Correspondence Log — CleanPowerSF Sfpuc Commission, November 12, 2024

OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.

525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
T 415.554.3155
F 415.554.3161
TTY 415.554.3488

San Francisco Public Utilities Commission
Correspondence Log
October 18, 2024 through November 4, 2024

Date Received From Subject
October 18, 2024 Dave Warner SFPUC Issues Overview (email and attachment)

October 18, 2024 Jeremy Pollock LAFCo Study for CleanPowerSF on Battery Energy Storage Systems (email and attachment)

October 21, 2024 Rush Rehm
Professor (emeritus),
Stanford University
Public comment submitted for October 22 SFPUC meeting
(duplicate email and attachment received three times)
October 22, 2024 Martin Gothberg SFPUC 10-22-2024

October 23, 2024 Francisco Da Costa Letter from the Chairperson - linked to the assault - and the replay from the U.S Department of the Interior.

October 23, 2024 Peter Drekmeier Biological Goals & Adaptive Management (email and attachment)

October 28, 2024 Nicole Sandkulla,

CEO/GM BAWSCA
BAWSCA's Review and Recommendations on SFPUC's FY 23-24 Annual Report on the WSIP (email and two attachments)
November 4, 2024 Peter Drekmeier Re: Biological Goals & Adaptive Management (email and two attachments)

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From: Dave Warner
To: Lennear, Tiffany; Commission
Cc: Herrera, Dennis J; Ritchie, Steve; Hom, Nancy; Busch, Laura; Corvinova, Erin E Subject: SFPUC Issues Overview
Date: Friday, October 18, 2024 12:18:39 PM
Attachments: SFPUC Issues Overview 2024-10-18.pdf
Hi Tiffany,
Thank you for your service to the commission! Would you provide the attached letter to the commissioners? I've included in this message those on the letter's cc list.

Best regards,
Dave

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October 18, 2024
Re: An Intro to Some Water Issues
Dear Commissioners,
Welcome new commissioners! Thank you all for your service. As Commissioner Stacey knows, I’ve been following water related commission issues and commented at commission meeEgRUﬀngs for many years. I’m a private industry Chief Financial Oﬃcer by trade, having worked extensively with CEO’s and Boards of Directors.

You represent 2.7 million Stakeholders
As you know, you represent the SFPUC’s stakeholders which are primarily the 2.7 million customers that rely on the SFPUC for water and a smaller number for wastewater and power.

You May Not Have Much Time to Make a Diﬀerence
Also as you know, three commissioners were not reappointed to their posiEgRUﬀons this year. The implicaEgRUﬀon is that your EgRUﬀme here may be limited. Please make the most of your EgRUﬀme on the Commission.

Your Team Has Potenwg;jEal
The SFPUC has many talented people and a strong depth of experEgRUﬀse.

The SFPUC is Falling Behind
However, from a water perspecEgRUﬀve the SFPUC is mired in past thinking and pracEgRUﬀces and has not been adapEgRUﬀng well to a changing world. Demand is declining. Costs are skyrockeEgRUﬀng. Water rates are skyrockeEgRUﬀng. The Tuolumne River ecosystem conEgRUﬀnues to suﬀer. And yet the SFPUC has not responded to these changes in a construcEgRUﬀve way.

Governance: SFPUC Pracwg;jEces Make Your Oversight Diﬃcult The SFPUC has a number of deeply insEgRUﬀlled pracEgRUﬀces and tradiEgRUﬀons that make your ability to provide oversight diﬃcult, as outline below.

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Governance: Commissioners Aren’t Given Real Choices
Staﬀ has a pracEgRUﬀce of providing materials for commissioner approval, but without giving commissioners a choice other than to not approve. OEgHH7en by the EgRUﬀme the materials are submiEgR7ﬀed to commissioners, there’s no EgRUﬀme to revise them should commissioners not approve.

For example: Water rates and ﬁnancial plans are inEgRUﬀmately related. However, commissioners are given liEgR7ﬀle opportunity to inﬂuence either ﬁnancial plans or water rate increases. The pracEgRUﬀce is for staﬀ to present in January, for all pracEgRUﬀcal purposes, “ﬁnal” ﬁnancial plans for approval with no ability to change the ﬁnancial plans nor understand how a change to the ﬁnancial plans might aﬀect water rates. A beEgR7ﬀer pracEgRUﬀce would be to give commissioners choices earlier in the ﬁnancial planning process and show how choices of ﬁnancial plans aﬀect water rates.

Governance: Commissioners Aren’t Provided with Real Transparency From a water perspecEgRUﬀve, staﬀ will provide a biased perspecEgRUﬀve on key issues.

They should be unbiased or at least fully disclose any bias. Unfortunately, there are many examples. A simple one is the AlternaEgRUﬀve Water Supply Plan (AWS) which states that 92 million gallons per day (mgd) of addiEgRUﬀonal supply are needed.

However I doubt anyone would say that we need to start building 92 mgd of AWS.

While the Plan acknowledges in smaller print that the full 92 mgd might not be needed, the overall message is misleading to the uninformed reader.

Transparency means providing a full, unbiased perspecEgRUﬀve to the commissioners as a group. Providing informaEgRUﬀon to individual commissioners or responding privately to individual commissioners deprives the commission as a whole (and the public) of an ability to have a rich discourse.

Governance: Staﬀ Have a History of Poor Responsiveness to Commissioners In comparison with Boards of Directors, I ﬁnd that, with a couple of excepEgRUﬀons, SFPUC commissioners were mostly disregarded on major items. The excepEgRUﬀons were commissioners Anson Moran and Ed Harrington, both of whom were former SFPUC General Managers.

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Former Commissioner Ajami asked for a sensiEgRUﬀvity analysis on demand and water rates. Never provided. At one EgRUﬀme the Commissioners passed a resoluEgRUﬀon requiring that any voluntary agreement that the SFPUC proposes related to the Bay Delta Plan includes an adapEgRUﬀve management feature. Never implemented.

I’ve come to understand that staﬀ is not required to respond to individual commissioner requests, but that they are required to respond to commissioner resoluEgRUﬀons. Despite the above example, it probably makes sense to propose a resoluEgRUﬀon if you want a signiﬁcant acEgRUﬀon from staﬀ.

Demand: The SFPUC Has Only Projected Increasing Demand Despite a Long-Term Decline
While demand has declined substanEgRUﬀally over the last 30 years, the SFPUC has only projected that demand will increase. Demand is fundamental to just about all aspects of the SFPUC’s Water Enterprise business. At a minimum, the SFPUC should be fully prepared for declining demand scenarios, sharing detailed conEgRUﬀngency plans including projected water rates, debt raEgRUﬀng impacts, and cash management plans.

Water Rates: The SFPUC’s Wholesale Water Rates are the Highest in the State; Retail Rates Will Likely Exceed the Aﬀordability Threshold The SFPUC already has the highest wholesale water rates of any major water agency in the State, and they are expected to increase by large amounts, even under the SFPUC’s projecEgRUﬀon of increasing demand. Should demand not increase but instead decline, meaning the SFPUC will not sell as much water as projected, water rates will need to go up beyond projecEgRUﬀons. The SFPUC’s water rate projec/g415ons do not include the cost of AWS should the projec/g415ons materialize.

Regarding retail water rates, today rates are 30% below the aﬀordability threshold. SFPUC projecEgRUﬀons show that in 20 years there will only be a 1% cushion below the threshold. Given that the projecEgRUﬀons are based on increasing demand and for other uncertainEgRUﬀes, including the lack of any signiﬁcant AWS in the ﬁnancial projecEgRUﬀons, there is a signiﬁcant chance that aﬀordability thresholds will be exceeded.

Alternawg;jEve Water Supplies: The Proposed Projects Are Among the Most Expensive in the State

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The proposed AWS projects in the latest AWS plan document have an average capital cost in the range of $200 million per million gallons of water per day (mgd) of supply. Projects in Los Angeles and San Diego are currently projected to have a capital cost in the range of $50 million per mgd. Even if LA’s and San Diego’s projecEgRUﬀons are opEgRUﬀmisEgRUﬀc, they would sEgRUﬀll be well below the SFPUC’s costs.

Project Management: Water Enterprise Has a Poor Track Record of Managing Capital Project Costs
The water enterprise capital projects currently underway were budgeted at approximately $3 billion. Current projecEgRUﬀons have the costs for the projects coming in 20% higher, at $3.6 billion. Such overages put further upward pressure on water rates
Finance: Cost Projecwg;jEons Are Skyrockewg;jEng
The 2024/25 ﬁnancial plans had a massive jump in the 10 year capital spending plan. Water Enterprise’s 10 year projecEgRUﬀon increased 38% or $1.25 billion in just the last year. This seems foolhardy in the SFPUC’s current ﬁnancial environment.

Finance: The SFPUC Has a Stunning Debt Load
50% of the water revenue the SFPUC collects goes to debt service costs. And the jump in the 10-year capital plan is primarily ﬁnanced by more debt. Los Angeles DWP, the San Diego County Water Authority and Valley Water all have debt loads less than half that of the SFPUC (on a percent of water revenue basis).

The Wastewater Enterprise has already seen a “negaEgRUﬀve outlook” issued by one of the raEgRUﬀng agencies for its debt. The San Diego County Water Authority had a similar negaEgRUﬀve outlook issued and esEgRUﬀmated its debt service costs would increase by $95 million. Should that happen to the SFPUC Water Enterprise, the impact would be much larger.

A best pracEgRUﬀce would be for the SFPUC to work down and eliminate its debt load over EgRUﬀme and start building a cash reserve for infrastructure replacement costs.

While this seems unfathomable in the SFPUC’s current situaEgRUﬀon, at least we should start moving in this direcEgRUﬀon.

Finance: The SFPUC has a Costly Drought Model

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The SFPUC has an 8.5 year drought model. The SFPUC refuses to quanEgRUﬀfy the risk of such a drought occurring. The SFPUC’s own Long Term Vulnerability Assessment from 2021 (LTVA) found no drought of such severity in 1100 years of tree ring data nor 25,000 years of stochasEgRUﬀc data. The LTVA also found that precipitaEgRUﬀon totals would not be adversely aﬀected by climate change through 2070, and instead found that drought return periods lengthened.

If the drought model were reduced by roughly a year, it would free up roughly 25 mgd of supply per year, reducing the need for alternaEgRUﬀve water supplies. If the capital cost of AWS were $50 million/mgd supply, this would save $1.25 billion. If the capital cost of AWS were $200 million, as was the average in the AWS plan, the savings would be $5 billion.

No other major water agency in California has such a drought model. CompleEgRUﬀng a risk analysis on the drought model and adjusEgRUﬀng the return period could reduce further upward pressure on both water rates and debt load while sEgRUﬀll having a acceptable drought model.

Environment: The SFPUC Gets Most of Its Water from a Devastated Ecosystem Up unEgRUﬀl early this century, the lower Tuolumne River had annual salmon counts in the tens of thousands, ﬂuctuaEgRUﬀng with drought cycles. However, since 2005 most annual salmon counts have been below 1,000 and none above 2,000. Clearly the Tuolumne ecosystem is in desperate shape.

The SFPUC has been liEgRUﬀgaEgRUﬀng against the Bay Delta Plan jointly with the Turlock and Modesto IrrigaEgRUﬀon Districts. The three have put forth a proposed voluntary agreement with a very limited increase in ﬂows and, despite a Commission resoluEgRUﬀon, with no adapEgRUﬀve management feature similar to what the Bay Delta Plan has.

The SFPUC has made modest investments in habitat restoraEgRUﬀon, but amongst the scienEgRUﬀﬁc community there’s liEgR7ﬀle consensus that habitat restoraEgRUﬀon will work without increased ﬂows.

Your consEgRUﬀtuents are concerned about the environment. There are many examples to cite, but a well-known one is 2016’s measure AA, which funded the San Francisco Bay RestoraEgRUﬀon Authority. It passed with 70% approval across the region.

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What Does the SFPUC of the Future Look Like?
Today the next 20 years look bleak: Commissioners’ inﬂuence limited. Demand overesEgRUﬀmated. Stunning water rates. Huge debt loads. Project overruns.

Perhaps this will lead to another ratepayer revolt like what happened in 1998, which might even lead to bankruptcy. And ecological devastaEgRUﬀon on the lower Tuolumne conEgRUﬀnues.

Please put us on a path to a beEgR7ﬀer future. Many of us would be excited to help! The good news is that there’s lots of opportunity and good people to work with.

Kind regards,

Dave Warner

cc: Dennis Herrera, SFPUC General Manager
Steven Ritchie, SFPUC Assistant General Manager, Water Enterprise Nancy Hom, SFPUC Chief Financial Officer
Laura Busch, SFPUC Deputy Chief Financial Officer
Erin Corvinova, SFPUC Financial Planning Director

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From: Pollock, Jeremy (BOS)
To: Board of Supervisors (BOS); Commission
Cc: Herrera, Dennis J; Hale, Barbara; Hyams, Michael; Jue, Tyrone (ENV); Tanenberg, Diedre (ENV) Subject: LAFCo Study for CleanPowerSF on Battery Energy Storage Systems Date: Friday, October 18, 2024 11:14:47 AM
Attachments: LAFCo_CleanPowerSF_Battery_Study_Transmittal-10-18-24.pdf Honorable Board of Supervisors and Public Utilities Commissioners, I am pleased to transmit the LAFCo Study for CleanPowerSF on Battery Energy Storage Systems (BESS).

As part of a memorandum of understanding (MOU) between LAFCo and the San Francisco Public Utilities Commission (SFPUC), LAFCo is conducting a series of studies on local energy innovations.

LAFCo contracted with Arup International to complete this first study on battery energy storage systems (BESS). The purpose of this study is to identify areas of improvement to existing local BESS policies and regulations in San Francisco to support the City’s goals of decarbonization, resilience, and economic development.

BESS is a critical technology in San Francisco’s 2021 Climate Action Plan. To meet San Francisco’s goal of 100% renewable electricity by 2025 and 100% renewable energy by 2040, we must dramatically increase our capacity for storing this renewable electricity to use when it is needed.

The study makes several recommendations for improving implementation of BESS in San Francisco, which are organized into these categories:
·
Streamline the permitting process
· Create a BESS implementation one-stop shop
· Provide financial assistance for BESS installations · Facilitate opportunities for virtual power plants

The study was developed with support from a core project team consisting of staff from Arup, LAFCo, the SFPUC, and the San Francisco Environment Department (SFE). The study was also informed by meetings and input from the San Francisco Fire Department (SFFD), the San Francisco Department of Building Inspection (SFDBI), the California Solar & Storage Association (CALSSA), the San Francisco Electrical Construction Industry (SFECI), and Luminalt, a local solar and energy storage installation company. We thank everyone for investing their time and expertise in this project. All of these entities were given the option to provide a letter to be included in the file with the study.

LAFCo is now transmitting the final work products for this study, including the following attachments, all of which are posted on the LAFCo webpage for this study:

LAFCo Study for CleanPowerSF on Battery Energy Storage Systems (9/16/24) LAFCo Introduction: Why BESS Is Important (7/19/24)
SFPUC Comment Letter (9/18/24)
SFFD Comment Letter (8/23/24)
Luminalt Comment Letter on CAL-FIRE Code Interpretation 24-02 (9/17/24) Arup Comment Letter on CAL-FIRE Code Interpretation 24-02 (9/19/24) SFECI Comment Letter (9/20/24)

Should you have any comments or questions on this study, or if you would like to schedule a briefing or presentation from LAFCo staff, please do not hesitate to contact me at [email protected] or 415-554-6756.

Sincerely,
Jeremy Pollock

Executive Officer
San Francisco Local Agency Formation Commission (LAFCo) 415-554-6756
Pronouns: he/him
https://sfgov.org/lafco/

San Francisco Local Agency Formation Commission
City Hall
1 Dr. Carlton B. Goodlett Place, Room 409
San Francisco, CA 94102-4689
Tel. 415.554.6756 Fax. 415.554.5163

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COMMISSIONERS

Hillary Ronen, Chair
Board of Supervisors

Hope Williams, Vice Chair
Member of the Public

Dean Preston
Board of Supervisors

Isaac Sevier
Member of the Public

Connie Chan
Board of Supervisors, Alternate

Shanti Singh
Member of the Public, Alternate

Jeremy Pollock
Executive Officer

Khalid Samarrae
Policy Analyst

Inder Khalsa
Legal Counsel

Alisa Somera
Clerk

October 18, 2024

TO: San Francisco Board of Supervisors
San Francisco Public Utilities Commission

FROM: Jeremy Pollock, LAFCo Executive Officer

CC: Dennis J. Herrera, SFPUC General Manager
Barbara Hale, SFPUC Assistant General Manager, Power Enterprise Michael Hyams, SFPUC Deputy Assistant General Manager, CleanPowerSF Commission on the Environment
Tyrone Jue, San Francisco Environment Department Director

SUBJECT: LAFCo Study for CleanPowerSF on Battery Energy Storage Systems

I am pleased to transmit the LAFCo Study for CleanPowerSF on Battery Energy Storage Systems (BESS).

As part of a memorandum of understanding (MOU) between LAFCo and the San Francisco Public Utilities Commission (SFPUC), LAFCo is conducting a series of studies on local energy innovations. LAFCo contracted with Arup International to complete this first study on battery energy storage systems (BESS). The purpose of this study is to identify areas of improvement to existing local BESS policies and regulations in San Francisco to support the City’s goals of decarbonization, resilience, and economic development.

The study makes several recommendations for improving implementation of BESS in San Francisco, which are organized into these categories:
• Streamline the permitting process
• Create a BESS implementation one-stop shop
• Provide financial assistance for BESS installations
• Facilitate opportunities for virtual power plants

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LAFCo is now transmitting the final work products for this study, including the following attachments, all of which are posted on the LAFCo webpage for this study:
• LAFCo Study for CleanPowerSF on Battery Energy Storage Systems (9/16/24) • Attachment 1: LAFCo Introduction: Why BESS Is Important (7/19/24) • Attachment 2: SFPUC Comment Letter (9/18/24)
• Attachment 3: SFFD Comment Letter (8/23/24)
• Attachment 4: Luminalt Comment Letter on CAL-FIRE Code Interpretation 24-02 (9/17/24) • Attachment 5: Arup Comment Letter on CAL-FIRE Code Interpretation 24-02 (9/19/24) • Attachment 6: SFECI Comment Letter (9/20/24)

Sincerely,

Jeremy Pollock
LAFCo Executive Officer

San Francisco Local Agency Formation Commission (LAFCo) LAFCo Study for CleanPowerSF on Battery Energy
Storage Systems
LAFCo BESS Policy Research

September 2024

© UL
This report takes into account the particular instructions and requirements of our client. It is not intended for and should not be relied upon by any third party and no responsibility is undertaken to any third party.

Job number 259426-24
Arup US, Inc.
560 Mission St., Ste. 700
San Francisco, CA 94105
USA
arup.com

SF Local Agency Formation Commission (LAFCo) LAFCo Study for CleanPowerSF on Battery Energy Storage Systems

July 31, 2024 | Arup US, Inc. LAFCo BESS Policy Research Page 2

Document Verification

Project title LAFCo Study for CleanPowerSF on Battery Energy Storage Systems Document title Final Draft Memo
Job number 259426-24
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Revision Date Filename Final Draft Memo
1 2
3 4
5 6
7 03/08/2024
05/03/2024
06/12/2024
06/28/2024
07/11/2024
07/31/2024
09/16/2024
Description Final Draft Memo
Prepared by Checked by Approved by
Name Christine Stavish,
Joshua Lyons,
Shoja Jahangard-
Mahboob,
Jasmine Bhairo
Hayley Powers
Mike Lepisto

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Filename
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Name
Signature
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Name
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Issue Document Verification with Document 

SF Local Agency Formation Commission (LAFCo) LAFCo Study for CleanPowerSF on Battery Energy Storage Systems

July 31, 2024 | Arup US, Inc. LAFCo BESS Policy Research Page 3

Contents

1. Executive Summary 5

2. Introduction 6

3. Summary 7

4. Project Goals and Objectives 7

5. Commercially Available Battery Technology 9

5.1 Efficiency 9

5.2 Storage Capacity 10

5.3 Usable Capacity 10

5.4 Energy Density 10

5.5 Durability 10

5.6 Safety 10

5.7 Maintenance 11

5.8 Cost 11

5.9 Key Takeaways 11

6. State and San Francisco Local BESS Codes and Policies for Group R-3 Occupancies 12

6.1 Introduction 12

6.2 San Francisco BESS Requirements 12

7. Comparable Municipalities ESS Codes and Policies for R-3 Occupancies 16

7.1 Summary 16

7.2 Austin, Texas 16

7.3 Chicago, Illinois 17

7.4 Fremont, California 17

7.5 New York City, New York 17

7.6 San Jose, California 18

8. State and SF Local BESS Codes and Policies for R-2 Occupancies 18

8.1 Introduction 18

8.2 San Francisco 18

9. Review of City Permitting by Building/Zoning Type and Storage Size 21

10. Existing Storage and Rooftop Solar Data 22

11. Financial Resources for BESS Implementation 23

11.1 State and Federal Financial Incentives 23

11.2 Low Income Incentives 25

12. BESS Consumer Navigation and Installation 27

13. BESS Installation Workforce and Training 30

14. BESS as a Virtual Power Plant 32

15. Discussion and Key Takeaways 33

15.1 External Deterrents Impacting BESS Implementation in CCSF 33

SF Local Agency Formation Commission (LAFCo) LAFCo Study for CleanPowerSF on Battery Energy Storage Systems

July 31, 2024 | Arup US, Inc. LAFCo BESS Policy Research Page 4

15.2 Challenges to BESS Implementation in CCSF 34

15.3 Opportunities for Improvement for BESS Implementation in CCSF 35

Tables
Table 1: Commercially Available Battery Type Comparison 9 Table 2: Examples of Commercially Available Batteries 9 Table 3: State and Federal Financial Incentives 23
Table 4: Low Income Incentives 26
Table 5: Data Sources 38
Table 6: BESS Codes and Policies for R-3 Occupancies 44

Figures
Figure 1: California Energy Storage System Survey – Bay Area 39 Figure 2: California Energy Storage System Survey – San Francisco 40 Figure 3: CSI Working Data – Bay Area 41
Figure 4: CSI Working Data – San Francisco 42
Figure 5: Data Scoring 43

Appendices
Appendix A 38
A.1 Data Sources 38
A.2 BESS Codes and Policies for R-3 Occupancies 44

SF Local Agency Formation Commission (LAFCo) LAFCo Study for CleanPowerSF on Battery Energy Storage Systems

July 31, 2024 | Arup US, Inc. LAFCo BESS Policy Research Page 5

1. Executive Summary
The City and County of San Francisco's (CCSF) 2021 Climate Action Plan identified battery energy storage systems (BESS) as important technologies to support the electrification of buildings and transportation, support the reliable operation of the electric grid, and provide emissions-free back-up power supply for energy reliance.1 This study was commissioned by the San Francisco Local Agency Formation Commission (LAFCo), in collaboration and with funding from CleanPowerSF, San Francisco's Community Choice Aggregation program, operated by the San Francisco Public Utilities Commission (SFPUC). The goal of this study is to improve the experience of residents and businesses seeking to install BESS systems. While multiple factors related to solar and battery markets, costs, and regulations influence customer adoption of BESS, this report focuses on the experience of residential customers seeking to install BESS in San Francisco.

The San Francisco Department of Building Inspection (SFDBI) and Fire Department (SFFD) regulations and policies play a significant role in the BESS installation process. While review of the regulations and codes promulgated by comparable major cities suggests San Francisco is neither an outlier nor creator of significant barriers to BESS installations in terms of code language, review of how that code language is interpreted and enforced by SFFD raises important permitting barriers for BESS implementation in R-2 and R-3 occupancies.

The most notable is inadvertent confusion on definitions for “system” and “unit”, and how the conflation of the two impacts BESS permitting process. The impact is primarily materialized in inconsistent permitting pathways across online permitting platforms and the departments’ (DBI and SFFD), branching permitting processes, and additional BESS installation and permitting requirements for “systems”, rather than “units”.

In 2023, CCSF adopted National Renewable Energy Laboratory’s (NREL) online Solar permitting program, SolarAPP+, allowing applicants to receive automated permits for their Solar+BESS if individual BESS units do not exceed 20 kWh. SolarAPP+ conflicts with the SFFD’s permitting policy which requires applicants to submit for a building permit if aggregate capacity of BESS units exceed 20 kWh. This permitting confusing on similar, but different, language and colloquial usage thereof is likely not the primary contributor to BESS implementation challenges. Despite having a more “streamlined” automated permitting option that has saved approximately one (1) hour per application for initial permit review, there have been only 54 SolarAPP+ submittals since October of 2023, suggesting other factors are influencing the low number of BESS associated with solar installations.

