Hello,
As you are aware we had a code change that took effect in October 2019 that has us permitting Energy Storage Systems (Chapter 52) meeting certain criteria. This is going to be challenging for many of us as we learn more about these systems. We were very fortunate to be ahead of this curve where we had so many educational sessions on this subject over the past few years.
Please share your stories so we can all learn as we go.
Thanks,
Chris,
I had reached out to you via email regarding ESS installs and Ch 52. I'll share some of my concerns in the forum for other's input and consideration.
In my extremely limited experience w/ ESS, I've only seen one residential installation proposed in my community through our building permit process. It is part of a proposed PV system and includes a Tesla 40.5 kWh [3 batteries @ 13.5 kWh per] ESS inside an existing single family dwelling constructed in 1986. It would seem that these installations will become more frequent as the govt mandates more energy conservation measures as part of construction and/or when those who currently have PV systems installed on their homes realize the cost benefit of storing the energy their PVs create in ESS inside those homes and not dumping it back out into the grid.
It is my understanding that Ch 52 applies to all buildings within the State. Among the reqs of Ch 52 are the installation of sprinklers [52.3.2.7] and monitored alarm systems [52.3.2.7.2]. These requirements are invoked when ESS is installed in excess of the threshold quantities listed in Table 52.3.1. Note that in the installation I referenced above, the Ch 52 reqs appear to be applicable in excess of 20 kWh. Does this mean that the homeowners would need to install a sprinkler and monitored fire alarm system in their home? As much as I'm an advocate for both types of fire protection systems, don't these reqs conspire to make ESS a much more costly than worthwhile energy conservation initiative?
Further, NFPA recently issued NFPA 855 for ESS et al. Within 855, Ch 15 specifically addresses 1, 2 family and townhouse ESS installations. I reviewed it while researching how to address the permit and found it to be more easily understood and applied as well as less restrictive than Ch 52. As much as I'd like to use it in place Ch 52, we have yet to adopt 855 as part of 527 CMR. I have inquired w/ DFS and been told as an AHJ, we can use 855, but find doing so could potentially leave myself liable as the installation would not meet applicable code. I left it with the applicant that he had to meet the reqs of 527 CMR Ch 52.
It is my hope that either the BFPR will take this up in the immediate future and issue guidance such as was done earlier today by the SFMO for tags and labels or that someone who is looking to install ESS in a single family home files an appeal to the BFPR, who can hopefully render a decision relative to the of applicability of CH 52, or NFPA 855, to residential ESS installs within the Commonwealth.
Looking forward to hearing what thoughts or experiences others may have on this issue.