Energy Storage Permitting Guidebook - Report - Page 16
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Energy Storage Guidebook
California Fire Code (CFC)
The California Fire Code, Part 9 of Title 24, governs the installation of ESS for commercial and multifamily
buildings and properties. Chapter 12 covers energy systems, and more specifically, Section 1207 covers
requirements for energy storage systems. Table 1207.1.3 includes threshold quantities for which an ESS must
comply with the requirements of this section.
Required construction documentation per the California Fire Code:
Location and layout diagram of the room or area in which the ESS will be installed.
Details on the hourly fire-resistance ratings of assemblies enclosing the ESS.
Quantities and types of ESS to be installed.
Manufacturer’s specifications, rating, and listings of each ESS.
Description of energy (battery) management systems and their operation.
Location and content of required signage.
Details on fire suppression, smoke or fire detection, thermal management, ventilation, exhaust,
and deflagration venting systems (if applicable).
Support arrangement associated with installation.
A commissioning plan.
A decommissioning plan.
In the instance of more than one type of ESS in a single room or enclosed area, and there is potential for
adverse interaction between the technologies, the installer is required to provide a failure modes and effects
analysis (FMEA) or other approved hazard mitigation analysis (HMA) as part of the permitting process. HMAs
typically encompass both a product-specific analysis and a site-specific analysis. Requirements of the hazard
mitigation analysis are outlined in Section 1207.1.4.
The CFC also includes protection provisions including spacing, sizing, and quantity restrictions on groups of
ESS. This is available in Section 1207.5.
Fire Safety Standards
Fire safety in energy storage systems is paramount due to the potential risks
associated with high-energy density technologies like lithium-ion batteries.
The rise in the number of ESS installations necessitates a heightened understanding of the hazards involved
and more extensive measures to reduce the risks. Ensuring safety requires adherence to stringent standards
and regulations such as UL 9540, UL 9540A, and NFPA 855.
UL standards are updated regularly to keep pace with evolving safety, security, and sustainability needs.
The UL standards development process involves a technical committee made up of a group of experienced
individuals who represent a variety of interest categories and who review, vote, and comment on standards
proposals and revisions. NFPA standards are revised and updated every three to five years.
It is important to remember that ESS certified to UL 9540 are highly designed, highly regulated, and should
be put into perspective. The highest incidence of lithium-ion battery hazards occurs with consumer products
and e-mobility devices, which are not subject to the same code requirements or permitting approvals as ESS
and may not undergo the stringent fire safety testing and standards required of ESS.