While the use of SolarAPP+ does not affect the initial public application process, it does create unintended and unaccounted inefficiencies for CCSF staff in processing the applications. The SolarAPP+ platform limits the information that may be submitted to a simplified checklist, which can be insufficient to convey critical information needed for complete design reviews. Though meant to minimize the initial review period, SolarAPP+ does not allow for detailed information such as plans, single line diagrams, or UL9540A information to be uploaded. This limitation ultimately leaves critical design information out of permit application and pushes design corrections to resubmittals or field inspections. The permitting platform also does not allow for particular use cases like those where solar is already installed at the building, and the applicant is applying for permit to add a BESS. SolarAPP+ platform usage questions are also directed to City staff, which incurs additional time and costs for both residents and the City. A maximum of $450 can be recouped for this additional effort due to the fee cap imposed by California Assembly Bill 1414, which in effect created another unfunded mandate by the State onto local government. Currently, the CCSF’s obsolete permitting fee system automatically calculates permit fees based on valuation as opposed to this legislated fee limit. To meet this permit fee limitation in lieu of updating permitting systems, DBI allows contractors to request refunds for the amount the contractor was charged in excess of the fee cap.

1 For more information see: https://www.sfclimateplan.org/

SF Local Agency Formation Commission (LAFCo) LAFCo Study for CleanPowerSF on Battery Energy Storage Systems

July 31, 2024 | Arup US, Inc. LAFCo BESS Policy Research Page 6

Some aspects of San Francisco’s BESS permitting process (including those mentioned above) that could be improved are:
• Interagency alignment and individually consistent usage of the BESS terms, specifically “unit” and “system” • SolarAPP+ limitations
• Branching review process (between DBI and SFFD)
• Unspecified review deadlines
• Staff rotation that negatively impacts the process through loss of familiarity and expertise • Updated IT systems to ensure compliance with state permit fee regulations.

Strengthening the coordination between the SFFD and SFDBI ensures alignment across departments and minimizes the use of resources while expediting the process. Additionally, the permitting process could be clarified by incorporating permit expediters, already commonly used in San Francisco, to field SolarAPP+ questions from applicants rather than City staff. Furthermore, coordination with SFFD to explore embedding inspection requirements into the SolarAPP+ platform to allow first-time BESS installers to have a more streamlined experience would contribute to strengthening SFFD and SFDBI coordination. Consideration for pre- inspection activities, such as an installer uploading photos and additional site information prior to a scheduled inspection, may also expedite the process.

Beyond the permitting process, other factors that may influence BESS uptake, such as equipment and installation costs, represent significant costs for those looking to implement BESS. While there are a variety of state and federal incentive programs dedicated to supporting BESS and solar installations through tax credits, deductions, rebates, technical assistance, and other types of incentives, these can be difficult for applicants to track, navigate, and understand to utilize their potential. This report does not address utility interconnection requirements, though utility interconnection application and permission to operate is also required from the electric utility of all BESS installations. This utility interconnection process can result in additional costs and delays. The complex, costly process of obtaining a permit and installing a BESS or solar system indicates that consumers may need more financial, technical, or communication support throughout the process.

From a workforce development standpoint, the industry is still calibrating to the needs of solar and BESS installations. This means that it can be difficult for contractors to navigate different licensure paths and gain the experience needed to advance their careers. Furthermore, the incentive-based nature of BESS and solar installations means that there is not a steady demand for this type of work. More coordination is needed within the industry to establish congruence between workforce development and BESS and solar installation to meet the respective needs and goals of all involved entities.

2. Introduction
The demand for residential battery BESS in California is increasing each year.2 According to the California Energy Commission, the total capacity of BESS in residential occupancies was 843 MW in 2023, a substantial increase from just 264 megawatts (MW) in 2020.2 Drivers of such growth include declining BESS cost, increasing energy costs, new Net Billing Tariff (NBT) compensation rates, concerns regarding grid reliability, and disaster resilience. However, the installation and permitting process can pose challenges. To better align the public experience with policy priorities, LAFCo, in collaboration with the SFPUC and the San Francisco Environment Department, has commissioned this report, funded by CleanPowerSF, with the goal of streamlining the BESS permitting and installation process, focusing on greater cost-effectiveness, policy efficacy, and safety.

2 California Sees Unprecedented Growth in Energy Storage, A Key Component in the State’s Clean Energy Transition

SF Local Agency Formation Commission (LAFCo) LAFCo Study for CleanPowerSF on Battery Energy Storage Systems

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3. Summary
This memo summarizes opportunities and barriers to BESS in Group R-3 and Group R-2 occupancies and provides discussion regarding a comparison to similar high-density municipalities. Group R-3 occupancies are single-family houses and duplexes, while Group R-2 occupancies contain more than two dwelling units.

Opportunities and barriers are presented through a summary and qualitative analysis of current BESS regulations for residential buildings in six U.S. cities. These regulations include permitting, installation, operation, and maintenance. The cities selected for this study were chosen for their similarity to San Francisco due to housing type, density, or similar BESS installation maturity. Austin, TX, Chicago, IL, Fremont, CA, New York, NY, and San Jose, CA were selected. The report highlights the similarities and differences amongst regulations and discusses the implications.

Specifically, this report covers the following topics:
• CCSF goals and objectives for BESS in Group R-3 and R-2 residential applications • Commercially viable battery technologies for BESS with a comparison of applications, safety, performance, price, and other factors
• State and local codes and policies for Group R-3 BESS. This occupancy is the most common for residential buildings in San Francisco. The report focuses on the San Francisco Fire Code (SFFC), San Francisco Electrical Code (SFEC), and SFFD Administrative Bulletin 5.12 “Energy Storage Systems in R-3 Occupancies” (AB 5.12).
• Review of the codes and policies for Group R-3 BESS installations from a sample of municipalities to identify best practices and lessons learned from other jurisdictions • State and local codes and policies for Group R-2 BESS. This includes relevant information from SFFC and SFEC, but it does not include details from SFFD since this does not apply to R-2 occupancies. • Review of the permitting processes for BESS by occupancy and capacity, including compliance with SB379 for real-time permitting and the use of NREL SolarAPP+
• Review and mapping of available data related to existing BESS storage and Solar installations in San Francisco
• Financial resources for BESS implementation, including state and federal financial incentives and low- income incentives.
• Educational resources for BESS implementation, including BESS installation workforce and training and consumer navigation and installation
• Opportunities to utilize BESS as a virtual power plant • Possible areas of improvement to existing San Francisco BESS regulations, and, where applicable, policy recommendations which promote safe and effective residential BESS installations

4. Project Goals and Objectives
The purpose of this study is to identify areas of improvement to existing local BESS policies and regulations in San Francisco to support the City’s goals of decarbonization, resilience, and economic development. Increasing BESS implementation could benefit individual residential customers, electric utilities, and the California Independent State Operator (CAISO), not just in energy resiliency but also in reduced energy costs over time

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despite the high upfront cost of these systems. Individual customers would benefit from lower time-of-use (TOU) rates, electric utilities can gain the benefit of increased distribution of locally generated resources amongst customers whilst still controlling the distribution network, and CAISO would benefit from flexibility and lower peak demands through offsetting demand locally without introducing additional outside electricity resources into the grid.

This study considers three use scenarios: Solar, BESS, and Solar+BESS. Solar installations are those in which there is no associated BESS system and the energy generated is first used to power the building, with any excess sent directly to the grid through a net energy metering (NEM) program. Such installations are not optimized for time-of-use based metering or reliance. BESS installations without Solar can be used to arbitrage price peaks or provide resilience during outage events but are reliant on the grid to be recharged. Solar+BESS installations have the greatest potential benefit as the configuration can generate, store, and use energy, which reduce reliance on the grid.

End users that would benefit the most from BESS deployment are those with existing Solar systems without NEM 1.0/2.0 and Solar users with NEM 3.0. NEM is a California metering policy that allows Solar system owners to earn credit for excess energy production, thereby reducing their monthly energy bill. NEM 1.0 and 2.0 guarantees participants 20 years of net metering after receiving authorization from Pacific Gas & Electric (PGE) through a Permission to Operate (PTO) resulting in bill credits equivalent to their full retail rate for excess Solar generation. Upon expiration of NEM 1.0 and 2.0, participants will no longer be eligible for excess Solar generation bill credits. As such, BESS deployment will ensure excess solar generation is not sent to the grid, but rather stored away for use when solar energy is not being generated. Similarly, Solar users that typically generate excess power and are currently enrolled in NEM 3.0 would also benefit more if paired with a BESS. This is because NEM 3.0 solar export rates are calculated as avoided costs which refers to the price that PG&E pays for solar energy sent to the grid. This new rate is approximately 75% less than NEM 1.0 and 2.0 export rates, meaning that there is less financial incentive to sell excess energy back to the grid. Instead, excess energy generated from Solar can be stored in BESS and used during peak demand when the cost of electricity is highest or when solar energy is not being generated. Older PV systems that are smaller and do not generate excess demand to sell back through the grid through NEM can still benefit from a BESS by engaging in energy arbitrage, but the upfront capital cost of the BESS is likely cost prohibitive for this use case.

Other specific end users that would benefit the most from BESS deployment include electric vehicle (EV) owners, residents planning to electrify their homes, and those who require uninterrupted power for medical reasons. EVs have become increasingly popular with San Francisco having the second highest EV adoption rate (about 34%) among major U.S. metropolitan areas in 2023

3. California EV incentive programs, such as the
Clean Cars for All program run by the Bay Area Air and Quality Management District, offer cash redemption for low-income residents who retire and replace certain vehicles with an EV. Additional incentives are available for installing a Level 2 home charging station attempting to make both EVs and home charging stations more affordable. As the number of residences electrifying and installing at home EV charging increases, BESS can be used to store excess energy that can be discharged during peak demand times, reducing the demand on the grid during peak charging times and saving the BESS user money on electric utility bills.

For medically vulnerable populations who are dependent on refrigerated medication or electricity-powered life sustaining equipment, a BESS can ensure a consistent power supply. Many common medications require refrigeration or run the risk of reduced potency, such as insulin and TNF inhibitors for inflammatory conditions.

Without these medications, users can experience a decrease in quality of life or even death. BESS deployment in such residencies reduces the risk of ineffective medication or equipment failure during power outages. These use cases may still be subject to high capital costs associated with BESS implementation, but likely have access to rebates, incentives, and other financing structures that significantly reduce or eliminate costs.

3 The Bay Area Leads the National Shift to Electric Vehicles - The New York Times (nytimes.com)

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5. Commercially Available Battery Technology
The most common battery types found in residential BESS are lithium iron phosphate (LFP), lithium nickel manganese cobalt oxide (NMC), both of which are a type of lithium-ion battery, and lead-acid. Historically, lead-acid was the standard battery chemistry until supplanted by NMC batteries. In recent years, LFP has become the industry standard for residential BESS by providing a more favorable combination of safety, cost, and performance compared to NMC batteries. Table 1 provides an overview of the main differences between lithium iron phosphate, lithium nickel manganese cobalt oxide, and lead-acid batteries. Table 2 provides a list of currently commercially available batteries.

Table 1: Commercially Available Battery Type Comparison Criteria Lithium Iron Phosphate
(LFP)
Lithium Nickel Manganese
Cobalt Oxide (NMC) Lead-Acid
Efficiency Has the highest total charge-
discharge cycle efficiency.

Has a high total charge-
discharge cycle efficiency.

Has a slightly lower total
charge-discharge cycle
efficiency than lithium-ion
battery technologies.

Storage capacity Systems available in a variety
of energy capacities.

Systems available in a variety
of energy capacities.

Systems available in a variety
of energy capacities but has a
lower capacity per battery
module than LFP and NMC
batteries.

Usable capacity Has a high usable capacity. Has a high usable capacity. Has a lower usable capacity than LFP and NMC batteries.

Energy Density Has a high energy density. Has the highest energy density. Has a low energy density.

Durability Has the highest durability with
a large total life cycle.

Highly durable with a large
total life cycle.

Less durable with a lower total
life cycle.

Safety Safest battery technology. Safe battery technology. Safer battery technology.

Maintenance Requires basic annual
maintenance.

Requires basic annual
maintenance.

Cost* More affordable than NMC. More expensive than LFP. Cost per cycle is typically higher than NMC and LFP
* Cost per cycle is highly dependent on operation, maintenance, and environment.

Table 2: Examples of Commercially Available Batteries
Battery Type Name Storage Capacity
Lithium Iron Phosphate sonnenCore 10 kWh
Lithium Iron Phosphate Enphase IQ 10 10.08 kWh
Lithium Iron Phosphate BYD Battery Box HVS 10.24 kWh
Lithium Nickel Manganese Cobalt Oxide Tesla Powerwall 13.5 kWh Lithium Nickel Manganese Cobalt Oxide LG RESU10H Prime 9.6 kWh Lithium Nickel Manganese Cobalt Oxide Generac PWRCell 9 kWh Lead-Acid UNBOUND Crown Battery Bank 2.58 kWh per battery pack

20.64 kWh per bank of 8 batteries

5.1 Efficiency
Battery efficiency is a measure of how effectively a battery can convert stored energy into usable power. Most lithium-ion batteries are 95% efficient or more, whereas most lead-acid batteries are 80% to 85% efficient. LFPs

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are slightly more efficient than NMCs4, especially at lower temperatures. This matters little when the BESS is installed indoors or in mild climates like San Francisco. Overall, lithium-ion batteries both offer longer usage times between charges and reduce energy waste compared to lead-acid batteries.

5.2 Storage Capacity
A higher storage capacity can be achieved with fewer lithium-ion batteries when compared to lead-acid batteries.

Additionally, the lead-acid battery packs have a larger footprint when compared to lithium-ion for the same storage capacity. Thus lithium-ion based battery technology is considered preferable for residential installations as greater capacity in less area is achieved.

5.3 Usable Capacity
The usable capacity of a BESS refers to the amount of electricity stored that is available for use compared to the total capacity, as batteries require a degree of charge to be retained to remain functional. A battery’s usable capacity is determined by the depth (e.g., %) that the battery can be discharged before negatively affecting the lifespan.

Lithium-ion batteries can handle discharges of 80% or more, whereas typical lead-acid batteries can accommodate a 50% discharge. Although both battery types can be fully discharged safely, lithium-ion batteries can handle a deeper discharge before risking damage. Lithium-ion batteries can provide more usable energy before needing to be recharged.

5.4 Energy Density
The energy density of a battery system relates to the amount of energy that the battery can store per kilogram (kg) of battery mass. Lead-acid batteries typically have 30–40 Wh/kg compared to 90–120 Wh/kg for LFP batteries and 150–220 Wh/kg for NMC batteries. This means a lead-acid based BESS will weigh more than lithium-ion system and may require additional infrastructure to support the increased weight.

5.5 Durability
The durability of a battery refers to the amount of charge-discharge cycles a battery can withstand before reaching the end of its useful life. Each charge-discharge cycle decreases a battery’s useful life and batteries that have reach ~80% of the original capacity are considered to have reached end-of-life. A typical lithium-ion battery can withstand the equivalent of a few thousand charge-discharge cycles to 100% depth of discharge, whereas a typical lead-acid battery can withstand only a few hundred charge-discharge cycles at 100% depth of discharge. Since batteries are never intentionally discharged to 100%, it is important to understand that the charge-discharge cycle is cumulative. For example, a battery that was discharged to 40%, recharged, discharged to 60% and then recharge would have the rough equivalent of a single 100% charge-discharge cycle. The cycle life of LFPs and NMCs are similar, but degradation occurs at a slower rate with LFPs. This means that LFP batteries can store and release more electricity than NMC and lead-acid battery types over time.

From a cost perspective, LFPs are more cost effective. For example, a 10 kWh sonnenCore LFP BESS has an approximate first cost of $9,500 but will output 58,000 kWh of energy over the expected lifetime. Whereas an LG Chem Prime NMC BESS has an approximate first cost of $7,000 but will only output 32,000 kWh of energy.

5.6 Safety
In terms of lithium-ion batteries, LFPs are considered safer than NMCs as lithium iron phosphate is more stable than lithium nickel manganese cobalt at high temperatures. Stability can be benchmarked by the temperature at which the battery enters thermal runaway. Thermal runaway is a fault process where the rate of heat generation in a battery exceeds the battery’s ability to dissipate the heat, leading to a rapid increase in temperature that can result in fire or an explosion. Thermal runaway occurs in LFP batteries ~518°F, whereas NMC batteries enter

4 Degradation of Commercial Lithium-Ion Cells as a Function of Chemistry and Cycling Conditions - IOPscience

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thermal runaway at ~410°F. Having a higher temperature tolerance means LFP batteries can handle larger draws of power due to the heat generation from internal resistance.

Due to the higher thermal runaway, LFP batteries are less likely to catch fire than NMC batteries. On the other hand, a fire involving any lithium-ion chemistry may be more severe than that of a lead-acid battery since the only combustible component of a lead-acid battery is the casing, which is usually made of fire-retardant polypropylene.

Battery management systems (BMS), which monitor parameters such as voltage, current, and temperature, allow the BESS to stop the charging or discharging process in case of abnormal conditions. This greatly reduces the chance a battery will enter a state of thermal runaway. A BMS is required as part of a BESS UL 9540 listing.

The UL 9540 listing aims to ensure a baseline level of safety and compatibility for a BESS. UL 9540A testing, which is referenced in UL 9540, also covers BMS that are part of a BESS and evaluates the fire safety hazards associated with propagating thermal runaway within a BESS. To pass UL 9540A testing, which is needed for the UL 9540 listing, a residential BESS must meet specific fire safety performance criteria without any external fire suppression or intervention.

5.7 Maintenance
Both LFP and NMC batteries require only basic annual maintenance which includes conducting full maintenance cycles (e.g., a full discharge and full charge) every 3-6 months. Unlike lithium-ion batteries, some lead-acid batteries are recommended to undergo regular maintenance at three-month intervals and certain types, such as flooded lead-acid batteries, must have electrolyte levels monitored and replenished in addition to regular visual inspection to spot sulfation. Failure to regularly maintain a lead-acid battery could result in abnormal operation, more rapid degradation, and other safety concerns.

5.8 Cost
LFP batteries have lower upfront costs than NMC batteries. This is mostly because the elements, iron and phosphate, incorporated into LFP batteries are more abundant and less expensive than the nickel, manganese, and cobalt required to produce NMC batteries. A 2020 report published by the Department of Energy found that LPF batteries cost 6% less per kWh than NMC batteries.
5 5.9 Key Takeaways
When compared to lead-acid batteries, lithium-ion battery types are generally more efficient, have a higher energy capacity, higher usable capacity, and a higher energy density. This means that a lithium-ion battery can provide more efficient usable energy while taking up less space than a lead-acid battery. Lithium-ion batteries are also more durable and have a longer life cycle and require less maintenance than comparable lead-acid batteries.

While LFP and NMC lithium-ion batteries perform very similarly, it is worth noting that LFP batteries are slightly more efficient and degrade slower than NMC batteries, meaning LFP batteries waste less energy and have a higher total energy output during their life cycle. LFP batteries are also more stable than NMC batteries and hit thermal runaway at higher temperatures, making LFP the safer lithium-ion battery technology. NMC batteries do have a higher energy density, resulting in an overall smaller battery when compared to LFP batteries. LFP, which has greater safety and cost-effectiveness, has become the industry standard for residential BESS.

5 Final - ESGC Cost Performance Report 12-11-2020.pdf (pnnl.gov)

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6. State and San Francisco Local BESS Codes and
Policies for Group R-3 Occupancies

6.1 Introduction
In this section, codes and policies affecting BESS in Group R-3 occupancy buildings, including SFFC, SFEC, and SFFD Admin Bulletin 5.12, are presented. A few key limitations on installing BESS in Group R-3 occupancies in San Francisco include:
• Energy capacity limits
• Physical system size
• Additional requirements for systems greater than 20 kWh • 3ft separation from doors, windows, and other BESS units • Specific safety requirements such as monitoring, ventilation, explosion mitigation, thermal runaway mitigation, spill control, and fire sprinklers

6.2 San Francisco BESS Requirements
The CCSF has set forth goals towards make the city a cleaner energy consumer by the year 2040.6 As part of this there has been a focus on transitioning the city’s residents towards residential Solar and BESS systems. The SFFD released AB 5.12 to attempt to clarify the Department’s interpretation, and how to meet SFFC requirements related to energy storage systems (ESS). This section reviews some of the codes and policies that place restrictions on installing BESS in Group R-3 buildings.

6.2.1 Energy Capacity
The maximum aggregate capacities per installation within Group R-3 occupancies are:

1. 40 kWh within utility closets and storage or utility spaces

2. 80 kWh outdoors on the ground

3. 80 kWh on exterior walls

4. 80 kWh in attached or detached garages and detached accessory structures AB 5.12 limits the maximum capacity of individual BESS to 20 kWh, and the maximum total energy rating permitted is 280 kWh if all four installation options noted above are implemented. BESS that exceed the individual capacity or aggregate capacity listed above are required to comply with the CFC §1207.1 through §1207.9. The SFFD has interpreted this portion of the code to apply to aggregate BESS and individual BESS units exceeding the 20-kWh threshold.

This is an interpretation of the code language that, in conflating BESS “system” and “unit”, aggregate systems exceeding the 20-kWh threshold are subject to additional installation and permitting requirements and processes per the SFFD. The 2022 California Fire Code, SFFD Admin Bulletin 5.12, and 2022 California Residential Code language is written in a way that delineates individual BESS unit requirements from aggregate BESS requirements. Individual battery modules are combined to create a BESS with the desired storage capacity. The capacity can be varied by increasing or decreasing the number of modules used. The aggregate storage capacity

6 San Francisco Adopts New Climate Action Goals | Office of the Mayor (sfmayor.org)

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of any residential BESS is generally limited to 40 kWh or 80 kWh, depending on the location of the system within an R-3 occupancy (reference Appendix A).

An illustrative home in San Francisco using 8,760 kWh of electricity per year, would average 24 kWh of electricity per day. For single family homes under R-3 occupancies, this 20-kWh limitation is typically sufficient, as a 13.5 kWh BESS can power the critical electrical systems, excluding electric heat and air conditioning, in an average house for 24 hours. However, this size of BESS may become increasingly strained as single-family home residents begin to electrify their space heating, water heating, and cooking equipment, add at home EV charging stations, and growing interest in energy resilience and self-reliance like those looking to meet San Francisco’s goal of 72-hour disaster recovery (SF72). This is exacerbated when applying this size of BESS to more dense residences like duplexes. Furthermore, if applicants are aiming to achieve whole home backup for even short periods of time, under all R-3 occupancy types, multiple BESS units would need to be combined.

Under SFFD’s interpretation of BESS “system” and “unit”, these latter scenarios would be subjected to the additional installation and permitting requirements for aggregate BESS over 20 kWh.

6.2.2 Ventilation
Indoor BESS that produce hydrogen or other flammable gases during charging shall be provided with mechanical ventilation in accordance with the San Francisco Mechanical Code. Of the three battery chemistries under consideration, this requirement would apply to lead-acid based BESS. BESS that have the potential to release toxic or highly toxic gas during charging, discharging, and normal use conditions shall not be installed within Group R-3. None of the battery chemistries considered fall under this restriction.

6.2.3 Permitting Requirements
A construction permit is required for BESS at 20 kWh or greater or for any BESS with liquid capacities exceeding 50 gallons in Group R-3 occupancies. DBI requires an electrical permit for construction, and additional building permits may be necessary depending on the scope of work. SFFD requires a construction permit for systems of 20 kWh or greater, as well as operational permits of systems with 50 gallons or more of electrolyte.
7,8 Compared to SolarAPP+ permits that can be automated for individual BESS units less than 20 kWh, larger systems where individual BESS units exceed 20 kWh can incur permitting fees of $6,000 or more.

While individual BESS in residential applications are unlikely to exceed this limit based on typical market sizing of residential BESS, the SFFD interpretation detailed in Section 6.2.1, forces BESS that, either in aggregate or individually, exceed the 20 kWh threshold to obtain a construction permit.

6.2.4 Listings
BESS shall be listed and labeled in accordance with UL 9540.9 BESS less than 1 kWh are not required to be listed and labeled in accordance with UL 9540.

The UL 9540 listing provides the confidence that a baseline level of safety has been met. The UL 9540 listing references UL 9540A “Test Method for Evaluating Thermal Runaway Fire Propagation in Battery Energy Storage Systems” which is a testing methodology to determine how components within the BESS act in thermal- runaway failure scenario from the cell level to the unit level of the system. 10 6.2.5 Vehicle Impacts
BESS must comply with applicable requirements of CFC §1207.11.7.1. Where a BESS is installed in the normal driving path of vehicle travel within a garage, impact protection complying with §1207.11.7.3 shall be provided.

