Residential ESS Limited to "Living Area" IFC Rule?

5/31/2024

A resident in our area is planning to install ground-mounted solar for an existing home, along with storing the energy produced in batteries. The area for the batteries (ESS - Energy Storage Systems) is a storage room which is accessible only through the inside of their garage.

Would this storage area still be considered a "living area" and thus subject to the max 20kWh of ESS per the IFC section 1207.1.1 (table)?

Or, could they store more batteries in this area since it's only accessible via the garage area?

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9 Comments

Franck Orset

5/31/2024 08:25:05 am

I will leave the floor to other peers regarding legislation in the US.

The only "good" news in your question is the choice of lithium iron phosphate ion. But, even if safer than "generic lithium-ion", they still present a fire hazard that may not be desirable in such a location.
It is true top say that thermal runaway is reduced with lithium iron phosphate ion, but it is not true to say it will not cause a thermal runaway event.
And consequences are the same for both technologies if a fire is involved.
Not to speak about the photovoltaic panels on the roof that is already a fire threat by themselves.

Joe

5/31/2024 08:40:47 am

Not sure what edition of the IFC you are using but most AHJ are using the most current edition 2024 for ESS since the rules, regulation and technology is every changing.

Chapter 1 of most fire and building code allow the AHJ to us other codes ( see section IFC section 102.8 and 102.9 of the 2024 IFC

Based on this I would start at section 1207 , review section 12017. 1.4, which limit the max unit size to 20kWh and aggregated rating of 40 or 80 kWh. Also see section 1207.11.7.1

joe

5/31/2024 08:53:52 am

sorry for the typo is read

>>> review section 1207.11.4 not 12017.1.4 >>>.

Jesse

5/31/2024 08:42:53 am

Great answer by Franck re: the reduced, but not eliminated, threat of thermal runaway with lithium iron phosphate ion batts.

This is one of those areas of code that can be interpreted differently. Unless the resident has modified the garage to be a game room or such and its conditioned space, I wouldn't consider it to be living space. But, the AHJ may see it differently.

Chad

5/31/2024 09:06:33 am

From an AHJ perspective, trying not to piss off a single family home owner, or the green movement folks:

A reasonable degree of safety is achieved, IMO, with it separated as it is even though it exceeds 20KWH and I would require a smoke alarm in there to alert occupants and get them out. Irrespective of living area or not. If you disallow they might just add it after.

smoke alarm because I assume they need to condition the space so the batteries don't get cooked or frozen, both of which is bad for them

Joe

5/31/2024 09:15:28 am

Does the IRC reference this IFC section? How do you get to IFC on a single-family detached dwelling?

Ricardo Gonzales Jr

5/31/2024 10:04:42 am

Note 1st that the IFC doesn't affect Residential Homes. Then comes in the question of IF the Jurisdiction has adopted NFPA 855. Most have not.
The best you can do is advise the Homeowner of the potentials, but also give the data on the frequency of such a situation. The #s are very small. As a Risk Analysis, the frequency is minute, but the action is devastating. Follow the guild lines of the SFPE Guide to Fire Risk Assessment before giving out any information.
You'll be surprised on the numbers and the over exaggeration of the media.

Joe

5/31/2024 10:41:42 am

Please review IFC 2024 edition section102.5 and section 1207.1.

The IFC does apply to R3 and R4 occupancies

Joe

5/31/2024 06:43:34 pm

Agreed but this is an R-5

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Residential ESS Limited to "Living Area" IFC Rule?

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