire Protection Association (NFPA) and the International Code Council (ICC).  Leading up to these filings, we held a webinar on September 13, 2017, and June 28, 2018, to provide information on the implications of upcoming revisions to the codes.  In this blog, we explain the code updating process and provide an overview of our comments to the NFPA and the IFC, which are available in full to members here (NFPA Standard 855) and here (IFC).

Who oversees fire codes and where are we in the process of updating them?

The NFPA publishes and maintains Standard 855, Standard for the Installation of Stationary Energy Storage Systems.  The NFPA began the process of revising the existing version of Standard 855 in late 2016 and ESA has been actively engaged in the process.  The latest round of comments were submitted electronically on July 12 in response to the First Draft Report published on May 9.

The ICC publishes and maintains the International Fire Code (IFC).  While both NFPA Standard 855 and the IFC impact the market for energy storage, the IFC may have wider-reaching implications because it has been adopted by 42 states and the District of Columbia for enforcement.  (Note that conversely, NFPA Standard 855 has not been adopted directly by any jurisdiction; although it is recognized indirectly in a few states via references in NFPA 70).  The ICC is in the process of revising the IFC.  ESA submitted several proposed changes to the IFC in January of this year and has worked closely with the IFC Code Action Committee to advocate for our proposals.  The ICC published The Report of the Committee Action Hearing on May 30 and comments on actions in the Committee were due on July 16.  

While represented by separate and independent documents (and processes), revisions to NFPA Standard 855 and the IFC are highly interrelated exercises.  Leaders in the IFC revision process also tend to participate in the development of NFPA 855, and there have been indications that the ICC is following the NFPA process closely.

What are the biggest issues in the current draft rules for energy storage?

ESA was pleased to see some significant progress in the latest round of revisions to NPFA Standard 855 regarding the treatment of energy storage systems.  First, we were successful in advocating for clarity that only new installations would be subject to the rules—thereby avoiding undue burdens on projects already operating today or will shortly finish development.  Second, ESA raised concerns about NFPA’s emphasis on annual training requirements for all installations, resulting in reduction of training requirements for certain installations.

In our latest comments at the NFPA and the ICC, ESA continues to reiterate the need to reduce the separation requirements between energy storage systems in outdoor enclosures from 100 feet to 50 feet.  ESA also calls for an increase in the maximum rated energy for each storage installation to 1,000 kilowatt-hours (kWh) from the proposed 600 kWh.  Additionally, ESA calls for NFPA Standard 855 to align with the IFC training requirements, minimizing undue impediments.  Finally, we advocate for clarifications in the definition of “Authority Having Jurisdiction” (AHJ) to ensure that the permitting is handled by qualified entities.

While we are confident in the validity of our positions, achieving our desired goal of lowering the separation requirements down to 50 feet for energy storage systems in outdoor enclosures will likely require additional effort with both the NFPA and the ICC.  We will also need to ensure that the requirements for walk-in containerized units allow for more diverse storage configurations and products.

What happens next?

The next NFPA meeting on energy storage is scheduled for July 24-26, 2018 in Salt Lake City, Utah, and the second draft NFPA report is scheduled for release on November 1, 2018. The ICC will hold a public comment conference on October 24, 2018 in Richmond, Virginia.

While ESA will be engaged for the total duration of the process, we are simultaneously focusing long-term on the next round of NFPA and ICC code revisions in 2020.  We look forward to better educating fire safety professionals and codes and standards developers about grid battery storage technologies in the interim.  Ultimately, ESA seeks to ensure that codes and standards for safe and reliable energy storage are appropriate in the context of the potential risks, and not unduly burdensome to our innovative, growing energy storage industry.

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