7 Get a permit for a Solar photovoltaic system | San Francisco (sf.gov) 8 2022 San Francisco Fire Code T-107-A
9 UL 9540 Energy Storage System (ESS) Requirements - Evolving to Meet Industry and Regulatory Needs | UL Solutions 10 UL 9540A Test Method | UL Solutions

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Where clear height of vehicle garage opening is 7 feet 6 inches or less, ESS installed not less than 36 inches above finished floor are not subject to vehicle impact protection requirements. Impact protection must be implemented per §1207.11.7.3 and either include bollards at least 6 inches from the BESS or wheel barriers not less than 54 inches from the BESS.

Vehicle impact protection protects the BESS from vehicular damage since such damage could result in thermal runaway or fire from abnormal conditions. This results in an increased level of safety for BESS that is installed in areas with a higher-than-normal risk of damage.

6.2.6 Space Requirements for Outdoor Specific Installation SFFC allows BESS to be installed outdoors not less than 3 feet from doors and windows. The purpose of the 3- foot separation from doors and windows is because, such openings create a pathway for fire to spread into the home more easily than an exterior wall. Where the exterior walls of homes are located closely adjacent to property lines or other homes, the exterior installation of BESS may be challenging.

Separation using fire-rated assemblies is not required unless the aggregate rating of the BESS exceeds 200 kWh, which is not typical of BESS used in R-3 occupancies. The SFFC does not outline egress or public way requirements for BESS of 20 kWh or less, but notes egress requirements for BESS larger than 20 kWh are as required by the fire code official, but not less than 10 feet.

6.2.7 Space Requirements for Interior Installation
The SFFC requires that BESS shall be installed only in the following locations:

1. Detached garages and detached accessory structures.

2. Attached garages separated from the dwelling unit living space and sleeping units as follows:
a. For attached garages located below habitable rooms, the separation shall be constructed of a minimum 5/8-inch Type X gypsum board or equivalent.
b. From the residence and attics, the wall separation shall be not less than a ½-inch gypsum board or equivalent on the garage side.

3. Outdoors or on the exterior side of the exterior walls located not less than 3 feet from doors and windows directly entering the dwelling unit.

4. Enclosed utility closets, basements, storage or utility spaces within dwelling units with finished or noncombustible walls and ceilings. Walls and ceilings of unfinished wood-framed construction shall be provided with not less than a 5/8-inch Type X gypsum wallboard.

Individual BESS units shall be separated by at least 3 feet of spacing. Clearance of 3 feet shall be provided in front of electrical equipment for maintenance purposes and kept clear of combustible storage. Any eaves, structures, decking, or other such construction protruding more than 2 feet from the exterior wall upon which the BESS is installed shall be located at least 3 feet from the BESS unless exterior walls and eaves are constructed with noncombustible surfaces.

SFFD AB 5.12 allows spacing requirements to be reduced from 3 feet upon review and approval by the AHJ when complying with CFC §1207.1.5 and §104.8.2. For approval, the applicant is required to submit copies of both UL 9540A testing report and installation instructions showing recommended reduced spacing between the ESS unit(s) being installed. If minimum spacing varies between the two documents, the more restrictive separation distance will be approved.

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6.2.8 Additional Installation Requirements per SFFD Bulletin 5.12 For exterior installations of BESS, the AB 5.12 requires the following:
• Property lines and means of egress: minimum separations of 3 feet may be reduced to 12 inches where a 1- hour free-standing fire barrier and extending 3 feet above and 3 feet beyond the physical boundary of the BESS installation is provided to protect the exposure.
• The exterior wall upon which the BESS is installed shall be located at least 12 inches from other exterior walls of the same building in either direction.
• The BESS shall be installed at a minimum of 3-feet from the public way, unless protected by a 1-hour fire barrier.

This language changes the SFFC code requirements which requires that BESS installed outdoors or on the exterior side of exterior walls be located at least 3 feet from doors and windows that open directly into the dwelling unit. This interpretation has additional implications for permitting BESS as it may require the Planning Department review.

For interior installations of BESS that are installed within 3 feet from the property line, AB 5.12 requires the following: the BESS shall be installed on not less than on a layer of 5/8 inch Type X gypsum board that extends not less than 4 feet in vertical directions, which is installed from the floor to the ceiling and not less than 4 feet across the ceiling from the wall on which the BESS is mounted.

Installing BESS in the permitted locations is intended to help compartmentalize fire away from normally occupied areas of the home for enough time to ensure safe egress. Locating individual BESS units away from each other will help prevent the spread of fire from one unit to another. Locating BESS systems away from a means of egress will ensure safe egress from any fire that originates from the BESS. These spacing requirements may reduce the flexibility of BESS installations in smaller occupancies, but ultimately ensure the safe egress of occupants during a fire and mitigate fire size by containing fire to a single BESS unit.

The additional language surrounding the additional Type X gypsum installation does pose a significant barrier when applied to San Francisco. The city contains a significant portion of R-3 occupancy buildings that share walls with buildings on either side, surpassing the 3-foot minimum property line requirement and ultimately requiring the Type X gypsum installation. This means each of these individual residences will need to install not less than one layer of 5/8 inch Type X gypsum board that extends not less than 4 feet in vertical directions, installed from the floor to the ceiling and not less than 4 feet across the ceiling from the wall on which the BESS is mounted. These are considerable design additions for CCSF applicants to account for. When this scenario is paired with raising demand for at-home energy storage systems, and a workforce not yet equipped to handle that demand, this barrier can grow into a significant deterrent for BESS uptake.

6.2.9 Fire and Gas Detection
2019 California Residential Code §R327.7 required rooms and areas within dwelling units, sleeping units, basements, and attached garages in which ESS are installed to be protected with a listed heat detector interconnected to a smoke alarm when smoke alarms cannot be installed based on their listing. 2019 California Fire Code §1206.11.6 contained this language as well. When the codes were written, and currently, listed heat detectors do not exist. Therefore the 2022 California Fire and Residential codes were changed to “a listed heat alarm.” There are not commercially available heat alarms listed for installation in unconditioned spaces where the temperature can exceed 100°F and installation of existing listed heat alarms in those conditions could create nuisance alarms.
11 12

11 Information Bulletin - 2019 California Residential Code section R327.7 12 https://34c031f8-c9fd-4018-8c5a-4159cdff6b0d-cdn-endpoint.azureedge.net/-/media/osfm-website/resources/information- bulletins/ib_ess_heat_detector_residential_code_final.pdf

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This led to confusion on how the code can be met and was a driving factor for the California State Fire Marshal Bulletin 21-004 and the subsequent interpretation from SFFD via AB 5.12. The State Fire Marshal has suggested local jurisdictions consider alternates to the use of heat alarms until clearer guidance and listed devices are available. Unconditioned garages are typical locations within Group R-3 occupancies of San Francisco where BESS would be installed, and therefore interim solutions are needed and should consider if the garage has fire sprinkler protection and expected ambient temperatures based on location and exposure.11 AB 5.12 provided additional language requiring areas containing BESS to be protected by one of the following:
• Existing fire alarm system shall be expanded to provide heat detection and notification. This requires a Fire- Only Permit.
• Install UL 539/CFSM listed interconnected heat alarm above the BESS area for applications where there is an existing UL 539/CSFM listed interconnected heat alarm and the garage/unconditioned BESS area does not exceed 100 degrees Fahrenheit. This requires a DBI permit since the interconnected heat alarm is hard- wired with battery backup.
• Install UL 539/CFSM listed interconnected heat alarm above the BESS area and heat alarm inside each dwelling unit in an approved location near the door leading to the garage/BESS space for applications where there is no existing system and the garage/BESS area does not exceed 100 degrees Fahrenheit. This requires a DBI permit since the interconnected heat alarm is hard-wired with battery backup. • Install a dedicated function UL 864/CFSM listed Fire Alarm Control Unit in an approved location at the dwelling unit. UL 521/CSFM listed heat detectors shall be installed at the BESS areas and compatible horns/audible appliance at the BESS and inside the dwelling unit for applications where there is no existing system and the garage/BESS area does exceed 100 degrees Fahrenheit. This requires a Fire-Only Permit.

7. Comparable Municipalities ESS Codes and Policies for R-3 Occupancies

7.1 Summary
Five cities’ state, local, electrical, and fire codes and policies for BESS in Group R-3 occupancies were compared to San Francisco. Those five cities were: Austin, Texas, Chicago, Illinois, Fremont, California, New York City, New York, and San Jose, California.

The key takeaways regarding requirements and limitations to installing BESS are:
• New York City has more stringent allowable maximum battery size standards, explosion mitigation standards, sprinkler system standards, and monitoring and detection standards. • Austin, Chicago, Fremont, and San Jose codes are similar to San Francisco’s requirements. However, San Francisco’s interpretation of the SFFC in AB 5.12 provides clarifications and additional requirements for installations of BESS in Group R-3 occupancies. More in-depth comparisons are shown in Sections 7.2, 7.3,

7.4, 7.5, and 7.6, and in Appendix A.

7.2 Austin, Texas
Austin and San Francisco’s BESS codes and restrictions for Group R-3 occupancies are almost identical with no noteworthy differences.

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7.3 Chicago, Illinois
Chicago and San Francisco’s BESS codes and restrictions for Group R-3 occupancies differ slightly in the following ways:
• Chicago’s energy storage capacities are less stringent and have a 600 kWh per fire area maximum allowable quantity (MAQ) for lithium-ion batteries. For all other battery types, refer to International Fire Code Table 1206.2.9.
• Chicago’s has not specifically listed fire rated walls and enclosure requirements. San Francisco requires 20 kWh or greater BESS to be separated from other rooms in a building by 2-hour fire barriers. San Francisco also allows 1-hour fire barrier protection around a BESS to reduce the required clearance from property lines, means of egress, and the public way by 3 feet.

7.4 Fremont, California
Fremont and San Francisco’s BESS codes and restrictions for Group R-3 occupancies are similar besides the following exception: Fremont has not created a local interpretation of Section 6.2.8’s California Fire Code installation requirements.13

7.5 New York City, New York
New York City (NYC) and San Francisco’s BESS codes and restrictions for Group R-3 occupancies differ in the following ways:

1. NYC has more stringent energy storage capacities regulations. BESS’ maximum rated energy capacity should not exceed 20 kWh, and BESS’ maximum aggregate should not exceed 20 kWh/dwelling unit, 40 kWh for a 2-hour fire barrier wall when in attached garages, or 40 kWh in attached garages.

2. NYC has more stringent permitting requirements. NYC requires permits for outdoor BESS only if the installation is larger than 20 kWh for lithium-ion chemistries or 70 kWh for lead-acid chemistries. Only a supervisor with a Certificate of Fitness can maintained and operate outdoor BESS.

3. NYC has more stringent monitoring and detection requirements. NYC requires an approved automatic smoke detection system or radiant energy sensing fire detection system in indoor areas that contain BESS.

Remote monitoring is required for all outdoor BESS.

4. NYC has more stringent outdoor-specific requirements. Outdoor lithium-ion BESS greater than 250 kWh and lead-acid BESS greater than 500 kWh cannot be installed in enclosed areas without direct access from a public street or fire access road unless full testing occurs.

5. NYC has more stringent space requirements. Indoor BESS cannot be installed below grade in a dwelling unit or garage.

6. NYC has more stringent sprinkler and fire extinguishing requirements. NYC requires fire extinguishing for outdoor lithium-ion BESS greater than 250 kWh and outdoor lead-acid BESS greater than 500 kWh.

7. NYC has less stringent explosion mitigation requirements. San Francisco has a blanket explosion mitigation requirement for all lead-acid, Ni-Cd, Ni-MH, and lithium-ion BESS. NYC only requires explosion mitigation for outdoor lithium-ion BESS greater than 250 kWh and outdoor lead-acid BESS greater than 500 kWh.

8. NYC has more stringent fire rated wall and enclosure requirements. NYC requires that all indoor BESS are protected by a 1-hour fire barrier when the clearances prescribed in sections 6.2.6 and 6.2.7 are reduced.

13 Due to existing building conditions in Fremont, including setbacks from buildings on adjacent parcels and from the public right of way, the addition of a local ordinance similar to SFFD Bulletin 5.12 would likely not impact BESS installation.

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7.6 San Jose, California
San Jose and San Francisco’s BESS codes and restrictions for Group R-3 occupancies are similar; however, San Jose has not created a local interpretation of Section 6.2.8’s California Fire Code installation requirements. San Jose’s existing building stock was constructed recently. As a result, due to differences in building form and age, there are significant setbacks from buildings on adjoining parcels and from the public right of way. As a result, if San Jose adopted AB 5.12’s interpretations, BESS installation could likely proceed unhindered.

8. State and SF Local BESS Codes and Policies for R-2
Occupancies

8.1 Introduction
In this section, we will examine state and local codes and policies for BESS in R-2 occupancies. Key requirements and limitations are energy capacity limits on BESS size, indoor and outdoor BESS separation distance requirements, indoor BESS installation sprinkler system standards, explosion mitigation requirements, spill control requirements, and upgraded enclosure construction requirements.

8.2 San Francisco
In San Francisco, for R-2 occupancies, the SFFC and SFEC regulations apply.

8.2.1 Energy Capacity
The MAQ of a lithium-ion BESS is 600 kWh per fire area. San Francisco requires that electrochemical BESS must be segregated into groups less than 50 kWh. Each BESS group must be separated a minimum of 3 feet from other BESS groups and walls unless a fire code official permits otherwise.

According to the U.S. Energy Information Administration, apartment buildings in the West use an average of 5,365 kWh per unit in 2020, which is about 15 kWh per unit per day. In R-2 occupancies, 600 kWh could supply 24 hours of uninterrupted energy to about 40 units in the case of a power outage.

8.2.2 Ventilation
San Francisco requires exhaust ventilation in areas containing lead-acid, Ni-Cd, Ni-MH, and flow battery technologies. Lithium-ion batteries do not produce toxic gas under normal operating conditions and do not require exhaust ventilation.

Ventilation systems must limit flammable gas concentrations to 25% of the lower flammability limit (LFL) in the area containing the BESS. Otherwise, mechanical ventilation is required at a minimum rate of 1 ft3/min/ft2.

8.2.3 Permitting Requirements
BESS installations require construction and operational permits, which can be obtained online.

8.2.4 Listings
BESS must be listed in accordance with UL 9540. A UL 9540 listing ensures a baseline level of safety and compatibility for a BESS’ integrated components. The UL 9540 listing references UL 9540A, which is the “Test Method for Evaluating Thermal Runaway Fire Propagation in Battery Energy Storage Systems.” This testing methodology examines how components within a BESS act in a worst-case scenario. UL 9540A tests BESS from the cell level to the unit level. UL 9540A models how thermal runaway may propagate through the system and to adjacent systems and areas. This test is used to reduce spacing between units.

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8.2.5 Monitoring and Detection
San Francisco requires that lead-acid, Ni-Cd, Ni-MH, and lithium-ion BESS installations have a device that prevents, detects, and contains thermal runaway events. Many commercially available BESS come equipped with a battery management system (BMS) designed to monitor and control the charging, discharging, and overall performance of a battery while maintaining its health and capacity. The BMS is covered by the battery’s required UL 9540 listing. The BMS system must disconnect electrical connections to the BESS or otherwise place it in a safe condition if potentially hazardous temperatures or conditions arise (e.g., short circuits, over voltage, or under voltage).

8.2.6 Vehicle Impacts
Vehicle impact protection must be installed in areas where motor vehicles may come in contact with BESS.

BESS subject to impact by a motor vehicle, including forklifts, shall be provided in accordance with CFC Section 312. Vehicle impact protection includes guard posts that comply with the following requirements:

1. Constructed of steel not less than 4 inches in diameter and concrete filled

2. Spaced not more than 4 feet between posts on center

3. Set not less than 3 feet deep in a concrete footing of not less than a 15-inch diameter

4. Set with the top of the posts not less than 3 feet above ground

5. Located not less than 3 feet from the protected object Vehicle impact protection protects BESS from vehicular damage, and such damage could result in thermal runaway or fire from abnormal conditions. This results in an increased level of safety for BESS that are installed in areas that pose a higher-than-normal risk of damage.

8.2.7 Space Requirements for Outdoor Installations
BESS located outdoors are required to be separated by a minimum of 10 feet from any means of egress, lots lines, public ways, buildings, stored combustible materials, and other exposures. This separation distance is permitted to be reduced by providing free-standing fire barrier around the BESS, or by providing upgrades to the exterior wall of an adjacent building. Additionally, areas within 10 feet of outdoor BESS are required to be cleared of combustible vegetation.

BESS is permitted to be installed outdoors on exterior walls where the maximum energy capacity of individual units does not exceed 20 kWh and individual units are separated from each other by 3 feet and doors, windows, HVAC inlets and other openings by 5 feet.

Doors and windows, which are generally unprotected openings in residential occupancies, create a pathway for fire to spread into the home more easily than an exterior wall would, giving reason to the mentioned spacing requirement. The exterior installation of BESS may be challenging where the exterior walls of homes are located close to property lines or other homes.

8.2.8 Space Requirements for Indoor Installation
Each electrochemical BESS group must be separated a minimum of 3 feet from other groups and from walls in the storage room or area. This is to prevent flame propagation between individual BESS groups or between a BESS and an adjacent wall.

Electrochemical BESS may not be installed in areas where the floor is located more than 75 feet above the lowest level of fire department vehicle access or below the lowest level of exit discharge.

8.2.9 Sprinkler Requirements and Fire Extinguishing Systems Areas containing BESS are required to be protected by one of the following:

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1. Automatic sprinkler coverage with minimum density of 0.3 gpm/ft2 based on the fire area or 2,500 ft2 design area; whichever is smaller

2. Automatic sprinkler coverage with a hazard classification based on large-scale fire testing

3. An approved alternative automatic fire-extinguishing system A sprinkler system with a design density of 0.3 gpm/ft2 over 2,500 ft2 is sufficient to protect an Extra Hazard Group 1 occupancy, which is defined as an occupancy where the quantity and combustibility of contents are very high and dust, lint, or other materials are present, introducing the probability of rapidly developing fires with high rates of heat release but with little or no combustible or flammable liquids.14 This is a more demanding system than what is typically required in common areas of R-2 occupancies, including guest rooms, restrooms, parking garages, and mechanical, electrical, and storage rooms.

8.2.10 Fire and Gas Detection
An automatic smoke detection system or radiant energy-sensing fire detection system is required to be provided in rooms, indoor areas, and walk-ins containing electrochemical BESS. An approved radiant energy-sensing fire detection system is required to be provided in open parking garages and rooftops where BESS is installed. Alarm signals from detection systems are required to be transmitted to a central station, proprietary or remote station service.

This requirement is not overly burdensome or costly as many R-2 occupancies are provided with smoke detection regardless of any BESS installations.

8.2.11 Explosion Mitigation
Explosion control complying with CFC §911 is required for Lithium-ion, Ni-Cd, and Ni-MH ESS battery types.

Explosion control will be achieved by providing deflagration venting, deflagration prevention systems, or barricades.

Usually, deflagration vents are the least costly solution, although they introduce additional requirements and constraints, and can still be expensive. Firstly, walls, ceilings, and roofs exposing surrounding areas are required to be designed to resist a minimum internal pressure of 100 lb./ft 2, which is a costly and difficult upgrade from a
typical gypsum stud wall. Secondly, deflagration vents are only permitted to be provided on exterior walls and roofs and may only discharge directly to the exterior of the building where an unoccupied space not less than 50 feet in width is provided between the exterior walls of the building and the lot line. Considering the proximity of neighboring buildings in San Francisco, this may be a difficult constraint to navigate.

8.2.12 Spill Control
Areas containing free-flowing liquid electrolyte or hazardous materials with Lead-acid, Ni-Cd, Ni-MH, and Flow ESS battery technologies are required to be provided with spill control. As such, lithium-ion batteries are not required to be provided with spill control.

Where required, spill control is relatively inexpensive and can be as simple as providing a spill berm capable of containing a spill from the single largest battery.

8.2.13 Fire Rated Wall and Enclosure Requirements
Enclosures of ESS shall be of noncombustible construction. In dedicated-use buildings, areas containing ESS shall be separated from areas in which administrative and support personnel are located by 2-hour fire barriers.

In nondedicated-use buildings, areas containing ESS shall be separated by other areas in the building by 2-hour fire barriers.

14 2019 NFPA 13 §3.3.134.1

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A fire barrier having a 2-hour fire resistance rating means that the fire barrier assembly can withstand an ASTM E119 test furnace on one side of the assembly for 2 hours without any flame penetration through the wall, ttemperature rise on the unexposed side of the wall beyond prescribed limits, and structural failure or collapse of the assembly. This fire resistance rating provides a baseline level of safety for the enclosure housing the BESS.

9. Review of City Permitting by Building/Zoning Type
and Storage Size
In September 2022, Chapter 356 of Senate Bill 379 (SB 379) was approved by the State of California and aims to streamline the permitting process for Solar energy systems and related energy storage systems serving residential properties. This bill targets single-family homes and buildings with no more than two units, also referred to as Group R-3 occupancy buildings. Cities and counties complying with SB 379 will have implemented an online, automated permitting system to verify code compliance and issue permits in real time.

San Francisco has complied with SB 379 and has established an online Solar permitting program using SolarAPP+, an online software facilitating the permitting process covering the energy systems of interest in SB 379 and is administered by NREL. To qualify for use of SolarAPP+, projects shall meet all the following criteria:15

1. Existing single- or two-family home (R-3 occupancy)

2. Photovoltaic and energy storage system are onsite

3. Does not include a ballasted or ground-mounted PV system

4. Is not a new service or panel upgrade

5. Meets the technical specifications listed by the City

6. Complies with the SFFD AB 5.12
The no-cost process of using SolarAPP+ issues an approval ID, inspection checklist, and specification sheet which is required for submission for the electrical permit. Users are then permitted to install their energy system, which is then subjected to inspection and approval by the SFFD and DBI.

For residential Solar energy permits, residential permits shall not exceed $450 plus $15 for every additional kilowatt above 15 kW. Only under reasonable and documented evidence shall this limit be exceeded.16 This cap applies to the entire jurisdiction and does not consider whether one department is providing a review, or multiple departments are (e.g., DBI and SFFD). For field inspections administered by the SFFD, the hourly fee begins at $144, which can increase application costs, particularly if additional inspections are required. Inspections by DBI start at $181.82 per hour. This is a financial burden for San Francisco since the departments are limited in recouping the costs of time spent on additional processing and reviews. Even when the additional building permit is not triggered by the BESS being over the 20 kWh threshold, it is still subject to structural review to screen whether the application must be put on hold until a building permit is secured, and the new system can be appropriately supported structurally. If it is determined that the structural work and additional strengthening is not needed and the additional building permit is not pulled, then the structural review cost is absorbed by the department. Similarly, costs for the electrical plan check and administration of an electrical trade permit for systems under 20 kWh are also absorbed by the DBI.

15 Get a permit for a Solar photovoltaic system | San Francisco (sf.gov) 16 Section 66015 - [Effective until 1/1/2034] Residential and commercial Solar energy systems, Cal. Gov. Code § 66015 | Casetext Search + Citator

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As of September 30th, 2023, NREL has reported the CCSF have issued 54 permits for photovoltaic systems (without energy storage systems) and 15 permits for photovoltaics with storage systems for a total capacity of 491 kWh approved.17 Since its adoption, the use of SolarAPP+ for this jurisdiction has saved an estimated 71 hours for first time permit reviews.17 For context, there are approximately 149,000 single- and two-family homes in San Francisco, indicating that there are likely multiple factors contributing to a low rate of BESS implementation in San Francisco rather than permitting. At the time of this memo’s writing, DBI and the SFFD were not experiencing high volumes of BESS applications. The SFFD reported an estimate of 1-2 SolarAPP+ applications per week, and 1-2 applications per month that warrant more thorough reviews and permitting due to exceeding BESS threshold sizes or deviating from SFFD installation requirements. The review of applications through the SolarAPP+ take the SFFD approximately 5 hours to complete which they are currently able to manage with an unregulated two-week turnaround. Current resourcing at SFFD would be limited to five SolarAPP+ applications per week before they are unable to manage turnaround within that same period, at which time the timeline becomes unknown.

10. Existing Storage and Rooftop Solar Data
To supplement findings from the technology, municipal code, and permitting reviews, Arup conducted a review of publicly available data containing existing energy storage and Solar installations in California. This aspect of the project was intended to allow us to visualize where the state has seen significant uptake in different types of energy storage systems (ESS). This visualization would identify the municipalities with more uptake in this realm as well as areas that may be at risk of missing an opportunity to benefit from this technology. Findings from this work can be used to inform future research, partnerships, and data collection efforts in this space.

Finding reliable storage and rooftop data that is publicly available proved difficult due to a lack of data collection standardization. Additionally, because the most granular spatial unit associated with the available datasets is the ZIP code, there is no reliable way to distinguish between R-2 and R-3 residential types across all datasets. After reviewing a variety of datasets sourced from utility companies and public agencies, the project team was not able to secure sufficiently robust data that could reliably illustrate existing installations isolated by residential occupancy type. Without comprehensive storage and rooftop solar data that allows distinction between R-2 and R-3 occupancy types, findings using the publicly available data would not provide an accurate representation of the total number of installations throughout San Francisco; any additional analysis like those to assess opportunities for solar and storage in disadvantaged communities (DACs) would be misguided.

One of the most promising datasets that provided some distinction between residential occupancies was application data from state incentive programs such as Multi-family Affordable Solar Housing (MASH), Solar on Multi-family Affordable Housing (SOMAH), and Single-family Affordable Solar Homes (SASH). Arup found that the datasets were reporting unexpectedly low installation amounts across CCSF, and even zero installations for single family affordable homes. While not meant to represent the entire stock of rooftop solar installations on multi-family and single-family housing, the reliability of this data was called into question when compared to GoSolarSF Program data that was available to the client team. GoSolarSF offers financial incentives to support the installation of rooftop solar panels across the City and keeps complete records from the program’s history. Because there was overlap in the incentive programs represented by the publicly available data and the GoSolarSF data, the client team was able to identify that the publicly available data was missing records. According to SFPUC GoSolar program data, since 2008 the GoSolar program provided over 1,000 systems with rebates for low-income applicants. Between 2008 and 2019, there were a total of 165 disadvantaged community SASH rebates. Arup was not able to access this dataset from SFPUC to verify, but the disconnect between reported GoSolar data from the SFPUC and the SASH dataset should be investigated further for proper alignment. The data sources, process, and visualizations of this data exercise are detailed further in Appendix A.1.1.

17 SolarAPP+™ | SolarAPP+ Adoption at a Glance (nrel.gov)

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The current landscape of BESS installation data is complicated by the many different technologies, many of which can be combined in a single installation. When data is reported from different sources, in this case utilities, there is some discrepancy in the categorization, and it becomes difficult to isolate BESS systems from general ESS. This is sure to improve over time as agencies innovate better ways to collect and publish data efficiently and effectively. Though the data needs to be investigated further for accuracy, the ESS data demonstrated that San Francisco installations largely pair BESS with Solar PV installations. The available data does not show which Solar installations are not yet bolstered with BESS. This category of installations would be the best candidates for BESS technology, but there is no way to isolate it with publicly available data. Finding this information would likely require outreach to Solar installation owners.

11. Financial Resources for BESS Implementation

11.1 State and Federal Financial Incentives
Table 3 below shows a list of applicable BESS financial incentives, rebates, and tax credits currently available, that can be used to spur growth in residential BESS installations. Since funding, grants, and financial incentives come in waves, and that funding is targeted differently each time with different eligibility requirements, securing funding is always a moving target. Therefore, this table represents a snapshot of funding available now, and is likely to change in the future as some funds become exhausted and others become available.

There is a wide array of State and Federal incentives for clean energy and energy efficiency, which include a mixture of tax credits, grants, rebates, and financing options for residential, business, and community projects.

Tax credits are available for 30% of the cost of battery storage and solar energy systems for homes and businesses with the Residential Clean Energy Tax Credit. Total grant availabilities range from $3 million for rural energy improvements (USDA High Energy Cost Grant Program) to $14 billion for national clean technology financing (via the National Clean Investment Fund), with targeted funds for low-income and disadvantaged communities. Property tax exclusions can cover 75% of solar and BESS system costs, and upfront incentives are offered for self-generated electricity. Additional programs provide affordable financing (R- PACE), accelerated depreciation for solar and storage systems (MACRS), and $101.5 million for low-income multi-family energy efficiency upgrades.

To keep up to date on the newest and most relevant funding opportunities, agencies seeking to tap into those opportunities to support initiatives and programs for BESS implementation must be vigilant in their incentives research, continuously stay informed on new opportunities, and employ staff that are equipped to interpret funding language, requirements, and processes. To help agencies better track these clean energy state and federal financial opportunities, websites have been developed to consolidate financial opportunities. One such aggregator website is https://www.dsireusa.org/
(Database of State Incentives for Renewables & Efficiency) which can be leveraged to identify applicable grants, rebates, and tax credits as they are made available to fuel the transition to a cleaner more resilient economy.

Table 3: State and Federal Financial Incentives
Incentive Name Incentive Summary Maximum Incentive Available 1 Residential Clean
Energy Tax Credit -
Battery Storage
Technology Tax Credit
Tax credit for battery installation for existing
homes or new construction Tax credit for 30% of system cost 2 Residential Clean
Energy Tax Credit -
Solar Energy Systems
Tax Credit
Tax credit for solar installation for existing
homes or new construction Tax credit for 30% of system cost

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Incentive Name Incentive Summary Maximum Incentive Available 3 Business Energy
Investment Tax Credit
(ITC)
Tax credit for solar and battery installation for
existing homes or new construction Tax credit for 30% of system cost 4 USDA - High Energy
Cost Grant Program
Grant program for the improvement of energy
generation, transmission, and distribution
facilities in rural communities
$3 million grant
5 Property Tax Exclusion
for Solar Energy
Systems and Solar Plus
Storage Systems
Property tax exclusion for certain types of solar
energy systems installed between January 1,
1999, and December 31, 2024
Tax credit for 75% of system cost (on property
taxes)
6 Self-Generation
Incentive Program
(SGIP)
Incentives to customers of SDG&E, PG&E,
SCE, or SoCal Gas who produce electricity with
wind turbines, fuel cells, PV, various forms of
combined heat and power and advanced energy
storage
Upfront incentive (or half of this figure if the
system is 30 kW or larger):
• Solar Generation: $2.00/W
• Small Residential Storage: $0.15/Wh -
$0.20/Wh
7 Net Metering/Net
Billing
Net Billing Tariff (often referred to as “NEM

3.0”). Credited to customer's next bill at the
utility’s avoided cost, to receive payment for the
surplus power generated.

NBT. Credited to customer's next bill at the
utility’s avoided cost. Customer to receive
payment for the surplus power generated. It
should be noted that NBT provides much lower
rate in the middle of the day during solar hours
than the older NEM 2.0.
8 R-PACE Residential
Property Assessed
Clean Energy
Affordable financing that expands access for
homeowners to make critical energy efficiency,
renewable energy, environmental conservation,
and disaster resiliency improvements to their
properties
Examples of property-based underwriting
standards may include the following:
• The PACE assessment does not exceed
20% of the fair market value of the
property.
• The combined mortgage related debt and
the PACE assessment do not exceed the
value of the property
9 MACRS (Modified
Accelerated Cost
Recovery System) for
Solar + BESS
A special accelerated depreciation schedule to
reduce year end taxes for PV + BESS systems
7-year MACRS (without solar) or 5-year
MACRS (with solar)
10 Low-Income
Weatherization
Program's (LIWP)
Multi-Family Energy
Efficiency and
Renewables
Component
Technical assistance and incentives for the
installation of energy efficiency measures and
solar photovoltaic systems in low-income multi-
family dwellings
$101.5 million available
11 National Clean
Investment Fund [Part
of the Greenhouse Gas
Reduction Fund
(GGRF)]
Provides grants to 2–3 national nonprofit clean
financing institutions capable of partnering with
the private sector to provide accessible,
affordable financing for tens of thousands of
clean technology projects across the country.

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Incentive Name Incentive Summary Maximum Incentive Available clean technology projects—with at least 40% of
capital flowing into low-income and
disadvantaged communities.
12 Clean Communities
Investment Accelerator
[Part of the
Greenhouse Gas
Reduction Fund
(GGRF)]
Provides grants to 2–7 hub nonprofits that will,
in turn, deliver funding and technical assistance
to build the clean financing capacity of local
community lenders working in low-income and
disadvantaged communities—so that
underinvested communities have the capital they
need to deploy clean technology projects.

These hub nonprofits will enable hundreds of
public, quasi-public, not-for-profit, and non-
profit community lenders—such as community
development financial institutions, credit unions,
green banks, housing finance agencies, minority
depository institutions, and many others—to
finance clean technology projects in low-income
and disadvantaged communities, with 100% of
funds dedicated to these communities.
$6 billion available
13 Disadvantaged
Communities – Single-
Family Solar Homes
program
California's DAC-SASH program (approved by
the CPUC) provides solar incentives for low-
income customers in disadvantaged
communities. Administered by GRID
Alternatives, the program offers Californians
$8.5 million in incentives annually.

11.2 Low Income Incentives
Energy poverty disproportionately affects low-income and disadvantaged communities (LIDACs) because they spend a larger percentage of their income on energy bills, often live in inefficient housing exacerbated by deferred maintenance, and have limited access to capital for energy-efficient upgrades. Financial strain further burdened by high energy costs from inefficient buildings and equipment can lead to health and safety risks when families are forced to cut back on essential heating or cooling. These risks underscore the need for targeted support to alleviate energy insecurity in disadvantaged communities and promote equity by engaging all socio- economic groups in the transition to renewable energy and ensuring they have access to the benefits of clean energy. BESS access for DACs can enable historically underserved communities to reduce monthly utility bills, enhance community resilience to energy price volatility, mitigate impacts of power outages, and enhance energy resilience. The accessibility of these systems relies on external structures of support to ensure first costs, implementation processes, technical assistance, and operational and maintenance costs are not an additional burden to DACs.

External structures that can be leveraged to support DACs in accessing renewable energy and BESS incentives are listed in Table 4 below. Many of these incentives and programs promote or even require that a certain percentage of funds go directly towards supporting disadvantaged communities. One example includes the National Clean Investment Fund, funded by the Greenhouse Gas Reduction Fund (GGRF), which has a requirement that at least 40% of capital from the fund is allocated for low-income and disadvantaged communities.

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BESS have often prohibitively high first costs that create significant barriers to DACs that are resource strained.

To maximize financial and technical support for BESS implementation in DACs, stacking incentives is an essential way to obtain the largest amount of financial support for solar and BESS projects and critical for implementing BESS in DACs despite the system’s high capital cost. Stacking incentives typically involves leveraging various financial incentives, such as tax credits, grants, rebates, or low-interest loans, to reduce the upfront costs and improve the return on investment.

Table 4 below shows a list of applicable low-income financial incentives that can be used to spur growth in residential BESS installations.

Table 4: Low Income Incentives
Incentive/Program Name Incentive Summary
1 Disadvantaged Communities –
Single-Family Solar Homes
program
California's DAC-SASH program provides solar incentives for low-income customers in disadvantaged communities. Administered by GRID Alternatives, the program offers Californians $8.5 million in incentives annually.

To qualify for DAC-SASH, homeowners must live in one of the top 25 percent most disadvantaged communities statewide using the CalEnviroScreen and be a billing customer of Pacific Gas & Electric (PG&E), Southern California Edison (SCE), or San Diego Gas & Electric (SDG&E). Homeowners must also meet income qualifications as denoted by annual CARE and FERA guidelines. See the CPUC website for more information about income limits.

The California Public Utilities Commission says that eligible customers can receive up to $3 per watt in incentives for solar installations. The current cost per watt of solar panels in California is $3.93, so DAC-SASH participants could save about 75% on solar installations.
2 Low-Income Weatherization
Program's (LIWP) Multi-Family
Energy Efficiency and Renewables
Component
Technical assistance and incentives for the installation of energy efficiency measures and solar photovoltaic systems in low-income multi-Property must contain 5 units or more in addition to:
• At least 1 building must have 5 units. If not, the property must have 20 total units. • At least 66% of tenants with incomes < 80% area median income (AMI). • Able to achieve modeled energy savings > 15%-family dwellings. • $101.5 million available
3 National Clean Investment Fund
[Part of the Greenhouse Gas
Reduction Fund (GGRF)]
Provides grants to 2–3 national nonprofit clean financing institutions capable of partnering with the private sector to provide accessible, affordable financing for tens of thousands of clean technology projects across the country.

These national nonprofit financing entities will enable families, small businesses, communities and many others to access the capital they need to install cost-saving and air pollution reducing clean technology projects—with at least 40% of capital flowing into low-income and disadvantaged communities.
4 Clean Communities Investment
Accelerator [Part of the Greenhouse
Gas Reduction Fund (GGRF)]
Provides grants to 2–7 hub nonprofits that will, in turn, deliver funding and technical assistance to build the clean financing capacity of local community lenders working in low-income and disadvantaged communities—so that underinvested communities have the capital they need to deploy clean technology projects.

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Incentive/Program Name Incentive Summary
5 Self-Generation Incentive Program
(SGIP)
The “Equity” and “Equity Resiliency” SGIP rebates lower the cost of energy storage technology to almost, if not completely, free of cost. Depending on which category a customer is eligible for, they can receive $850 per kilowatt hour under the “Equity” Category or $1,000 per kilowatt-hour under the “Equity Resilience” Category. Both of these amounts would mean an energy storage system for the home or facility would be almost, to potentially completely, free of cost.

Household income must be 80% or less of area median income (AMI).

Incentives to customers of SDG&E, PG&E, SCE, or SoCal Gas who produce electricity with wind turbines, fuel cells, PV, various forms of combined heat and power and advanced energy storage.
6 GoSolarSF
The GoSolarSF solar rebate program provided by the SFPUC began in 2008 and has provided solar rebates to over 5000 solar installations in San Francisco, including 1200 low-income residential systems. All incentive categories have become fully subscribed, except for its Low-income DAC-SASH category which continues to provide substantial rebates in cooperation with the States DAC-SASH program administered by Grid Alternatives delivering no-cost solar systems to DAC located low-income homeowners.

12. BESS Consumer Navigation and Installation
As a relatively new residential technology, CCSF residents must first be made aware of the opportunities to deploy this technology in their homes, and then be properly assisted to evolve from awareness and interest through permitting, installation, and maintenance. Residential battery systems are a significant investment, and navigating the installation, design, and permitting phases is crucial for ensuring minimized costs and timelines, safety, compliance, optimal performance, and longevity. Proper guidance helps customers make informed decisions, avoid common pitfalls, increase access to residential batteries, reduce time to install batteries, and maximize the benefits of their energy storage solutions.

A few resources to help consumers navigate the installation design, permitting, and rebates for BESS include the following:

Step by Step Permit Guidance for SF PV + BESS:18 The Step-by-Step Permit Guidance Tool provided by CCSF can be used to help prospective solar customers walk through the PV + battery permitting process. This tool walks a resident through how they can apply for a PV + battery permit by providing the following information:

1. Whether the prospective customer meets the requirements to apply for a PV system permit

2. Whether building permit, electrical permit, or SolarAPP+ can be used for permit

3. The process the prospective customer needs to follow based on the type of permit they need

4. The process the prospective customer needs to follow to get their installed system inspected This resource does not include guidance in electrical-interconnection application processes which is a critical component to safely installing BESS. Interconnection applications are complex, require time, and are routinely managed by licensed contractors installing solar and BESS systems.

18 Get a permit for a solar photovoltaic system | San Francisco (sf.gov)

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Solar Access Act and SolarAPP+:19 20 21 In 2022, California passed the Solar Access Act, Senate Bill 379 (Wiener), which requires cities and counties to adopt an online instant permitting system to allow residents to instantly obtain a permit for simple residential solar and solar-plus storage systems in real time. This will help to reduce permitting time and costs to streamline the installation of PV + BESS systems.

In response to this requirement, San Francisco adopted the use of the SolarAPP+ platform. SolarAPP+ is an online platform developed by the National Renewable Energy Laboratory (NREL) in collaboration with the US Department of Energy (DOE). The primary purpose of SolarAPP+ is to streamline and expedite the permitting process for residential solar energy systems.

The SolarAPP+ has the following benefits:

1. Instant Permitting: SolarAPP+ allows for instant approval of simple residential solar and solar-plus-storage system permits.

2. Automated Review: The platform uses automated algorithms to assess system designs and ensure compliance with safety and code requirements.

3. Reduced Wait Times: By eliminating manual reviews, it significantly reduces the time required for permitting by approximately 71 hours for first time permit reviews per applicant.

4. Standardized Process: SolarAPP+ attempts to establish consistent standards across jurisdictions, making it easier for homeowners and installers.

However, SolarAPP+ has the following disadvantages:

1. Low Usership: Since October of 2023, there have only been approximately 54 SolarAPP+ applications, indicating other factors may be influencing the low rate in PV and BESS installations or that this platform is not streamlining the process consistently for applicants.

2. Lack of Granularity: Even though this SolarAPP+ process has minimized time expended for applicant’s first review, the simple platform does not allow for detailed plans, single line diagrams, or 9540A information to be uploaded to allow for more comprehensive and proactive reviews. This limitation ultimately leaves critical design information out of permits and pushes design corrections to the field inspection incurring additional time and costs.

3. Maximum Allowable BESS Size: For BESS permitting of 20 kWh or larger, additional requirements and inspection are needed to meet the permitting standards. CalSSA has flagged that the average desired system size is over 20 kWh.

4. ‘Not-So-Standardized’ Standardized-Process: While the SolarAPP+ attempts to establish confident standards across jurisdictions, the various jurisdictions still have a different understanding and interpretation of the code. The process across jurisdiction differs, which means contractors are never properly in the loop since they are constantly evolving to the jurisdiction they are installing in. One example of how different interpretations of the code impact this process is the use of the terms “panel,” “system,” and “unit,” interchangeably, sometimes to mean the same thing, and when referring to different things. This lack of standardization can cause issues in the permitting process.

5. Excludes Existing PV-Only Systems: SolarAPP+ does not currently support users who already have a PV system and want to add a BESS, even if the BESS complies with the threshold requirements to use the permitting platform.

19 https://www.energy.ca.gov/programs-and-topics/programs/residential-solar-permit-reporting-sb-379 20 SolarAPP+™ | SolarAPP Adoption at a Glance (nrel.gov) 21 SolarAPP+™ | Solar TRACE (nrel.gov)

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Energy Storage Permitting Guidebook:22 23 The Center for Sustainable Energy, is creating an Electronic Energy Storage Guidebook (Guidebook) to help Authorities Having Jurisdiction (AHJs) standardize and streamline their energy storage permitting process. The goal for the guidebook (which is not yet complete) is to increase the adoption of behind-the-meter (BTM) energy storage technologies in all market sectors, by reducing the barriers and soft costs associated with permitting. The guidebook will contain lessons learned and best practices based on input from local governments, AHJs, industry representatives, state agencies and end-use customers. Furthermore, the guidebook will document and simplify the patchwork of permitting requirements into one authoritative best practices manual. It will build upon NREL’s SolarAPP+ by developing a software module that will integrate the Guidebook recommendations into the SolarAPP+ platform. The guidebook will also attempt to integrate the following topics into its recommendations:

1. CA Title 24 Standards Codes

2. SolarAPP+

3. National Simplified Residential PV and Energy Storage Permit Guideline 24 4. NFPA 855 Standard for the Installation of Stationary Energy Storage Systems

5. Safety Best practices for the Installation of Energy Storage Symbium:25 Symbium is a free software which automatically checks for code compliance and issues permits instantly for residential rooftop solar and battery storage systems. The platform helps to simplify the complex legal landscape of property development and management by translating intricate laws and regulations into straightforward workflows, effectively automating the regulatory review process for city planning. This innovation aims to empower individuals by enabling them to easily understand, visualize, and manage what is possible on their property, including the submission and management of permits, related rebates, and inspections. Currently, the software is limited to 10 jurisdictions and two unincorporated counties within California and is not yet approved to be used in CCSF territory. The software is planning to add more jurisdictions to their remit, so this resource should be revisited in the future for application to the CCSF.

DSIRE USA Clean Energy Programs Finder:
26 The Database of State Incentives for Renewables and
Efficiency (DSIRE), operated by the North Carolina Clean Energy Technology Center (NCCETC), is a comprehensive source of information on clean energy-related policies and incentives in the United States.

DSIRE provides detailed summary maps and data on financial incentives, regulatory policies, and other initiatives that promote renewable energy and energy efficiency. The database is updated regularly and serves as a valuable resource for individuals, businesses, policymakers, and researchers interested in clean energy development.

NODE Collective:27 Formally known as the National Open Data for Electrification (NODE) Collective, is a nonprofit alliance that focuses on creating and maintaining a comprehensive database of electrification incentives available across the country. By structuring and sourcing data on various incentive programs, Node Collective supports consumers in making informed decisions and encourages market actors to align with an electric-oriented future. Their efforts are instrumental in overcoming the fragmentation and confusion that often accompany the landscape of electrification rebates and incentives. This tool works with NCCETC’s DSIRE and

22 Developing the Energy Storage Permitting Guidebook | Energy Storage (energystorageca.com) 23 Resources | Energy Storage (energystorageca.com)
24 National Simplified Residential PV and Energy Storage Permit Guidelines (PDF) | SolSmart 25 Symbium - Property and Permit Information Portal
26 DSIRE (dsireusa.org)
27 NODE Collective - Powering Electrification through Open Data

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expands upon its impact by enabling the development of more consumer-facing tools with a standardized underlying dataset to navigate incentive data holistically.

EnergySage Marketplace:28 29 EnergySage’s marketplace platform empowers consumers by providing a platform to request and compare quotes from vetted local installers and providers, facilitating informed decisions and potential savings on energy solutions, including clean energy products such as solar, energy storage, and heat pumps. EnergySage partners with manufacturers of solar and battery equipment to provide promotions and rebates and can help identify those opportunities for prospective BESS owners.

13. BESS Installation Workforce and Training
The residential battery storage installation sector is a burgeoning field in the US, reflecting the growing demand for energy solutions to support solar adoption, electrification, reduce energy costs, and enhance energy resilience in the face of increasing power disruptions from aging infrastructure and intensifying weather conditions brought on by climate change. In 2019, 83% of all reported small-scale (less than 1 MW) storage power capacity in the US was in California, 31% of which was specific to the residential sector.30 However, there has been a slowdown of residential BESS installations in California, and more notably, in San Francisco over the last couple years.31 This volatility in demand for BESS has impacted the workforce trained to do this work and the supportive workforce pipelines to fuel this work’s development and implementation.

As this industry demand has ebbed and flowed over the past 5-10 years, specialized training and upskilling opportunities for workers have become available, but most lack BESS specific training, and over time some of those resources that have been made available have also been closed, like the International Brotherhood of Electrical Workers (IBEW) in San Francisco (“local 6”) who has halted their union apprenticeship classes the last several years. After reviewing currently available BESS installation and workforce trainings in San Francisco, few residential battery focused programs were found. And while there are multiple online focused BESS and microgrid trainings available, they are usually focused on larger systems rather than residential BESS.

Opportunities for San Francisco workforce development in the BESS space include:

The Energy Storage and Microgrid Training and Certification (ESAMTAC): Led by Penn State University, ESAMTAC is an online (and/or in person) education/training program and credential that prepares electrical contractors and workers for the safe and effective assembly, testing, commissioning, maintenance, repair, retrofitting, and decommissioning of energy storage and microgrid (ESM) systems. This training mostly focuses on systems larger than those used in residential applications. The course includes instruction, testing and credentialing based on skills attainment. This course is for electricians and electrical contractors. 32 Department of Industrial Relations (DIR) Electrician Certification Program: This program is to obtain certification required for persons who perform work as electricians for contractors licensed as class C-10 electrical contractors.33 This program requires the individual to complete a state-approved electrical apprenticeship, or a predetermined number of equivalent work experience hours based on certification type. At the time of this writing, the program was not accepting online applications due to a high volume of applications

28 Compare and save on clean home energy solutions | EnergySage 29 Promotions | EnergySage
30 https://www.eia.gov/analysis/studies/electricity/batterystorage/pdf/battery_storage_2021.pdf 31 CaliforniaDGStats
32 ESAMTAC
33 Division of Labor Standards Enforcement - Electrician certification program

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and limited staffing. By-mail applications currently are being accepted but all applications are taking approximately 12 weeks to review and process.

Western Electrical Contractors Association (WECA) Apprenticeships:34 A Sacramento-based apprenticeship open to individuals who are 18 years of age or older and have a high school diploma or GED. The program consists of full-time classroom training and hands-on labs for two consecutive weeks every five to seven months. This apprenticeship focuses on building commercial and residential wiremen, and though it builds out critical baseline training for future BESS workforce it lacks specific content on BESS.

Eden Area Regional Occupation Program (ROP):35 This program provides career pathways for high school students and adults that are aspiring electricians across the mid-Alameda County region. There are 6-month accelerated electrician training, 5-year journey-level hybrid training, and certified electrician continuing education programs. This training is not specific to BESS, but education on BESS may be embedded into the electrician training.

Community College Degree/Certificate Programs: Several local community colleges offer class and hands-on experience-based curriculums that, if completed, give individuals training to support future careers as general electricians. Local colleges with these offerings include Hayward, Contra Costa, and Foothill College among many others.36 37 38 39 40 There are no BESS-specific curriculums available, though education on BESS may be embedded into the inside wireman and residential wireman associate degrees and certificates.

Joint Apprenticeship and Training Committee (JATC): There are several JATCs across California, including in Alameda, Contra Costa, and San Francisco Counties, that are sponsored by the National Electrical Contractors Association (NECA) and the IBEW to create apprenticeship training programs. These programs are 3-5 years long and allow individuals to “learn while you earn” by providing wages and benefits while program individuals learn hands-on experience. There are no BESS specialties available in the apprenticeships, though training regarding BESS may be embedded in the inside wireman and residential wiremen specialties.

There is a distinct gap in BESS specific programs available for the San Francisco workforce and future workforce to get involved in. While the general electrician and electrical contractor training currently offered is critical to serve as a baseline for more specialized work, it is clear BESS specializations are lacking in the CCSF region and needed to upskill the workforce. Even though the opportunities locally are sparse, CCSF can look to other programs available to inspire future possibilities of creating their own programs, like the below program:

Los Angeles Cleantech Incubator (LACI) Microgrid Maintenance Training Program: The Advanced Prototyping Center at the LACI and Clean Power Alliance (CPA) have a combined microgrid (solar + storage) maintenance workforce training program. This program includes a specialized microgrid curriculum, hands-on training for tools and equipment, certifications, and extended internship stipends. 41 To supplement Arup’s review of local training and educational resources to support BESS implementation, Arup gleaned insights from the local solar and battery design build firms of Luminalt, the California Solar & Storage Association (CALSSA), and the San Francisco Electrical Construction Industry (SFECI). These conversations confirmed that the best way to break into the industry is to complete a community college program or an

34 Apply for Apprenticeship (goweca.com)
35 Home - Eden Area ROP (edenropadultprograms.org)
36 Apprenticeship Programs (foothill.edu)
37 Apprentices | Alameda County JATC (595jatc.org)
38 Electrician Apprenticeship School San Francisco (sfeca.org) 39 electrical training ALLIANCE || About Us
40 Electrician Schools in San Francisco, CA: Top Programs (2024 Updated) (electricianclasses.com) 41 Workforce Training and Development - Clean Power Alliance

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apprenticeship, but even then, there are limitations. Installing solar and BESS systems is a multi-craft trade and there are currently no registered solar apprentice programs in San Francisco. Currently, the C-10 electrical contractors license is required to install BESS projects, with an exception that C-46 contractors are permitted to install BESS when they are installed at the same time as a solar PV system, leading to a discrepancy between the workforce capable of doing the work and the workforce that is allowed to do the work.42 Another recent development within the workforce for BESS installation is the passing of Assembly Bill (AB) 2143, which requires ‘large customer-cited renewable electrical generation (solar) facilities, and any associated battery storage, that enroll in tariffs designed for these projects to provide prevailing wages to all construction workers and apprentices.’43 There are three exception categories outlined in the bill:

1. Residential facilities that have a maximum generating capacity of 15 kW or less, or that will be installed on a single-family home

2. Projects that are already a public work under existing law

3. Facilities that serve only a modular home, a modular home community, or multi-unit housing that has 2 or fewer stories
A consequence of this bill from a workforce development standpoint is that employees looking to train specifically on solar and BESS installation projects will be excluded from opportunities on prevailing wage jobs.

Since BESS installations must be performed by a C-10 electrical contractor, and there are only special cases where a C-46 license is acceptable, it may be difficult for some members of the workforce to gain the necessary experience and licenses required to work on these projects. This difficulty may be exacerbated by ramifications of AB 2143. IBEW expressed that there is not a huge demand for installing these systems, and incentive-based programs tend to be unpredictable in terms of workforce demand. Without intervention, these factors may make it difficult for the solar and BESS installation subset of the workforce to grow.

14. BESS as a Virtual Power Plant
An additional method of enhancing BESS installations across CCSF, is to identify opportunities for San Francisco residents to participate in Virtual Power Plant (VPP) programs. VPPs represent an innovative and sustainable approach to managing energy resources, and they are gaining traction in California, creating pathways for CCSF to follow suit. These systems integrate multiple distributed energy resources (DERs) like solar panels and BESS into a single, flexible network that can be managed and optimized in real time. Given there are no VPP programs available for San Francisco residents to partake in, the opportunities to integrate VPPs are substantial, both in terms of economic benefits and sustainability goals. VPPs could provide several advantages, including:

1. Grid Reliability: By aggregating multiple small-scale energy producers and storers, VPPs can offer a more reliable and resilient power supply, which is crucial during peak demand periods or emergencies. By offering greater demand flexibility, VPPs also protect the grid as customers increasingly electrify their heating, cooking, and transportation.

2. Cost Savings: Participants in VPPs can reduce their energy bills through demand response programs and by selling excess power back to the grid. These cost savings are particularly salient when VPPs are used to lower the demand for expensive power during peak energy demand periods.

42 https://web.cslb.ca.gov/Resources/BoardPackets/BESS_report.pdf 43 Prevailing Wage for Qualified Renewable Energy Facilities (ca.gov)

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3. Environmental Impact: VPPs help decrease reliance on fossil fuels by optimizing the use of renewable energy sources and minimize the use of high polluting peaker plants during times of high energy demand.

Currently, there are promising developments in the broader California region that San Francisco residents can look to for inspiration. Marin Clean Energy (MCE) has unveiled a VPP program, launching in 2025, which can serve as a model for future VPP aspirations in CCSF. MCE’s VPP program leverages financing from California Energy Commission (CEC) grants to specifically rehabilitate abandoned homes with energy efficiency updates as well as establish a VPP.
44 MCE’s program relies on a partnership that will assist in financing the acquisition of the abandoned homes, rehabilitating the homes, and subsequently reselling the homes as affordable properties.

Part of the rehabilitation includes upgrades that will be included in the VPP program like smart thermostats, heat pump space and water heating, and EV charging. MCE’s program encourages residents to install solar and BESS
through upfront incentives and ongoing payments to participants who contribute their energy storage systems to the aggregated network. This aggregate network can then provide grid services and enhance energy security.

Residents can sign up for this program through MCE’s website, where they can find detailed information on the benefits and the installation process.

Additional initiatives San Francisco can look towards include SunRun’s CalReady VPP program that has been successfully developing VPPs across California. Their partnerships with investor-owned utilities (IOUs) like Pacific Gas & Electric (PG&E) and Southern California Edison (SCE) as well as community choice aggregators (CCAs) like Ava Community Energy, Silicon Valley Clean Energy (SVCE), and Peninsula Clean Energy (PCE) have allowed SunRun to aggregate residential solar and battery systems for grid services. SunRun has heavily leveraged the CEC’s Demand Side Grid Support Program and is responsible for monitoring and dispatching all enrolled customer’s batteries. Similar to MCE’s program, customers are incentivized to enroll in the, CalReady program by receiving compensation for sharing their stored solar energy with the grid while SunRun manages the battery dispatching.45
While there is currently no VPP program for San Francisco residents, opportunities exist through broader regional initiatives and the potential for new programs inspired by successful models in other areas. By addressing access gaps through policy support, public-private partnerships, and community engagement, San Francisco has an opportunity to create a robust and inclusive VPP network, enhancing its energy resilience and sustainability.

15. Discussion and Key Takeaways

15.1 External Deterrents Impacting BESS Implementation in CCSF When assessing how various factors may impact the safety of BESS implementation, there is a qualitative consensus that the number of fires caused by battery malfunction is very low compared to the number of installed systems. Arup has not been able to find any data that specifically tracks the incidence of fires due to BESS in residential or commercial buildings. SFFD is working to develop a database to track how fires were started when a BESS was present (not necessarily that cause) but does not anticipate this effort will conclude for another few years, with an additional 5-10 years to properly interpret the data. Thus, Arup has no evidence to support the assumption that the current installation process in San Francisco is unsafe or needs additional regulation.

Due to fear surrounding battery fires in devices such as electric scooters, electric bikes, and handheld devices, it is worth noting that building battery systems are different from smaller and less regulated micromobility and replacement batteries. Micromobility batteries, such as those used in electric bikes and scooters, have different characteristics and risks than residential BESS, especially in terms quality control and BMS features.

44 California Community Choice Aggregator Unveils Virtual Power Plant Program | American Public Power Association 45 Sunrun sets a record in California with the US's largest virtual power plant (electrek.co)

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Micromobility batteries are often smaller, lighter, and more portable than residential batteries, which means they are more likely to be exposed to physical damage, environmental factors, and improper handling. There is little regulation of micromobility batteries and no formal permitting process, meaning micromobility batteries are not held to the same safety standards as a listed BESS system. As of March 7th, 2024, San Francisco has begun requiring all Powered Mobility Devices (PMDs) to be UL 2849 or UL 2272 listed, though there is no clear means to enforce this requirement. Unregulated micromobility battery fires prior to this date have helped form a negative public opinion regarding lithium-ion battery safety.

Residential battery storage systems, on the other hand, are larger, heavier, and stationary, which means they are less prone to physical damage and more protected from varying environmental conditions. BESS also have more sophisticated safety features and monitoring systems that can prevent or mitigate thermal runaway from abnormal conditions. Residential BESS, unlike micromobility battery systems, are required be listed and labeled in accordance with UL 9540, the Standard for Energy Storage Systems and Equipment, which provides a safety baseline that must be met before a BESS is permitted to be installed in a residential occupancy. Overall, BESS intended for residential use does not pose the same level of risk as a less regulated micromobility battery.

15.2 Challenges to BESS Implementation in CCSF
Arup found that the construction regulations and code language are generally similar across the analyzed cities as they typically use the current edition of UL 9540 which limits the maximum energy capacity of individual BESS units for residential use to 20 kWh for their BESS code requirements. The rationale behind this limit is not relevant for the purposes of this report, as it is based on the NFPA standards that are developed through government, industry, and consumer input apart from the additional requirements included in the SFFD AB 5.12 code interpretation. New York City has slightly more stringent requirements than San Francisco, while the other four municipalities reviewed have only slight code variations compared to San Francisco. These differences between local BESS codes are primarily due to cities outside California adopting different editions of the International Fire Code with few to no amendments. Due to the nature of how cities are legally incorporated in California, many can create and apply local amendments leading to lack of consistency residential and fire codes, especially in larger cities.

However, CCSF is distinct from the other municipalities reviewed in terms of review procedures and interpretations and has formalized additional code language through the SFFD AB 5.12. For example, a separate fire department permit is required to install an aggregate or individual BESS larger than 20 kWh in CCSF. Due to SFFD’s interpretation of “system” and “unit” in the code, BESS aggregate systems exceeding 20 kWh are required to obtain a building fire department permit even though the system’s individual BESS units do not exceed the 20-kWh threshold. This incurs additional installation and permitting requirements and impacts to CCSF and applicant resources that would otherwise be avoided if the BESS was not subject to this unique SFFD code interpretation. On the CCSF side, the resources spent on additional reviews is not able to be recouped due to the Assembly Bill 1414 fee cap mandate.

SFFD’s additional installation requirements delivered through their AB 5.12, means that San Francisco also does not permit BESS to be installed within 3 feet from property lines, means of egress, and the public way unless protected by a 1-hour fire barrier; a reduction from the 10-foot clearance required by the California Building Code. For interior installations of BESS that are installed within 3 feet from the property line, AB 5.12 requires the following: the BESS shall be installed on not less than on a layer of 5/8 inch Type X gypsum board that extends not less than 4 feet in vertical directions, installed from the floor to the ceiling and not less than 4 feet across the ceiling from the wall on which the BESS is mounted. This additional installation language poses a significant barrier when applied to CCSF. San Francisco contains a significant portion of R-3 occupancy buildings that share walls with buildings on either side, surpassing the 3-foot minimum property line requirement and ultimately requiring the Type X gypsum installation.

From a review perspective, there is a branching permitting process across different departments that creates inconsistency across the building department and an additional financial and procedural burden for CCSF and those looking to install BESS. Currently, SolarAPP+ allows aggregate BESS over 20 kWh to receive an automated permit if individual BESS units do not exceed 20 kWh, conflicting with the SFFD code interpretation.

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If that same application did not go through the SolarAPP+ platform, and instead was sent to DBI for review, that application would be returned to the applicant and require the applicant to submit for a building permit which includes a SFFD review. In addition to inconsistency across permitting pathways, SolarAPP+ has its own limitations and unintended consequences.
• SolarAPP+ does not allow for detailed information to be uploaded for review, leaving critical design information out of automated permits and pushing design corrections to resubmittals or field inspections. • SolarAPP+ does not allow for particular use cases, limiting its applicability. • SolarAPP+ platform usage questions are directed to City staff which incurs additional time and unrecoverable costs due to the Assembly Bill 1414 fee cap mandate.

To complement optimized permitting and installation processes and cultivate BESS implementation, applicants need to be well-informed on and guided through those processes, the workforce needs to be comprehensively equipped to deliver code compliant and effective systems efficiently, and VPP programs could be leveraged to improve the energy cost savings of BESS implementation. Recent federal funding opportunities through the Inflation Reduction Act has created a variety of financial resources to implement Solar+BESS and BESS, though targeted resources to guide applicants through accessing these ever-evolving resources is lacking. On the workforce side, there are currently few programs that are designed to develop the workforce specifically for BESS and solar installations. Some programs created for this purpose have paused or cancelled due to a lack of consistent work in the field. Additionally, because BESS installations must be performed by a C-10 electrical contractor and there are only special cases where a C-46 license is acceptable, it may be difficult for some members of the workforce to gain the necessary experience and licenses required to work on these projects. This difficulty may be exacerbated by ramifications of AB 2143, prevailing wage requirements may make it more difficult for apprentices to gain the needed training hours under new prevailing wage requirements. VPP programs could enhance the value San Francisco residents could obtain from their BESS installations, and there are regional examples that CCSF can look to and model future programs after.

15.3 Opportunities for Improvement for BESS Implementation in CCSF The following are notable observations areas of recommendations resulting from this study:

15.3.1 Observations
• The upfront cost of installing battery energy storage systems may be a bigger deterrence to consumers than other factors. Even though there are a variety of state and federal financial incentives available to support the investment, these resources are evolving and difficult to navigate, and installations likely do not offer an attractive enough ROI to outweigh high upfront costs. BESS may become more financially attractive as costs of electricity continue to rise, NEM export rates lower, and the importance of energy resilience grows. • Users that may benefit most from BESS include current Solar users that participate in NEM 3.0 or do not participate in a NEM program at all, people with home EV charging stations, residents that will be electrifying their homes, and medically dependent people that cannot risk power interruptions. • The typical battery size offered on the market for R-3 occupancies is 13.5 kWh. If two or more batteries are needed for installation, this immediately exceeds SFFD’s interpretation of the 20-kWh threshold for R-3 occupancies and shall comply with more stringent requirements as well as a lengthier and more costly permitting process.
• AB 2143 requires most large electrical generation (solar) facilities that are above 15 kW or 3+ story multi- unit housing facilities to provide prevailing wages to all construction workers and apprentices. While this strengthens wages for certified, licensed installers, it may impact workforce development efforts as apprentices will not be able to train on projects that fall under this bill. There should be strategic efforts to ensure workforce development opportunities across various levels of experience grow alongside the desired growth of BESS and solar installations throughout San Francisco.

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ograms that can be used to model future programs in CCSF.

15.3.2 Opportunities for Improvement
• Defined code-related BESS terms: The lack of clarity around the terms “system” and “unit” as they relate to BESS in applicable codes is causing confusion for installation and permitting requirement expectations for BESS in residential (primarily R-3) occupancies. Developing a shared language around these terms will put applicants, installation stakeholders, and permitting stakeholders in alignment. This alignment can sow stronger interagency coordination at CCSF to safeguard BESS implementation delays and wasted resources associated with unclear policies and procedures. Consider not using the terms ‘system’ or ‘unit’ as modifiers when describing a BESS. If multiple BESS are installed state it as such and continue to use the terms ‘aggregate’ or ‘aggregate capacity’.
• Streamline permitting process:

1. Investigate and pursue opportunities to treat BESS permit applications that exceed the 20-kWh threshold similar to a Solar permit application. The permitting process for these systems can be expedited if the applications were able to be sent via email to DBI for electrical review directly, and then routed to the SFFD for detailed review of the BESS. This would bypass unnecessary reviews that accompany full building permits, while directing the application to staff at the SFFD who hold the expertise necessary to perform targeted reviews of BESS.

2. Utilize dedicated plan expediters to clarify the permitting process and field SolarAPP+ questions from applicants to minimize resources spent by other City technical review staff.

3. Update SolarAPP+ platform capabilities to allow for more detailed plans to be reviewed across different departments. Allowing first time permit applicants to complete SFFD inspection through the SolarAPP+ and allowing higher and more detailed functionality within SolarAPP+ for plan review may streamline the permitting process, which currently requires separate inspections by SFFD and DBI and incurs unrecoverable costs. SolarAPP+ would be more efficient if plans could be submitted via email to the DBI electrical reviewers and additional disciplines required for complete reviews were added on as needed (as noted in item 1 in this list).

4. Update permitting department IT system to have capabilities of complying directly with state fee cap regulations. Currently, CCSF’s obsolete permitting systems automatically calculate permit fees based on valuation as opposed to this mandated fee cap. To meet this permit fee regulation DBI allows contractors request refunds in the amount the contractor was charged that exceeded this fee cap. However, refunds must be requested to be given, meaning that contractors may not always be charged appropriately, and extra CCSF resources are used to handle and administer the refunds. • Create a BESS implementation one-stop shop: Efficient navigation of the application, installation, design and permitting processes is crucial for minimizing timelines, costs, safety, compliance, optimal performance, and longevity of BESS and solar installations. There are several different resources available for consumers to consult while making decisions during this process, but this web of information may be overwhelming to some prospective consumers and may contribute to lower uptake. Applicants could benefit from a consolidated and organized list of resources to serve as a BESS implementation hub to guide them from BESS consideration through installation, operation, and maintenance. • Provide financial assistance for BESS installations: Reduce the initial investment barrier for installing solar panels and battery systems through targeted financial incentive programs. Low-interest loans could enable middle-income households to use energy savings to gradually pay off the upfront costs of solar and BESS.

Low-income households who do not have the financial resources to take on loan payments will require additional subsidies to be able to install solar and BESS.

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July 31, 2024 | Arup US, Inc. LAFCo BESS Policy Research Page 37 • Facilitate opportunities for VPP: To unlock VPP as an opportunity for BESS owners to increase the value of their systems; there are several strategies that can be considered:

1. Public-Private Partnerships: evaluate opportunities to collaborate with companies like SunRun and local utilities to develop and promote VPP programs. For example, SunRun's partnerships with IOUs and other CCAs could serve as a model for similar collaborations in San Francisco.

2. Community Engagement: educating residents about VPPs and providing easy access to participation through streamlined processes and financial incentives. Outreach programs can specifically target low- income and underserved communities to ensure equitable access.

3. Simplify Enrollment: once a VPP is established, develop user-friendly online platforms where residents can easily sign up and access information about VPP programs.

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Appendix A
A.1 Data Sources
The following data sources were used to compile and map the existing energy storage and Solar installations across California with a particular focus on the San Francisco Bay Area.

Table 5: Data Sources
Source California Energy Storage
System Survey
California Distributed Generation
Statistics
U.S. Zip Code
Areas
Author California Energy
Commission
California Solar Initiative (CSI), GRID
Alternatives, California IOUs, and CPUC
United States
Postal Service
(USPS) / ESRI
Description
This contains information
about ESS installations
throughout the state of
California. It is the first of its
kind, combining data from all
utility providers into one
dataset.

This contains data from the CSI program
which includes Solar installation data
sourced from various incentive program
applications. The data sets highlighted in this
memo include the CSI program data and the
Single-family Affordable Solar Homes
(SASH) program data.

This is geospatial
data for each ZIP
code in the US.

File Type CSV CSV ESRI Shapefile
Link Workbook: Energy Storage
Dashboard (ca.gov)
CaliforniaDGStats
USA ZIP Code
Areas -
(arcgis.com)

A.1.1 Data Processing
A.1.1.1 California Distributed Generation Statistics
The two datasets within this resource used were the CSI Working Data set, which was last updated in 2020, and the Low-Income Applications set which includes the SASH incentive program dedicated to single-family homes.

The CSI data was queried to include only non-SASH and non-MASH (multi-family equivalent of SASH) residential installations that were listed as of May 28, 2020, within the nine Bay Area Counties. The Low- Income Applications data was queried to include completed installations that received funding through single- family incentive programs. Both sets of queried data were summarized by calculating the total amount of installations and the sum of the nameplate capacity per each ZIP code.

A.1.1.2 U.S. Zip Code Areas – United States Postal Service (USPS) / ESRI The ZIP code data was processed by reprojecting the shapefile from its original coordinate system into the NAD83 California State Plane projected coordinate system to maintain the highest level of accuracy. Zone III was the state plane zone used due to this project’s focus on the San Francisco Bay Area. Then, a new layer containing only California ZIP codes was created from the original shapefile to shadow the energy storage system data.

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A.1.1.3 Preliminary Results
Finalized maps with legends, scale bars, etc. will be included in the final report. For reference, grey indicates a ZIP code where there are 0 installations while light to dark green indicates the least to most installations per number of housing units in each ZIP code. For each dataset, there is one map for the entire Bay Area and one map for San Francisco. The ranges were recalculated at the San Francisco scale; the images are not merely zoomed in.

Figure 1: California Energy Storage System Survey – Bay Area

This map shows that there are BESS installations of some form throughout the Bay Area, with higher frequencies of installations outside of the downtown areas of San Francisco, Oakland, and San Jose. The lightest green indicates a ZIP code with anywhere between 1 and ~150 installations, while the darkest green indicates a ZIP code with anywhere between ~600-750 installations. From this map, it is clear that San Francisco has a relatively low uptake in ESS compared to the rest of the Bay Area. This is a very high-level observation as there are other factors that influence ESS adoption, and the size and density of the ZIP codes are not incorporated within this map.

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Figure 2: California Energy Storage System Survey – San Francisco

Taking a closer look at San Francisco, we see that there are BESS installations in most ZIP codes aside from a few. This map shows where ESS is more prominent within San Francisco. The three ZIP codes that are the darkest green contain between 80 and 100 installations each, while the lightest shaded ZIP codes may contain up to 20 installations. Per CalEnviroScreen The lighter regions roughly correspond to areas experiencing increased poverty rates, housing burden, and typically include census tracts identified as low-income.

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Figure 3: CSI Working Data – Bay Area

This map shows Solar installations current as of May 2020 that were funded in some part through the now- exhausted CSI program. It does not include incentive applications from more directed incentive programs such as SASH and MASH. The darkest green ZIP codes contain between ~360-460 installations each. The map shows that the installations are spread across almost the entire Bay Area, with some ZIP codes in San Francisco hosting the similar amounts of installations as less dense areas of the region.

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Figure 4: CSI Working Data – San Francisco

Recalculating for San Francisco can show more clearly which ZIP codes have the most and least installations.

This map is nearly identical to the ESS map shown previously, with the same ranges for the colors. As was the case in the ESS map, the darkest green ZIP codes contain between 80-100 installations each. It is not possible to say how much overlap there is between these datasets without having more information about the ESS data and any incentive programs that a given installation utilized. Because the BESS data in San Francisco was heavily skewed towards Solar PV technology, this map with CSI data confirms that the same ZIP codes are showing much higher adoption rates than other parts of the city.

A.1.1.4 Data Scoring
This subsection serves to demonstrate an evaluation of each dataset used for the purposes of this project. Each dataset was scored based on how much qualifying information could be readily found from 1-3. For a dataset to receive a score of 3, it needs to have each column of the below table completed. The ZIP code data and incentives application data from CA Distributed Generation Statistics received a score of 3 because both had complete methodologies, and the latter included data keys that defined each column of the exported CSVs. The CA ESS Survey data received a score of 2 because although it was published by a reputable source, the California Energy Commission (CEC), we were not able to find detailed information about how the data was compiled from utility surveys.

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Figure 5: Data Scoring
Source - Title Description Methodology Updated Scoring; Metadata
CEC - CA Energy
Storage System
Survey
Statewide dataset
including residential,
commercial, and
utility-scale
installations as
obtained through a
semi-annual survey of
all utilities in
California. Note: Data
may not be available
for all zip codes as
some utilities do not
report ESS as
separately identifiable
from a co-located
Solar photovoltaic
system.

Data in this dashboard is obtained
through a survey of all utilities in
California and is current as of October
24, 2023. The dataset will be updated
semi-annually upon completion of each
survey.

Note: Utility data on installations of
energy storage systems may not be
available for all zip codes. Due to
variations in local permitting
regulations, not all utilities reported
energy storage systems as separately
identifiable from a co-located Solar
photovoltaic system.
10/24/23 2; Incomplete
USPS,
Esri - U.S. Zip
Code Areas
This shapefile
contains the ZIP
Code, postal district
name, population, and
area for the ZIP Code
areas in the United
States.

U.S. ZIP Code Areas represents five-
digit ZIP Code areas used by the U.S.

Postal Service to deliver mail more
effectively. The first digit of a five-digit
ZIP Code divides the United States into
10 large groups of states (or equivalent
areas) numbered from 0 in the
Northeast to 9 in the far West. Within
these areas, each state is divided into an
average of 10 smaller geographical
areas, identified by the second and third
digits. These digits, in conjunction with
the first digit, represent a Sectional
Center Facility (SCF) or a mail
processing facility area. The fourth and
fifth digits identify a post office,
station, branch, or local delivery area.
8/20/23 3; Complete
CPUC,
et al –
CSI Working Data;
Low-Income Solar
PV Data
This contains data
from the CSI program
which includes Solar
installation data
sourced from various
incentive program
applications. The data
sets highlighted in this
memo include the CSI
program data and the
Single-family
Affordable Solar
Homes (SASH)
program data that is
found in the Low-
Income Solar PV Data
Set.

The California Solar Initiative (CSI)
Working Data Set represents the CSI
incentive application data from PG&E,
SCE and SDG&E service territories for
the now-closed CSI Program, except
for applications removed due to
erroneous data.

The Low-Income Solar PV Data Set
contains all applications received
through the Single-family Affordable
Solar Homes (SASH) programs, the
Multi-family Affordable Solar Housing
(MASH) programs and the
Disadvantaged Communities - Single-
family Affordable Solar Homes (DAC-
SASH) program. This data set includes
incentive applications from PG&E,
SCE and SDG&E territories and is
updated weekly. Please note that SASH

1.0 and MASH 1.0 incentive
applications are also included in the
CSI Working Data Set.
5/28/20;
4/18/24 3; Complete

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A.2 BESS Codes and Policies for R-3 Occupancies
Table 6: BESS Codes and Policies for R-3 Occupancies
Comparison Item SF Austin NYC Chicago San Jose Fremont
Energy Capacity Maximum capacity per individual ESS unit shall not exceed 20 kWh.

Maximum aggregate capacities per installation
location within R-3 occupancy are:

1. 40 kWh within utility closets and storage or
utility spaces

2. 80 kWh outdoors on the ground

3. 80 kWh on exterior walls

4. 80 kWh in attached or detached garages and
detached accessory structure
Maximum energy rating permitted is 280 kWh.

ESS installations exceeding the individual ESS
rating of 20 kWh or the aggregate capacities
shall be installed in accordance with CFC
§1207.1-§1207.9.
1 Individual ESS units shall have a maximum
rating of 20 kWh. The aggregate rating structure
shall not exceed:
2 1. 40 kWh within utility closets and storage or
utility spaces.

2. 80 kWh in attached or detached garages and
detached accessory structures.

3. 80 kWh on exterior walls.

4. 80 kWh outdoors on the ground.

For NYC, the maximum rated energy capacity of
any ESS shall not exceed 20 kWh, and the
maximum aggregate should not exceed 20
kWh/dwelling unit or 40 kWh for a 2 hr fire
barrier wall when in attached garages, or 40 kWh
in attached garages3
For New York State, individual ESS units shall
have a maximum rating of 20 kWh. The
aggregate rating structure shall not exceed:
4 1. 40 kWh within utility closets and storage or
utility spaces.

2. 80 kWh in attached or detached garages and
detached accessory structures.

3. 80 kWh on exterior walls.

4. 80 kWh outdoors on the ground.

The maximum allowable quantity (MAQ) of a
lithium-ion battery is 600 kWh per fire area.

For all other battery types, refer to IFC Table
1206.2.9.
5 Electrochemical ESS shall be segregated into
groups not exceeding 50 kWh. Each group shall
be separated a minimum of 3 feet from other
groups and walls within the area.
6 Individual ESS units shall have a maximum
rating of 20 kWh. The aggregate rating
structure shall not exceed:7

1. 40 kWh within utility closets and storage or
utility spaces.

2. 80 kWh in attached and detached garages
and detached accessory structures.

3. 80 kWh on exterior walls.

4. 80 kWh outdoors on the ground.

Maximum capacity per individual ESS unit
shall not exceed 20 kWh.

Maximum aggregate capacities per
installation location within R-3 occupancy
are:
8 1. 40 kWh within utility closets and storage
or utility spaces

2. 80 kWh outdoors on the ground

3. 80 kWh on exterior walls

4. 80 kWh in attached or detached garages
and detached accessory structure
Ventilation Indoor installations of ESS that produce
hydrogen or other flammable gases during
charging shall be provided with mechanical
ventilation in accordance with the CMC.
9 ESS that have the potential to release toxic or
highly toxic gas during charging, discharging,
and normal use conditions shall not be installed
within Group R-3.
10 Indoor installations of ESS that include batteries
that produce hydrogen or other flammable gases
during charging shall be provided with exhaust
ventilation in accordance with Section
1207.6.1.
11 Exhaust ventilation required for areas containing
Lead-acid, Ni-Cd, Ni-MH, and flow battery ESS
technologies. Not required for Lithium-ion ESS.

Ventilation shall be designed to limit the
maximum concentration of gases to 25% of the
LFL or to provide an exhaust rate of not less than
1 ft
3/min/ft2 of floor area of the area.12
Indoor installations of ESS that include batteries
that produce hydrogen or other flammable gases
during charging shall be provided with exhaust
ventilation in accordance with Section
1206.13.1.
13 ESS that have the potential to release toxic or
highly toxic gas during charging, discharging,
and normal conditions shall not be installed with
one and two family dwellings and townhouses
14 Exhaust ventilation required for areas
containing Lead-acid, Ni-Cd, Ni-MH, and flow
battery ESS technologies. Not required for
Lithium-ion ESS. Ventilation shall be designed
to limit the maximum concentration of gases to
25% of the LFL or to provide an exhaust rate of
not less than 1 ft
3/min/ft2 of floor area of the
area.15
Indoor installations of ESS that include
batteries that produce hydrogen or other
flammable gases during charging shall be
provided with exhaust ventilation.16
Indoor installations of ESS that produce
hydrogen or other flammable gases during
charging shall be provided with mechanical
ventilation in accordance with the CMC.
17 ESS that have the potential to release toxic or
highly toxic gas during charging,
discharging, and normal use conditions shall
not be installed within Group R-3.
18 Permitting Requirements
(operational building permits,
FD reviews)
A construction permit is required for ESS at 20
kWh or greater.
19 Operational permits are required for ESS and
lithium batteries.
20 Construction permits are required for stationary
ESS installations in accordance with AFC
Section 105.5.22.
21 Operational permits are required for stationary
ESS that exceed the energy capacities listed in
AFC Table 1207.1.1 and employ Capacitor ESS,
Lithium-ion batteries, Ni-MH, or other
electrochemical ESS technologies in accordance
with AFC Section 105.5.22.
22 Operational permits are required for stationary
ESS installations utilizing fifteen or more gallons
of corrosive electrolyte in flooded lead-acid,
valve regulated lead-acid batteries or Ni-Cd
batteries in accordance with AFC Section
105.5.22 based on Health Hazard Category 3
liquids.
23 Construction permits are required including the
following specifications listed below. Location
and layout diagram of the room or area in which
the ESS is to be installed. Details on the fire-
resistance rating of assemblies enclosing the
ESS. Manufacturer's specifications. Ratings and
listings of each ESS. Description of energy
storage 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. Seismic restraint
24 Permits only required for outdoor BESS larger
than 20 kWh for Li-ion and 70 kWh for lead-acid
batteries
25 Outdoor BESS of all sizes need to be maintained
and operated under the general supervision of
someone holding a Certificate of Fitness
26,27.

Construction permits are required for stationary
ESS installations in accordance with IFC
Section 105.7.2.

Construction documents are required with the
permit application
28 Construction and operational permits shall be
obtained for stationary ESS installations.
29 Construction documents are required to be
provided with the permit application.
30 Construction and operational permits shall be
obtained for stationary ESS installations.

Construction documents are required to be
provided with the permit application
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Comparison Item SF Austin NYC Chicago San Jose Fremont
Listings ESS shall be listed and labeled in accordance
with UL 9540.32
Where approved, repurposed unlisted battery
system from electric vehicles are allowed to be
installed outdoors or in detached sheds located
not less than 5 feet from exterior walls, property
lines, and public ways.
33 ESS shall be listed and labeled in accordance
with UL 9540. ESS listed and labeled solely for
utility or commercial use shall not be used for
residential applications
34 Where approved, repurposed unlisted battery
systems from electric vehicles are allowed to be
installed outdoors or in detached dedicated
cabinets located not less than 5 feet from exterior
walls, property lines and public ways.
35 ESS less than 1 kWh is not required to be listed
and labeled in accordance with UL 9540.
36 ESS shall be installed in accordance with NFPA
70 and UL 9540
37 (in IFC 2018 same as R-2) ESS shall be listed in accordance with UL 9540.
38 Inverters shall be listed and labeled in
accordance with UL 1741 or provided as part of
the UL 9540 listing.
39 ESS shall be listed and labeled in accordance
with UL 9540.
40 Monitoring and Detection For BESS over 20 kWH, where required by the ESS listing, an approved energy storage
management system that monitors and balances
cell voltages, currents and temperatures within
the manufacturer’s specifications shall be
provided.

Where required by the ESS listing, an approved
energy storage management system that monitors
and balances cell voltages, currents and
temperatures within the manufacturer’s
specifications shall be provided. The system shall
place the ESS system in a safe condition if
hazardous conditions are detected.
41 Where required by the ESS listing, an approved
energy storage management system that monitors
and balances cell voltages, currents and
temperatures within the manufacturer’s
specifications shall be provided. The system shall
place the ESS system in a safe condition if
hazardous conditions are detected.
42 An approved automatic smoke detection system
or radiant energy sensing fire detection system
shall be installed in rooms indoor areas and walk
in ESS units containing ESS.
43 Remote monitoring required for outdoor battery
systems of all sizes
44 Indoor and outdoor systems shall be designed to
address the hazards identified by full scale
testing including fire barriers, fire alarms,
explosion mitigation, gas detection, fire
extinguishing, and ventilation systems
45 Where required by the ESS listing, an approved
energy storage management system that
monitors and balances cell voltages, currents
and temperatures within the manufacturer’s
specifications shall be provided. The system
shall place the ESS system in a safe condition if
hazardous conditions are detected.
46 Fire detection, smoke detection, and gas
detection systems shall be provided in
accordance with Sections IFC 1206.2.11-
1206.2.11.5, IFC 907.2, And IFC 916
respectively47
Where required by the ESS listing, an approved
energy storage management system that
monitors and balances cell voltages, currents
and temperatures within the manufacturer’s
specifications shall be provided. The system
shall place the ESS system in a safe condition if
hazardous conditions are detected.
48 Required if energy capacity is exceeded.

Where an ESS is installed in the normal driving
path of vehicle travel within a garage, impact
protection complying with Section 1207.11.7.3
shall be provided. Normal driving path is a
space between garage vehicle opening and
interior face of the back wall to a height of 48
inches above the finished floor.

Impact protection shall also be provided for
ESS installed at either of the following
locations:

On interior face of back wall and located within
36 inches to the left or to the right of the normal
driving path.

On interior face of a side wall and located
within 24 inches from the back wall and within
36 inches of the normal driving path.

Where clear height of vehicle garage opening is
7 feet 6 inches or less, ESS installed not less
than 36 inches above finished floor are not
subject to vehicle impact protection
requirements.

ESS installed in a location subject to vehicle
damage shall be protected by approved barriers.

Appliances in garages shall also be installed in
accordance with Section 304.3 of the
International Mechanical Code.

ESS installed in a location subject to vehicle
damage or other impact shall be protected by
approved barriers
50 Where ESS are subject to impact by a motor
vehicle, including forklifts, vehicle impact
protection shall be provided in accordance with
CFC Section 312.
51 ESS installed in a location subject to vehicle
damage shall be provided with impact
protection. In garages, ESS shall be provided
with impact protection when installed in the
normal driving path of vehicle travel within a
garage as defined by SJFC §1207.11.7.1.
52 Acceptable forms of impact protection include
bollards or wheel barriers constructed in
accordance with SJFC §1207.11.7.3.

ESS installed in a location subject to vehicle
damage shall be provided with impact
protection. In garages, ESS shall be provided
with impact protection when installed in the
normal driving path of vehicle travel within a
garage as defined by CFC §1207.11.7.1.

Acceptable forms of impact protection
include bollards or wheel barriers constructed
in accordance with CFC §1207.11.7.3.

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Comparison Item SF Austin NYC Chicago San Jose Fremont
Outdoor Specific ESS shall be permitted to be installed outdoors or on the exterior side of exterior walls located
not less than 3 feet from doors and windows
directly entering the dwelling unit.
53 For exterior installations of ESS:54

1. Property lines and means of egress:
minimum separations of 3 feet may be
reduced to 12 inches where a 1 hour free-
standing fire barrier and extending 3 feet
above and 3 feet beyond the physical
boundary of the ESS installation is provided
to protect the exposure.

2. The exterior wall upon which the ESS is
installed shall be located at least 12 inches
from other exterior walls of the same
building in either direction.

Outdoor walk-in units housing ESS shall not
exceed 53 feet by 8 feet by 9.5 feet high. Outdoor
walk-in units exceeding these limitations shall be
considered indoor installations.
55 ESS located outdoors shall be a minimum of 10
feet from lot lines, public ways, buildings, stored
combustible materials, hazardous materials, high-
piled stock, an other exposure hazards.
56 This
distance is permitted to be reduced to 3 feet for
the following:

1. A 1-hour free standing fire barrier exceeding
5 feet above and 5 feet beyond the physical
boundary of the ESS is provided to protect
the exposure.

2. Clearances to buildings are permitted to be
reduced to 3 feet where noncombustible
exterior walls with no openings or
combustible overhangs are provided on the
wall adjacent to the ESS. Wall must be rated
for 2-hours.

3. Clearances to buildings are permitted to be
reduced to 3 feet where a weatherproof
enclosure constructed of noncombustible
materials that has gone through large-scale
fire testing is provided over the ESS.

ESS is permitted to be installed outdoors on
exterior walls where the maximum energy
capacity of individual units does not exceed 20
kWh and individual units are separated from
each other by 3 feet and doors, windows, HVAC
inlets and other openings by 5 feet.
57 Outdoor walk-in units housing ESS shall not
exceed 53 feet by 8 feet by 9.5 feet high. Outdoor
walk-in units exceeding these limitations shall be
considered indoor installations.58
Outdoor walk in ESS shall not exceed 4,028 cu ft
in size
59 (same as requirement listed above but
NY State reworded it)
Areas within 10 ft on each side of an outdoor
ESS shall be cleared of combustible vegetation
60 BESS systems must be a minimum of 10 ft from
any of the following exposures: lot lines, public
streets, vehicle parking, building entrances,
windows, or ventilation intakes, building egress,
hazardous materials storage, overhead power
lines, public utility or transportation
infrastructure
61 Outdoor lithium ion greater than 250 kWh and
lead-acid greater than 500 kWh shall not be
installed in enclosed areas without direct access
from a public street or fire access road unless full
testing is undergone. 62

ESS located outdoors and in open parking
garages shall be separated from any means of
egress as required by the fire code official by no
less than 10 feet. Reduced separation shall be
subject to approval by fire code official upon
review of large-scale fire testing.63
ESS located outdoors shall be a minimum of 5
feet from lot lines, public ways, buildings,
stored combustible materials, hazardous
materials, high-piled stock, and other exposure
hazards.
64 This distance is permitted to be
reduced to 3 feet for the following:

Outdoor walk-in units housing ESS that
exceeds 53 feet by 8 feet by 9.5 feet high shall
be considered indoor installations and must
comply with the applicable requirements.
65 ESS located outdoors and in open parking
garages shall be separated from any means of
egress by a minimum of 10 feet.
66 ESS located outdoors shall be separated by a
minimum of 10 feet from lot lines, public ways,
buildings, stored combustible materials,
hazardous materials, high-piled stock, and other
exposure hazards. The distance is permitted to
be reduced to 3 feet if the requirements of SJFC
§1207.8.3 Exceptions 1 through 3 are met.
67 ESS shall be permitted to be installed outdoors
on exterior walls of buildings when all of the
following conditions are met:
68 1. Individual ESS units shall not exceed 20
kWh.

2. The ESS shall comply with SJFC Section
1207.

3. The ESS shall be installed in accordance
with the manufacturer’s instructions and
their listing.

4. Individual ESS units shall be separated from
each other by at least 3 feet.

5. The ESS shall be separated from doors,
windows, operable openings into buildings
or HVAC inlets by at least 5 feet.

ESS and associated equipment that are located
on rooftops and not enclosed by building
construction shall comply with the following:
69 1. Stairway access to the roof shall be
provided either through a bulkhead from the
interior of the building or a stairway on the
exterior of the building.

2. Service walkways at least 5 feet in width
shall be provided from the point of access to
the roof to the system.

3. ESS and associated equipment shall be
located from the edge of the roof a distance
equal to at least the height of the system,
equipment, or component but not less than 5
feet.

4. T
he roofing materials under and within 5
feet horizontally from an ESS or associated
equipment shall be noncombustible or shall
have a Class A rating in accordance with
ASTM E108 or UL 790.

5. A class I standpipe outlet shall be installed
at an approved location on the roof level of
the building or in the stairway bulkhead at
the top level.

The ESS shall be a minimum of 10 feet from
the fire service access point on the rooftop.

Where approved, repurposed unlisted battery
system from electric vehicles are allowed to
be installed outdoors or in detached sheds
located not less than 5 feet from exterior
walls, property lines, and public ways.
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Comparison Item SF Austin NYC Chicago San Jose Fremont
Space requirements for
installation
ESS shall be installed only in the following
locations:
71 1. Detached garages and detached accessory
structures.

2. Attached garages separated from the
dwelling unit living space and sleeping units
in accordance with Section R302.6.

3. Outdoors or on the exterior side of the
exterior walls located not less than 3 feet
from doors and windows directly entering
the dwelling unit.

4. Enclosed utility closets, basements, storage
or utility spaces within dwelling units with
finished or noncombustible walls and
ceilings. Walls and ceilings of unfinished
wood-framed construction shall be provided
with not less than 5/8-inch Type X gypsum
wallboard.

Individual ESS units shall be separated by at
least 3-ft of spacing. Spacing requirement may
be reduced upon review and approval by AHJ
when complying with CFC §1207.1.5 and
§104.8.2. Applicant shall submit copies of both
UL 9540A testing report and installation
instructions showing recommended reduced
spacing between the ESS unit(s) being installed.

If minimum spacing varies between the two
documents, the more restrictive separation
distance will be approved.

ESS shall be installed minimum of 3 feet from
property lines, unless protected by a 1-hour fire
barrier.

ESS shall be installed at a minimum of 3 feet
from the dedicated 36 inch wide means of
egress pathway unless protected by a 1 hour fire
barrier.

ESS shall be installed at a minimum of 3 feet
from the public way, unless protected by a 1
hour fire barrier.

Clearance of 3 feet shall be provided in front of
electrical equipment for maintenance purposes
in accordance with CEC and CMC and kept
clear of all combustible storage.

Any eaves, structures, decking, or other such
construction protruding more than 2 feet from
exterior wall upon which the ESS is installed
shall be located at least 3 feet from the ESS.72
ESS shall only be installed in the following
locations:
73 1. Detached garages and detached accessory
structures.

2. Attached garages separated from the dwelling
unit living space and sleeping units in
accordance with Section 406.3.2 of the
International Building Code.

3. Outdoors on exterior walls located a
minimum of 3 feet from doors and windows.

4. Utility closets and storage or utility spaces
within dwelling units and sleeping units.

Combustible materials shall not be stored in ESS
rooms, areas or walk-in units.
74 Groups of ESS are required to be separated a
minimum of 3 feet from other groups and from
walls in the storage room or area.
75 Electrochemical ESS shall not be located in areas
where the floor is located more than 20 feet
above the lowest level of fire department vehicle
access or below the lowest level of exit
discharge.
76 No indoor system shall be installed below grade
in a dwelling unit or garage.
77 ESS shall only be installed in the following
locations:
78 1. Detached garages and detached accessory
structures.

2. Attached garages separated from the dwelling
unit living space and sleeping units in
accordance with Section 406.3.2 of the
International Building Code.

3. Outdoors on exterior walls located a
minimum of 3 feet from doors and windows.

4. Utility closets and storage or utility spaces
within dwelling units and sleeping units.

ESS shall only be installed in the following
locations:

1. Detached garages and detached accessory
structures.

2. Attached garages separated from the
dwelling unit living space and sleeping units
in accordance with Section 406.3.2 of the
International Building Code.

3. Outdoors on exterior walls located a
minimum of 3 feet from doors and
windows.

4. Utility closets and storage or utility spaces
within dwelling units and sleeping units.

Combustible materials shall not be stored in
ESS rooms, areas or walk-in units.

Groups of ESS are required to be separated a
minimum of 3 feet from other groups and from
walls in the storage room or area.

Electrochemical ESS shall not be located in
areas where the floor is located more than 20
feet above the lowest level of fire department
vehicle access or below the lowest level of exit
discharge.

Individual units shall be separated from each
other by at least 3 feet of spacing.
79 ESS shall only be installed in the following
locations:
80 1. Detached garages and detached accessory
structures.

2. Attached garages separated from the
dwelling unit living space and sleeping
units.

3. Outdoors or on the exterior side of the
exterior walls located not less than 3 feet
from doors and windows directly entering
the dwelling unit.

Enclosed utility closets, basements, storage or
utility spaces within dwelling units with finish
or noncombustible walls and ceilings.

Individual units shall be separated from each
other by at least 3 feet of spacing.
81 ESS shall be installed only in the following
locations:
82 1. Detached garages and detached accessory
structures.

2. Attached garages separated from the
dwelling unit living space and sleeping
units in accordance with Section R302.6.

3. Outdoors or on the exterior side of the
exterior walls located not less than 3 feet
from doors and windows directly entering
the dwelling unit.

4. Enclosed utility closets, basements,
storage or utility spaces within dwelling
units with finished or noncombustible
walls and ceilings. Walls and ceilings of
unfinished wood-framed construction
shall be provided with not less than 5/8-
inch Type X gypsum wallboard.

Sprinkler requirements and fire
extinguishing systems
For BESS over 20 kWh, areas containing ESS
are required to be protected by one of the
following:

1. Automatic sprinkler coverage

2. Automatic sprinkler coverage with a hazard
classification based on large-scale fire
testing
An approved alternative automatic fire-
extinguishing system
Areas containing ESS are required to be
protected by one of the following:

1. Automatic sprinkler coverage with a
minimum density of 0.3 gpm/ft
2 over 2,500
ft2

2. Automatic sprinkler coverage with a hazard
classification based on large-scale fire testing

3. An approved alternative automatic fire-
extinguishing system (e.g. CO
2, water spray,
water mist, clean agent, fixed aerosol)
Fire suppressions system is required with
automatic sprinklers or following NFPA 12, 15,
750, 2001, and 2010.83
Fire extinguishing for outdoor BESS is needed
for lithium ion greater than 250 kWh and lead-
acid greater than 500 kWh84
Indoor and outdoor systems shall be designed to
address the hazards identified by full scale
testing including fire barriers, fire alarms,
explosion mitigation, gas detection, fire
extinguishing, and ventilation systems
85 Areas containing ESS are required to be
protected by automatic sprinkler coverage in
accordance with IFC Section 903.3.1.1. 86

Rooms and areas within buildings and walk-in
units containing electrochemical ESS shall be
protected by an automatic sprinkler system
designed with a minimum density of 0.3
gpm/ft
2 over the fire area or 2,500 ft2,
whichever is smaller.87
ESS located in walk-in units on rooftops shall
be provided with automatic fire suppression
systems within the ESS enclosure.88
Required if energy ratings are exceeded.

Rooms and areas within buildings and walk-
in units containing electrochemical ESS shall
be protected by an automatic sprinkler
system designed with a minimum density of

0.3 gpm/ft
2 over the fire area or 2,500 ft2,
whichever is smaller.89
ESS located in walk-in units on rooftops
shall be provided with m automatic fire
suppression systems within the ESS
enclosure.
90 SF Local Agency Formation Commission (LAFCo) LAFCo Study for CleanPowerSF on Battery Energy Storage Systems

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Comparison Item SF Austin NYC Chicago San Jose Fremont
Fire and gas detection Rooms and areas within dwelling units, basements, and attached garages in which ESS
are installed shall be protected by smoke alarms
in accordance with Section R314. A heat
detector, listed and interconnected to the smoke
alarms, shall be installed in locations within
dwelling units and attached garages where
smoke alarms cannot be installed based on
either listing.
91 ESS that have the potential to release toxic or
highly toxic gas during charging, discharging,
and normal use conditions shall not be installed
within Group R-3.
92 Rooms and areas within dwelling units, sleeping
units and attached garages in which ESS are
installed shall be protected by smoke alarms in
accordance with Section 907.2.11. A heat
detector listed and interconnected to the smoke
alarms shall be installed in locations within
swelling units, sleeping units and attached
garages where smoke alarms cannot be installed
based on their listing.
93 Rooms and areas within dwellings units, sleeping
units and attached garages in which ESS are
installed shall be protected by smoke alarms in
accordance with Section 907. A heat detector or
heat alarm listed and interconnected to the smoke
alarms shall be installed in locations within
dwelling units, sleeping units and attached
garages where smoke alarms cannot be installed
based on their listing.
94 ESS that have the potential to release toxic or
highly toxic gas during charging, discharging and
normal use conditions shall not be installed
within Group R-3 and R-4 occupancies.
95 Automatic smoke detection shall be installed in
rooms containing ESS in accordance with IFC
Section 907.2.
96 Rooms and areas within dwelling units,
sleeping units, basements and attached garages
in which ESS are installed shall be protected by
smoke alarms. A listed heat alarm
interconnected to the smoke alarms shall be
installed in locations within dwelling units,
sleeping units, and attached garages where
smoke alarms cannot be installed based on their
listing.
97 Rooms and areas within dwelling units,
sleeping units, basements and attached
garages in which ESS are installed shall be
protected by smoke alarms. A listed heat
alarm interconnected to the smoke alarms
shall be installed in locations within dwelling
units, sleeping units, and attached garages
where smoke alarms cannot be installed
based on their listing.
98 Explosion mitigation For BESS over 20 kWh, explosion control is required to be provided for Lead-acid, Ni-Cd,
Ni-MH, Lithium-ion, and flow battery
technologies
Explosion control complying with AFC Section
911 is required for Lithium-ion, Ni-Cd and Ni-
MH ESS battery types.
99 Explosion mitigation for outdoor BESS is needed
for li-ion greater than 250 kWh and lead-acid
greater than 500 kWh
100
Indoor and outdoor systems shall be designed to
address the hazards identified by full scale
testing including fire barriers, fire alarms,
explosion mitigation, gas detection, fire
extinguishing, and ventilation systems
101
Explosions will be contained within unoccupied
battery storage rooms for the minimum duration
of fire resistance rated walls.
102
Explosion control is required to be provided for
Lead-acid, Ni-Cd, Ni-MH, Lithium-ion, and
flow battery technologies.
103 Explosion control
shall consist of explosion (deflagration)
venting, explosion (deflagration) prevention, or
barricades.
104
Required if energy ratings are exceeded.

Explosion control is required to be provided
for Lead-acid, Ni-Cd, Ni-MH, Lithium-ion,
and flow battery technologies.
105
Spill control For BESS over 20 kWh, areas containing free- flowing liquid electrolyte or hazardous
materials with Lead-acid, Ni-Cd, Ni-MH, and
Flow ESS battery technologies are required to
be provided with spill control.

Areas containing free-flowing liquid electrolyte
or hazardous materials with Lead-acid, Ni-Cd,
Ni-MH, and Flow ESS battery technologies are
required to be provided with spill control.
106
Areas containing free-flowing liquid electrolyte
or hazardous materials with Lead-acid, Ni-Cd,
Ni-MH, and Flow ESS battery technologies are
required to be provided with spill control.

Areas containing free-flowing liquid electrolyte
or hazardous materials with Lead-acid, Ni-Cd,
Ni-MH, and Flow ESS battery technologies are
required to be provided with spill control and
neutralization.
107
Areas containing free-flowing liquid electrolyte
or hazardous materials with Lead-acid, Ni-Cd,
Ni-MH, and Flow ESS battery technologies are
required to be provided with spill control and
neutralization.
108
Required if energy ratings are exceeded.

Areas containing free-flowing liquid
electrolyte or hazardous materials with Lead-
acid, Ni-Cd, Ni-MH, and Flow ESS battery
technologies are required to be provided with
spill control and neutralization.
109
Thermal runaway For BESS over 20 kWh, lead-acid, Ni-Cd, Ni- MH, and Lithium-ion battery ESS types are
required to be provided with a listed or
approved method to prevent, detect, and
minimize the impact of thermal runaway
Lead-acid, Ni-Cd, Ni-MH, and Lithium-ion
battery ESS types are required to be provided
with a listed or approved method to prevent,
detect, and minimize the impact of thermal
runaway.
110
Lead-acid, Ni-Cd, Ni-MH, and Lithium-ion
battery ESS types are required to be provided
with a listed or approved method to prevent,
detect, and minimize the impact of thermal
runaway.

Lead-acid, Ni-Cd, Ni-MH, and Lithium-ion
battery ESS types are required to be provided
with a listed or approved method to prevent,
detect, and minimize the impact of thermal
runaway.
111
Lead-acid, Ni-Cd, Ni-MH, and Lithium-ion
battery ESS types are required to be provided
with a listed or approved method to prevent,
detect, and minimize the impact of thermal
runaway.
112
Required if energy ratings are exceeded.

Lead-acid, Ni-Cd, Ni-MH, and Lithium-ion
battery ESS types are required to be provided
with a listed or approved method to prevent,
detect, and minimize the impact of thermal
runaway.
113
Fire rated wall and enclosure
requirements
For BESS over 20 kWh, enclosures of ESS
shall be of noncombustible construction.

Rooms and areas containing ESS shall be
separated from other areas in the building by 2-
hour fire barriers.

Enclosures of ESS shall be of noncombustible
construction.
114
In dedicated-use buildings, areas containing ESS
shall be separated from areas in which
administrative and support personnel are located
by 2-hour fire barriers.

In nondedicated-use buildings, areas containing
ESS shall be separated by other areas in the
building by 2-hour fire barriers.
115
Indoor systems shall be protected by a 1 hr fire
barrier: NYC
116
Rooms and areas containing ESS shall be
protected on the system side by 2-hour rated fire
barriers (NY State) constructed in accordance
with Section 707 of the Building Code of New
York State and 2-hour rated horizontal
assemblies constructed in accordance with
Section 711 of the Building Code of New York
State
117
Not mentioned for ESS technology but 2 hour
fire resistance rated construction required for
capacity type energy storage systems.
118

Enclosures of ESS shall be of noncombustible
construction.
119
Rooms and areas containing ESS shall be
separated from other areas in the building by 2-
hour fire barriers.
120
Required if energy ratings are exceeded.

Enclosures of ESS shall be of
noncombustible construction.

Rooms and areas containing ESS shall be
separated from other areas in the building by
2-hour fire barriers.
121

SF Local Agency Formation Commission (LAFCo) LAFCo Study for CleanPowerSF on Battery Energy Storage Systems

June 28, 2024 | Arup US, Inc. LAFCo BESS Policy Research Page 49

1 San Francisco Fire Department Administrative Bulletin 5.12 Energy Storage Systems in R-3 Occupancies
2 2021 AFC §1207.11.4
3 2022 New York City Fire Code Chapter 6 section 608.1
Stationary ESS
4 2020 Fire Code of NY State Chapter 12 Section 1206:

Electrical ESS
5 2018 IFC Table 1206.2.9
6 2018 IFC §1206.2.8.3
7 2022 SJFC §1207.11.4
8 2022 CFC §1207.11.4
9 2022 CRC §328.9
10 2022 CFC §1207.11.9
11 2021 AFC §1207.11.8
12 2021 AFC Table 1207.6, §1207.6.1
13 2020 Fire Code of NY State Chapter 12 Section 1206:

Electrical ESS
14 2020 Residential Code of NY State Chapter 3 Section R327 ESS
15 2018 IFC 1206.2.11.3
16 2022 SJFC §1207.11.8
17 2022 CFC §1207.11.8
18 2022 CFC §1207.11.9
19 San Francisco Fire Department Bulletin 5.12 ESS in R-3 Occupancies
20 2022 SFFC Table 107-A
21 2021 AFC §1207.1.2 Item 1
22 2021 AFC §1207.1.2 Item 2
23 2021 AFC §1207.1.2 Item 3
24 2020 Fire Code of NY State Ch 12 Section 1206.4
25 New York City Fire Department: New Fire Department Rule 3 RCNY 608-01: "Outdoor Stationary Battery Systems"
26 New York City Fire Department: New Fire Department Rule 3 RCNY 608-01: "Outdoor Stationary Battery Systems"
27 2022 New York City Fire Code Chapter 6 section 608.1 Stationary ESS
28 2018 IFC §1206.2.1 and 1206.2.2
29 2022 SJFC §1207.1.2
30 2022 SJFC §1207.1.3
31 2022 CFC §1207.1.2, §1207.1.3
32 2022 CRC §R328.2
33 2022 CRC §R328.2 Exception
34 AFC §1207.11.1
35 AFC §1207.11.1 Exception 1
36 AFC §1207.11.1 Exception 2-
37 2020 Fire Code of NY State Chapter 12 Section 1206:

Electrical ESS
38 2022 SJFC §1207.11.1
39 2022 SJFC §1207.11.5
40 2022 CFC §1207.11.1
41 AFC §1207.3.4
42 AFC §1207.3.4
43 2020 Fire Code of NY State Ch 12 Section 1206.12.4
44 New York City Fire Department: New Fire Department Rule 3 RCNY 608-01: "Outdoor Stationary Battery Systems"
45 2022 New York City Fire Code Chapter 6 section 608.1 Stationary ESS
46 2018 IFC §1206.2.10.3
47 2018 IFC §1206.2.11
48 2022 SJFC §1207.3.4
49 2022 CFC §1207.3.4
50 2020 Residential Code of NY State Chapter 3 Section R327 ESS
51 2018 IFC §1206.2.5
52 2022 SJFC §1207.11.7
53 2022 CRC §328.4
54 San Francisco Fire Department Bulletin 5.12 ESS in R-3 Occupancies
55 2021 AFC §1207.5.6
56 2021 AFC §1207.8.3
57 2021 AFC §1207.8.4
58 2021 AFC §1207.5.6
59 2020 Fire Code of NY State Chapter 12 Section 1206:

Electrical ESS
60 2020 Fire Code of NY State Chapter 12 Section 1206:

Electrical ESS
61 New York City Fire Department: New Fire Department Rule 3 RCNY 608-01: "Outdoor Stationary Battery Systems"
62 New York City Fire Department: New Fire Department Rule 3 RCNY 608-01: "Outdoor Stationary Battery Systems"
63 2018 IFC §1206.2.8.7.2
64 2018 IFC §1206.2.8.7.1
65 2022 SJFC §1207.5.6
66 2022 SJFC §1207.5.8
67 2022 SJFC §1207.8.3
68 2022 SJFC §1207.8.4
69 2022 SJFC §1207.9.5
70 2022 CFC §1207.11.1 Exception
71 2022 CRC §R328.4
72 San Francisco Fire Department Bulletin 5.12 ESS in R-3 Occupancies
73 AFC §1207.11.3
74 2021 AFC §1207.4.6
75 2021 AFC §1207.5.1
76 2021 AFC §1207.5.3
77 2022 New York City Fire Code Chapter 6 section 608.1 Stationary ESS
78 2020 Fire Code of NY State Chapter 12 Section 1206:

Electrical ESS
79 2022 SJFC §1207.11.2.1
80 2022 SJFC §1207.11.3
81 2022 CFC §1207.11.2.1
82 2022 CFC §1207.11.3
83 2020 Fire Code of NY State Ch 12 Section 1206.12.5
84 New York City Fire Department: New Fire Department Rule 3 RCNY 608-01: "Outdoor Stationary Battery Systems"
85 2022 New York City Fire Code Chapter 6 section 608.1 Stationary ESS
86 2018 IFC §1206.2.11.1
87 2022 SJFC §1207.5.5
88 2022 SJFC §1207.9.4
89 2022 CFC §1207.5.5
90 2022 CFC §1207.9.4
91 2022 CRC §R328.7
92 2022 CFC §1207.11.9
93 AFC §1207.11.6
94 2020 Fire Code of NY State Chapter 12 Section 1206:

Electrical ESS
95 2020 Fire Code of NY State Chapter 12 Section 1206:

Electrical ESS
96 2018 IFC §1206.2.11.2
97 2022 SJFC §1207.11.6
98 2022 CFC §1207.11.6
99 2021 AFC Table 1207.6, §1207.6.3
100 New York City Fire Department: New Fire Department Rule 3 RCNY 608-01: "Outdoor Stationary Battery Systems"
101 2022 New York City Fire Code Chapter 6 section 608.1 Stationary ESS
102 2018 IFC §1206.2.3.2
103 2022 SJFC Table 1207.6
104 2022 SJFC §1207.6.3, §911.1
105 2022 CFC Table 1207.6
106 2021 AFC Table 1207.6, §1207.6.2
107 2018 IFC §1206.2.11.5
108 2022 SJFC Table 1207.6, §1207.6.2
109 2022 CFC Table 1207.6
110 2021 AFC Table 1207.6, §1207.6.5
111 2018 IFC 1206.2.10.7
112 2022 SJFC Table 1207.6, §1207.6.5
113 2022 CFC Table 1207.6
114 2021 AFC §1207.3.5
115 2021 AFC §1207.7.4
116 2022 New York City Fire Code Chapter 6 section 608.13 Stationary ESS
117 2020 Fire Code of NY State Chapter 12 Section 1206:

Electrical ESS
118 2018 IFC 1206.3.2.2
119 2022 SJFC §1207.3.5
120 2022 SJFC §1207.7.4
121 2022 CFC §1207.3.5, §1207.7.4

San Francisco Local Agency Formation Commission
City Hall
1 Dr. Carlton B. Goodlett Place, Room 409
San Francisco, CA 94102-4689
Tel. 415.554.6756 Fax. 415.554.5163

Page 1 of 5 ends

COMMISSIONERS
Hillary Ronen, Chair
Board of Supervisors
Hope Williams, Vice Chair
Member of the Public
Dean Preston
Board of Supervisors
Connie Chan
Board of Supervisors, Alternate
Shanti Singh
Member of the Public, Alternate
Jeremy Pollock
Executive Officer
Khalid Samarrae
Policy Analyst
Inder Khalsa
Legal Counsel
Alisa Somera
Clerk
July 19, 2024
TO: LAFCo Commissioners
FROM: Jeremy Pollock, Executive Officer
SUBJECT: LAFCo Introduction to Study for CleanPowerSF on Battery Energy Storage Systems: Why BESS Is Important
The following memo was presented at the July 19, 2024 LAFCo meeting as introduction to Arup International’s “LAFCo Study for CleanPowerSF on Battery Energy Storage Systems” to discuss why BESS is such an important consideration in San Francisco’s climate efforts.

This memo contains the following sections:
• Battery Storage and San Francisco’s Climate Goals
• BESS Use Cases
• The Duck Curve
• San Francisco’s Climate and Electricity Usage Profile Battery Storage and San Francisco’s Climate Goals
Battery energy storage systems (BESS) are a critical technology in San Francisco’s 2021 Climate Action Plan. To meet San Francisco’s goal of 100% renewable electricity by 2025 and 100% renewable energy by 2040, we must dramatically increase our capacity for storing this renewable electricity for use when it is needed. Specifically, BESS play key roles in these strategies for eliminating greenhouse gas emissions in the energy sector:
• Energy Supply Strategy 2: Invest in local renewable energy and energy resilience projects
o ES.2-1: Assist affordable housing developments with installing on-site solar and battery storage and meeting City energy efficiency and solar energy requirements.
o ES.2-3: Explore developing grid-independent solar and storage at critical municipal facilities and other critical or vulnerable community sites. o ES.2-4: Support the development of local renewable electricity production by scaling up programs such as net metering, community solar, feed-in tariffs, and battery storage.
o ES.2-6: Continue to encourage private sector investment in local renewable energy solutions by engaging in public advocacy, educating consumers about their options (such as financing), and serving as a strategic partner. • Energy Supply Strategy 3: Design and develop the reliable and flexible grid of the future o ES.3-1: Plan for the change in electricity demand and usage due to electrification of transportation and buildings through efforts such as the SFPUC’s Integrated Resource Plans and ensure community engagement in these efforts.

ATTACHMENT #1

Page 2 of 5 ends

o ES.3-3: Invest in distribution infrastructure (including acquisition of PG&E assets) and smart-grid technologies, such as advanced metering infrastructure, demand response, and distribution automation.

BESS Use Cases
In residential systems, batteries are predominantly installed to complement rooftop solar power systems.

Residential BESS has two primary uses cases in San Francisco:
• Resilience and Backup Power: BESS provides the ability for maintaining power during grid outages. This has become increasingly important since PG&E adopted the practice of Public Safety Power Shutoffs (PSPS), where PG&E intentionally turns power off during times of severe wildfire danger where high winds could damage PG&E equipment and cause fires in areas with dry vegetation. While San Francisco has not yet experienced any PSPS, backup power remains a vital concern for disaster resilience, particularly in preparing for earthquakes. The City’s SF72 program recommends San Franciscans prepare for 72 hours of self-reliance in case of serious emergencies. The typical size of residential BESS systems will not support 72 hours of full backup power, but would support critical needs, such as refrigeration and medical equipment.

Backup power will become a more important consideration as the City progresses on electrification of transportation and other building operations, such as space heating, water heating, and cooking.
• Load Shifting: BESS enables the storage of excess electricity generated by rooftop solar systems to be used during times of peak demand. CleanPowerSF and PG&E have transitioned most customers to time-of-use (TOU) rates that charge different rates based on the supply and demand of electricity. This load shifting can provide significant savings for ratepayers and help recover the costs of the BESS installation.

The Duck Curve
The “duck curve” is a term that was coined by the California Independent System Operator (CAISO) in 2013, to describe the chart showing the difference in electricity demand and the available solar energy throughout the day in California. The chart (Figure 1) resembles the silhouette of a duck, with demand for electricity being lowest during the middle of the day, when solar generation peaks, before demand rapidly spikes in the evening as solar generation decreases and electricity usage peaks in the mid-evening hours.

Figure 1: California Duck Curve, 2015 to 2022 (Source: CAISO) The steepness of this duck curve has increased in California because of several factors:
• Increased solar capacity
• Increased temperatures from global warming, which increases the need for air conditioning

Page 3 of 5 ends

• Increased electric vehicles and home electrification, which increases the amount of electricity demand in the evening when people typically return home from work California’s solar capacity (Figure 2) has increased dramatically in recent years.

Figure 2: California Solar Capacity, 2014 to 2023 (Source: U.S. Energy Information Association) The duck curve provides dual challenges for utilities and electricity providers:
• The need to rapidly ramp up electricity production for these evening peaks in demand. This is often accomplished by peaking power plants that can quickly be turned off and on. These are typically highly polluting plants powered by natural gas. • The need to prevent oversupplies of electricity on the grid during the midday peak in solar production. This can lead to the curtailment of solar power generation where the grid operator is not able to use all of the solar power being produced.

CAISO data (Figure 3) shows how curtailment has increased significantly with the increased solar capacity in recent years. CAISO states, “solar curtailment occurs most frequently in spring and fall when demand is low because of moderate weather, and sunny, breezy days produce an abundant supply of renewable generation.”
Because the electricity grid must always be built to meet peak demand, some amount of electri city curtailment is inevitable. However minimizing the duck curve and curtailment offer significant benefits:
• Reducing GHG emissions by minimizing the need for peaker plants • Reducing the total amount of electricity generation needed • Reducing the need for new electricity transmission infrastructure BESS is the primary solution to smoothing out the duck curve by storing the excess electricity produced during the midday peak in supply for usage during the early evening peak in demand.

Page 4 of 5 ends

Figure 3: California Wind and Solar Curtailment Totals by Month (Source: CAISO) San Francisco’s Climate and Electricity Usage Profile
The California electric grid is built to meet the state’s peak electricity demand, which typically occurs between late June and early September, when high temperatures increase the demand for air conditioning. San Francisco is one of the very few parts of the state where demand peaks in the winter.

Figure 4: CleanPowerSF Electricity Load Forecast vs Statewide Forecast

Page 5 of 5 ends

CleanPowerSF’s 2022 Integrated Resource Plan states that “CleanPowerSF is a winter peaking program and has lower demand than the CAISO system average during the summer months, due in part to San Francisco’s unique weather which has cooler than average summer months and lower load during this time of the year.”
Figure 4 shows how the statewide electricity load forecast developed by the California Public Utilities Commission has a significant peak in the summer. CleanPowerSF’s electricity load forecast is shown in yellow, with a smaller peak in the winter.

San Francisco’s winter peak presents a challenge for CleanPowerSF’s ability to meet the City’s 100% renewable electricity targets, because solar energy is more available and affordable in the summer.

Purchasing sufficient solar power to meet San Francisco’s winter peak would result in surplus power during the summer. This power can be resold to other areas of the state during the summer, when electricity prices are typically highest, but this introduces additional complexity and potential financial uncertainty for CleanPowerSF.

This dynamic emphasizes the critical role BESS plays in San Francisco’s ability to simultaneously maximize our renewable energy resources while minimizing costly investments required for electricity production and transmission.

CleanPowerSF is a program of the San Francisco Public Utilities Commission (SFPUC), an enterprise department of the City and County of San Francisco.

CleanPowerSF is committed to protecting customer privacy. Learn more at cleanpowersf.org/privac y.

525 Golden Gate Avenue, 7th Floor
San Francisco, CA 94102
T 415.554.0773
TTY 415.554.3488
[email protected]
M

EMORANDUM
D
ATE: September 17, 2024
TO
: Jeremy Pollock, LAFCo Executive Officer
F
ROM: Michael Hyams, Deputy Assistant General Manager,
CleanPowerSF and Power Resources
Daniel Young, Manager, Customer Programs
Russell Stepp, Utility Specialist, Customer Programs
SU
BJECT: Study on Barriers to Installing Battery Energy Storage Systems in Residential Buildings in San Francisco
On behal
f of the s taff of the San Francisco Public Utilities Commission (SFPUC), we are providing the following comments on L AFCo’s recen tly completed study on the barriers to installing battery energy storage systems in San Francisco residential buildings (Study). The LAFCo study was c onducted with funding provided by CleanPowerSF ratepayers pursuant to the Memorandum of Understanding (MOU) executed between the SFPUC and LAFCo on May 9, 2023.

W
e appreciate LAFCo’ s col laborative work on the S tudy, which involv ed the participation and consultation of staff from LAFCo, SFPUC, the Environment Department, Department of Building Inspection and the Fire Department.

W
e see battery storage as one of many important technologies and tools that will support reach ing and maintaining San Francisco’s goal of a 100% renewable energy system by optimizing the delivery and use of variable renewable generation and improving grid stability and reliability. The residential battery storage market is st ill developing and faces both cost and technical challenges. By providing general background on batteries and examining some of the barriers that may be slowing their deployment in residential buildings , this report will be a helpful resource for local policymakers.

Th
e Study specifically focused on the very important challenges faced by local building and fire officials throughout the country as batter y systems become more common in urban areas. It was gratifying that the S tudy concluded that local building and fire officials safeguarding San Francisco are generally in ATTACHMENT #2
Page | 2

lockstep with the several comparative jurisdictions examined. We hope that the identified permitting challenges (Section 15. 2) and the suggested improvements made in the report in Section 15 .3.2 (specifically defining key code terms and permitting process streamlining) are helpful to the Department of B uilding Inspection and the Fire Department as they continue to improve permitting requirements, and processes for this new technology.

Overall, we hope the Study’s review of San Francisco’s fire code and permitting processes for battery energy storage will help San Francisco improve the experience of residents seeking to install these systems. Improving the permitting process and inter-agency coordination for these projects will help residents willing to invest in clean energy systems and their install ers avoid unnecessary delays and cost. The Study’s conclusion that local regulations and code provisions were consistent with the other jurisdictions examined, indicates that San Francisco is not out of sync, and that other factors may be involved in shaping or limiting local uptake.

To enhance the value of batteries for residential c ustomers, t he Study recommends the C ity “facilitate opportunities for Virtual Power Plants.” Virtual Power Plants are an emerging technology that involves aggregating various customer-owned/sited equipment (e.g., solar, batteries/energy storage , heat pumps, other building syste ms) through monitoring and control software to respond to power market price signals. Most Virtual Power Plants are managed by a third-party aggregator who controls the participating equipment and decides when and how they operate in exchange for sharing s ome of the revenue they earn with their owners (subject to agreement by the owner of the equipment). While there is promise in the use of Virtual Power Plants to control customer-owned equipment for the benefit of the grid, more research needs to be done t o understand their ef fectiveness and value t o both participat ing customers and utilities before committing to or facilitating these arrangements , as well as the rol e of other incentive mechanisms (e.g., rebates, etc.) that may also be used to promote storage.

The ec onomics of energy storage is dynamic and constantly evolving in response to government policies, technologi cal change, and global supply chains and markets. With the California Public Utilities Commissio n’s recent adoption of the Net Billing Tariff (sometimes referred to as Net Energy Metering

3.0) oversizing solar has become a poor investm ent, which batteries can help mitigate, but adding a battery signific antly i ncreases the size of the overall investment required. To better understand what may be needed to foster the market for energy storage in San Francisco, additional work could be done to examine what mo tivates residential and commercial customers to i nvest in battery stor age systems in the first place (e.g., financial payback, improved electric reliability, etc.), as well as the value of storage to the utility and the grid.

The SFPUC will be evaluating these dr ivers as it works to design new programs to serve CleanPowerSF customers.

Although some areas require further research, we believe the Study will contribute to improving the experience of residential customers seeking t o install battery systems. We look forward to continuing to work with LAFCo to Page | 3
identify ways we can promote the equitable, smart growth of battery storage systems in San Francisco, as the market and technologies for these devices continue to mature.

San Francisco Fire Department
•
. .

August 23, 2024
Mr. Jeremy Pollock, Executive Officer
San Francisco Local Agency Formation Commission (LAFCo) 1 Carlton B. Goodlett Place
San Francisco, CA 94102
Division of Fire Prevention
and Investigation
Re: Feedback on LAFCo Study Regarding Battery Energy Storage Systems (BESS) Dear Mr. Pollock,
The San Francisco Fire Department (SFFD) appreciates the opportunity to review and provide feedback on the LAFCo study concerning Battery Energy Storage Systems (BESS). We recognize the increasing interest from residents and commercial property owners in adopting BESS to reduce their carbon footprint, enhance energy independence, and ensure power availability during grid outages. However, ensuring the safe implementation of these systems is paramount to prevent hazards that could jeopardize lives, property, and the environment.

As the Authority Having Jurisdiction (AHJ), the SFFD has a multifaceted role in overseeing Energy Storage Systems throughout their lifecycle. This includes setting standards based on applicable fire codes, reviewing BESS project plans, conducting installation inspections, and managing BESS fires when necessary. When the fire code is silent or ambiguous-such as regarding battery hazards----our team must interpret these risks and develop standards to ensure public safety and protect our firefighters.

The 2022 California Fire Code (CFC) currently lacks specific hazard classifications for batteries used in BESS, leaving significant regulatory decisions to the AHJ. The absence of detailed data on battery performance during fires, long-term use, and environmental exposure further complicates regulation. To address these gaps, the SFFD has created Administrative Bulletins (ABs) to clarify our interpretation and application of the code. Administrative Bulletin 5.12 (AB 5.12) was developed to assist the public in understanding BESS requirements for single-family (A-3) and multi-family homes (A-2) as outlined in the 2022 CFC.

For instance, AB 5.12 addresses the potential hazards associated with interior BESS installations near property lines in unfinished wood-framed constructions. To mitigate these risks, we require the installation of 5/8-inch Type X gypsum board behind and above the BESS to reduce fire risks to neighboring properties in the event of a thermal runaway. This precaution was not specified in the 2022 CFC.

Although the report was drafted primarily before June 2024, it is important to note that, effective July 1, 2024, the CFC increased the maximum aggregate capacity for BESS from 280 kWh to 600 kWh, aligning with regulations in other jurisdictions as mentioned in the report. Additionally, the mid-cycle supplement codified the need for gypsum board protection, although it did not specify dimensions as detailed in our AB 5.12.

Telephone (415) 558-3300
Fax (415) 558-3323
698 Second Street, Room 109
San Francisco, CA 94107-2015
ATTACHMENT #3
San Francisco Fire Department Division of Fire Prevention and Investigation
The LAFCo report also references our interpretation of fire code language concerning BESS "systems" and "units," suggesting that this may impose additional requirements on homeowners for aggregate BESS exceeding 20 kWh. However, it is crucial to note that the CAL-FIRE Office of the State Fire Marshal issued Code Interpretation 24-02 on July 9, 2024, clarified that the 20 kWh limit applies to each individual unit and to the aggregate rating. Installations exceeding this limit must comply with California Fire Code Sections 1207.1 through 1207.9. Consequently, installations exceeding 20 kWh, whether as a "unit" or a "system," will also require a building permit, and the SFFD will enforce these requirements accordingly.

The SFFD has also observed numerous fires involving lithium-ion battery-powered mobility devices (PMDs). In response, we have updated the San Francisco Fire Code (SFFC) to mandate that batteries in these devices must be listed and that buildings storing or charging five or more PMDs must include a I hour rated room with fire sprinklers and a smoke detection system. We acknowledge that PMDs and BESS are distinct and should be treated accordingly.

To address hazards related to electric vehicle (EV) charging, we developed Administrative Bulletin 4.29 (AB 4.29) to guide the installation of indoor EV charging stations. Given the lack of specific hazard classifications for lithium-ion batteries in the CFC, AB 4.29 provides guidance on fire sprinkler design and rated enclosures necessary to contain fires before emergency services arrive, as water alone cannot extinguish these vehicle battery fires.

We understand the challenges faced by building owners in complying with code requirements for BESS, PMDs, and indoor EV charging stations. To support compliance, we offer pre-application meetings where designers and building owners can seek code clarifications or propose alternative solutions. We remain committed to updating the SFFC and our Administrative Bulletins as new information becomes available.

Finally, based on the study, state legislation requirements, and our experience with Solar App+, we recommend modifications to the software's permitting capabilities. Enhancing these capabilities could significantly streamline the process and facilitate the broader installation of BESS.

Thank you for your attention to these important safety considerations.

Sincerely,
Ken Cofflin
Fire Marshal
Assistant Deputy Chief
San Francisco Fire Department
cc: AFM Kathy Harold
Telephone (415) 558-3300
Fax (415)558-3323
698 Second Street, Room 109
San Francisco, CA 94107-2015
Issued: July 9, 2024
Electrical Energy Storage Systems (ESS) Listing and Rating

OVERVIEW
Code Section(s):

Edition:

Requested By:

Date Received:

QUESTION:

California Fire Code (CFC) 1207.11.1 & 1207.11.4
2022 California Fire Code
Bryan Hamlin, HomeGrid subsidiary of Lithion
October 23, 2023
Does CFC 1207.11.1 require the company that performs testing and lists a product be the same company that develops the testing standards.

ANSWER:

No. CFC 1207.11.1 states that ESS shall be listed and labeled in accordance with UL 9540.

QUESTION:

Does the CFC 1207.11.4 individual 20kWh limit apply when modularized units can be stacked beyond that limit?
ANSWER:

Yes. Per CFC 1207.11.4, each unit shall be 20kWh maximum. ESS installations exceeding the permitted individual or aggregate ratings shall be installed in accordance with California Fire Code Sections 1207.1 through 1207.9.

Issued: July 9, 2024 Page 1 of 1
Memorandum
September 17, 2024
T o: Jeremy Pollock, Executive Officer, San Francisco Local Agency Formation Commission (LAFCo) From: August Goers, Chief T echnology Officer, Luminalt Energy Corporation Subject: 20 kWh Energy Storage System Interpretation for Building Permit Threshold In regards to the SFFD LAFCo BESS response letter dated August 23, 2024, I would like to provide a response to the statement that the 20 kWh system size threshold for R-3 or R-4 occupancies requires full building permit approval.

I believe there was a misunderstanding of CAL FIRE Code Interpretation 24-02. In Code Interpretation 24-02, the following question was asked and answered:

The SFFD LAFCo response letter stated that this “clarified that the 20 kWh limit applies to each Fire Code Sections 1207.1 through 1207.9.”
However, The CAL FIRE Code interpretation was referring to CFC 1207.11.4 Energy Ratings as highlighted:
10 Carolina St, San Francisco, CA 94103 Phone: (415) 641-4000 [email protected] www.luminalt.com CSLB #845219 ATTACHMENT #4
Asseenhighlightedingreen, ESSexceedingthepermittedindividual (20kWh) or aggregateratings(600kWhontheproperty) arerequiredtobeinstalledtomeet Sections1207.1through1207.9. Otherwise, section1207.11ESSinGroupR-3andR-4Occupanciesapplies.

TheSFFDLAFCoresponseletter seemstohaveconflatedtheratingsasintendedfor 1207.11R-3andR-4OccupanciesperhapswithTABLE1207.1.1, whichdoesnot applyfor R-3or R-4buildings.

I welcometheopportunityfor further discussiononthismatter, otherwiseI hopetheSFFDisamenabletoacceptingemail electrical permitsfor R-3or R-4buildingswithESSmeetingthesizerequirementsof 1207.11.

Sincerely,
August Goers(415) [email protected]
Luminalt EnergyCorporation
10CarolinaSt, SanFrancisco, CA94103 Phone: (415) 641-4000 [email protected] www.luminalt.com CSLB#845219

From: Mike Lepisto
To: Pollock, Jeremy (BOS)
Cc: Joseph Kaylor; Cole Roberts
Subject: RE: BESS study feedback and presentation
Date: Thursday, September 19, 2024 3:49:27 PM
Attachments: image001.png
image004.png
image005.png
image003.png
image002.png
image007.png
Jeremy,
Luminalt

correct.
24-02

does

not

state

that

CFC
§
1207.11

not

applicable

any

“unit”

“system”

over
20kWh.

When

the

individual

“unit”

exceeds

20kWh,

the

aggregate

limit

exceeded,

then
CFC

§1207.11

longer

applicable.

CFC
§
1207.11.2.1

supports

this

with

spacing
between

units

requirement

(which

5.12 incorporates

requiring

UL9540A

test

data

and
manufacturer’s

installation

instructions).

The 24-02 interpretation is referring to modular units which can be configured for varying capacities.

This

obvious

because

question

comes

from

Homegrid

which

sells

units

that

can
be

configured

between

9.6kWh

38.4kWh
https://cdn.sanity.io/files/xcmp4e9i/production/90826f0975af48b98a2dd1a0963991e3870833e

6.pdf. If the capacity of one Stack’d Series unit is over 20kWh for the unit then § 1207.1 – .9 are

applicable.

For

the

current

Stack’d

Series

(image

below)

1-4

would

SFFC
§
1207.11
while

5-8

would

follow
§
1207.1

through

§1207.9.

ATTACHMENT #5
As

today,

9/19,

longer

able

access

AB5.12
Access

Denied

Fire

Website

(sf-
fire.org). However, yesterday 9/18 was accessible and stated:

Mike
Mike Lepisto
Associate | Fire & Life Safety PE,
Fire Protection
Arup
560 Mission Street, Suite 700
San Francisco, CA 94105 USA
This message is from outside the City email system. Do not open links or attachments from untrusted sources.

From: Alex Lantsberg
To: Pollock, Jeremy (BOS)
Subject: Comments on BESS report
Date: Friday, September 20, 2024 10:30:11 AM
Attachments: Outlook-clb55yms
Outlook-p3fobwip.png
Jeremy,
Thank

you

for

the

opportunity

provide

comments

this

report.

This

summarizes

the

comments

I
shared

with

you

the

document.

While

this

study

represents

important

step

towards

accelerating

the

adoption

Battery

Energy
Storage

System,

the

authors

make

some

fundamental

errors

that

have

significant

policy

implications.

short,

one

doesn’t

accurately

describe

the

industry

they’re

trying

affect

then

the

interventions
will

not

work

and

may

fact

harmful.

will

specifically

focus

the

study’s

workforce

and

training
elements

1. Section 13 ignores the current availability of a skilled electrical workforce that isn't working because of the economic impacts of the pandemic and changes in San Francisco's market conditions. Because

apprenticeship

programs

are

*DEMAND

BASED*

overhang

of
unemployed

journey-level

workers

reduces

demand

for

apprentices.

Even

under

those
circumstances,

with

the

dislocations

the

COVID

pandemic

increasingly

behind

Local

6 has
initiated

two

apprenticeship

cohorts

2024

and

planning

third

for

later

this

year.

date
will

announced

shortly.

2. The most direct way to expand workforce development opportunities in the renewable energy sector is to extend the SFPUC’s water and wastewater PLAs to energy projects (p. 30). This

will

both

send

signals

the

market

that

these

workers

are

needed

that

the
program

will

adjust

accordingly

and

well

provide

mechanism

for

the

City

take

active
role

expanding

the

skilled

and

trained

electrical

workforce.

3. There is no need for standalone training on BESS (p. 31-32).

SFECI

again

underscores

that
BESS

work

component

electrical

work

which

already

covered

joint

apprenticeship
programs

via

ESAMTAC

modules

and

general

electrician

education.

The

California

Contractors
State

Licensing

Board

has

recognized

this

fact

and

promulgated

regulations

accordingly.

Similarly,

shown

research

the

Don

Vial

Center

for

the

Green

Economy,

the

occupation
of

solar

installer

limited

and

doesn't

provide

opportunity

work

across

the

electrical

and
renewable

energy

sector;

general

electrician

can

solar

but

solar

installers

can't

do
electrical

work.

Simply

fusing

narrow

BESS

specialization

without

the

complete

electrical
training

limits

both

economic

and

career

opportunities.

ATTACHMENT #6

4. The study is unclear how the absence of Virtual Power Plant incentives creates “substantial… economic benefits and sustainability goals” for San Francisco residents.

5. Prevailing wage regulations create opportunities for apprentices (p. 35). The authors betray a fundamental misunderstanding of prevailing wage regulations. Registered apprentices are paid according to the prevailing wage rates established by DIR regardless of whether they’re working on public works project or under a union agreement. Rather than limiting opportunities for apprentices, adding an overall prevailing wage requirement, which embeds apprentice utilization ratios in the regulation, creates opportunities for electrical apprentices.

Thank you for your consideration. SFECI looks forward to engaging with both LAFCO and SFPUC to ensure that battery energy systems are safely integrated into San Francisco’s built environment and that this expands economic opportunities for electrical workers.

Alex Lantsberg
Director of Research & Advocacy

San Francisco Electrical Construction
Industry
55 Fillmore St.

San Francisco, CA 94117
Mobile 415.794.2539
@ECI415

FACTORY BUILT ERRORS:
www.honestbuilderscoalition.org
EV CHARGER REBATE:
www.skilledandtrained.com
Book time to meet with me

This Message Is From an External Sender
This message came from outside your organization.

Report Suspicious ‌
From: Rush Rehm
To: Commission
Subject: Public comment for the SFPUC meeting on October 22 Date: Monday, October 21, 2024 1:18:16 PM
Attachments: New SFPUC comment.pdf
Let me welcome the new SFPUC commissioners and wish you the best as you deal with the problems and crises that affect all of us who live in the Bay Area.

I write – as I have written and spoken via zoom to the Commission before – to express my deep concern about the SFPUC proposed budget and 10-year capital plan. A perusal of the proposal as it currently stands reveals several serious issues, which I hope the Commission will address.

Many others, myself included, point out the short- and long-term negative effects that will result from your current Design Drought model. Although one should prepare for the worst, by assuming more than an Armageddon-like water shortage, one that has a statistical likelihood of occurring once in 25,000 years, the knock-on effects are disastrous– for today's rate payers and for allocation of water usages in the future (especially long-term disastrous effects on the health of our local rivers, fish populations, and other beneficial uses).

Consider the real advantages of reducing your Design Drought from seven years worst-case scenario to six years, or five years (a far more sensible metric).

By projecting ridiculously inflated future water demand, the Commission does a great disservice to the current population, especially ratepayers. Look again at your projections for population increase and water use and compare it realistically to what current statistical predictions indicate. If water sales continue to decline, as many predict, the consequences will prove dire for the finances of the Commission.

It would be wise for the Commission to conduct a sensitivity analysis that includes low, medium, and high water demand and sales projections. If you stick with what the SFPUC has proposed in the past, the Alternative Water Supply would have a disastrous effect on the budget, perhaps doubling it. What will happen then? Water rates will soar to cover the costs, and then rate payers will go bananas, as they should.

I appreciate the opportunity to contribute my thoughts via email, as I cannot attend the meeting on Tuesday October 22 in person. I am also attaching my comments as a PDF file, which you may distribute to the commissioners if that should prove convenient.

Sincerely,

Rush Rehm
Professor (emeritus), Stanford University
415-710-7074
[email protected]
Let me welcome the new SFPUC commissioners and wish you the best as you deal with a series of crises that affect all of us who live in the Bay Area. I write – as I have written and spoken via zoom to the Comission before – to express my deep concern about the SFPUC proposed budget and 10-year capital plan. A perusal of the proposal as it currently stands reveals several serious issues, which I hope the Commission will address. Many others, myself included, point out the short- and long-term negative effects that will result from your current Design Drought model. Although one should prepare for the worst, by assuming more than an Armageddon-like water shortage, one that has a statistical likelihood of occurring once in 25,000 years, the knock-on effects are disastrous– for today's rate payers and for allocation of water usages in the future (especially long-term disastrous effects on the health of our local rivers, fish populations, and other beneficial uses). Consider the real advantages of reducing your Design Drought from seven years worst-case scenario to six years, or five years (a much better metric). By projecting ridiculously over-inflated future water demand, the Commission does a great disservice to the current population, especially ratepayers.. Look again at your projections for population increase and water use and compare it realistically to what current predictions indicate. If water sales continue to decline, as many predict, the consequences will prove dire for the finances of the Commission. It would be wise for the Commission to conduct a sensitivity analysis that includes low, medium, and high water demand and sales projections. If you stick with what the SFPUC has proposed in the past, the Alternative Water Supply would have a disastrous effect on the budget, perhaps doubling it. What will happen then? Water rates will soar to cover the costs, and then rate payers will go bananas, as they should. I appreciate the opportunity to contribute my thoughts via email, as I cannot attend the meeting on Tuesday October 22 in person. Sincerely Rush Rehm Professor (emeritus), Stanford University 415-710-7074 [email protected] This Message Is From an Untrusted Sender
You have not previously corresponded with this sender.

Report Suspicious ‌
From: Martin Gothberg
To: Lennear, Tiffany; Commission
Subject: SFPUC 10-22-2024
Date: Tuesday, October 22, 2024 6:13:35 AM
General Comment, Item 5 on the Agenda
_______________________________________
Welcome new members and thank you all for your time.

My name is Martin Gothberg and I am a consumer of Tuolumne River water.

My comment relates to the Design Drought, an imaginary and arbitrary drought that has never happened in history. Models tell us it is beyond conservative - unlikely within 8 thousand to 25 thousand years.

What’s frustrating is the response from the Commission that we “just don’t know how long a drought can be, especially with climate change.” Over a two-year period the last of the videotaped workshops focused on the Design Drought, and the NGOs cited extensively from the Long-Term Vulnerability Assessment (climate change study).

SFPUC staff ignored the report because it didn’t support their narrative. The report essentially concluded that climate change doesn’t pose a risk.

Ignoring data and evidence because it is contrary to your narrative means you might have a corrupted decision making process. It is a Red Flag.

Staff refuses to comment on a likelihood of occurrence/return period of the Design Drought, and the Commission has never asked them to respond to analyses presented.

The longer the amount of time used for an imaginary drought, the more financial impacts come into play like capital expenditures and maintenance cost for new storage or any other system of water capture and delivery.

Please keep this in mind as you act going forward. Thank you.

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From: Francisco Da Costa
To: Peskin, Aaron (BOS); Ronen, Hillary (BOS); Mandelman, Rafael (BOS); Dorsey, Matt (BOS); Stefani, Catherine (BOS); Preston, Dean (BOS); Chan, Connie (BOS); Walton, Shamann (BOS); [email protected]; London Breed; Charlene Nijmeh; Francisco Da Costa; [email protected]; Lennear, Tiffany; Ordikhani, Masood; Joshua Arce; Ken Nijmeh; Valerie Tulier
Subject: Letter from the Chairperson - linked to the assault - and the replay from the U.S Department of the Interior.

Date: Wednesday, October 23, 2024 10:04:16 AM
I am sending you the response from the Chairperson - the Muwekma Ohlone - so that you all are informed that the Muwekma Ohlone is here to stay.

The Muwekma Ohlone will fight for their rights as a Tribe that once was Federally recognized until 1927 - and then illegally removed:

Please see attached:
https://www.facebook.com/muwekma
FILE_3617.pdf
We must support the Muwekma Ohlone, the host nation and tribe of San Francisco.

Francisco Da Costa
Director
Environmental Justice Advocacy
This Message Is From an External Sender
This message came from outside your organization. Report Suspicious From: Peter Drekmeier
To: Commission
Subject: Biological Goals & Adaptive Management
Date: Wednesday, October 23, 2024 10:56:43 AM
Attachments: TRT Letter Re- SFPUC Resolutions.pdf
Dear Commissioners,
Once again, welcome to the three new Commissioners and congratulations to Commissioners Stacy and Arce for their new roles as President and Vice President.

As I mentioned at Tuesday’s meeting, one of the biggest issues you will face over the next year is whether the Bay Delta Water Quality Control Plan should be implemented or replaced by the Tuolumne River Voluntary Agreement. I strongly encourage you to hold a workshop soon (we would love to present) to get a better understanding of the debate. I hope we don’t find ourselves in a situation where decisions are rushed without proper background on the issue.

Attached is a letter I submitted on September 5 regarding the issue of biological goals and adaptive management that I raised at yesterday’s meeting.

Thank you.
-Peter
-----------------------
Peter Drekmeier
Policy Director
Tuolumne River Trust
[email protected]

OFFICES
San Francisco

Modesto

Sonora

Mailing Address
P.O. Box 3727
Sonora, CA 95370

Phone
(415) 882-7252

Website
www.tuolumne.org

BOARD MEMBERS
John Kreiter, Chair
Eddie Corwin, Vice Chair
Eric Riemer, Treasurer
Marek Robinson, Secretary
Jose Borroel
Cindy Charles
Harrison “Hap” Dunning
Eric Gonzalez
Camille King
Marty McDonnell
Homero Mejia
John Nimmons
Iris Stewart-Frey
Bart Westcott
Brad Wurtz

September 5, 2024

President Tim Paulson and Commissioners
San Francisco Public Utilities Commission
Via email to [email protected]

Re: Concerns about SFPUC Governance.

Dear President Paulson and Commissioners:

On March 26, 2019, the SFPUC adopted Resolution 19-0057 (attached), and on June 23, 2020 the Commission adopted Resolution 20-0138 (attached). Both resolutions directed staff to work with the Modesto and Turlock Irrigation Districts to include biological goals and an adaptive management plan in the Tuolumne River Voluntary Agreement (TRVA).

On May 10, 2024, I submitted a Public Records Act request to the SFPUC for “all documents and communications produced or received by the SFPUC related to biological goals/outcomes and/or an adaptive management plan and process using performance measures that have been or might be included in the Tuolumne River Voluntary Agreement.”

On June 5, 2024, I received a response to my request from the SFPUC stating, “We have located responsive records but except for the attached resolution, we are withholding them because they are exempt from disclosure. Specifically, records that contain information that constitutes attorney-client communications…”

I hope you will agree that biological goals and adaptive management have nothing to do with attorneys.

After the SFPUC unjustifiably denied my request, I filed similar Public Records Act requests with the Modesto and Turlock Irrigation Districts. Both agencies responded, providing me with more than 60 documents. Not a single document referenced any conversations with the SFPUC about biological goals and/or adaptive management.

It appears that staff simply ignored the Commission directives. I request that the Commission revisit Resolutions 19-0057 and 20-0138, and direct staff to report on progress made on the directives.

2 Background

From the outset, the SFPUC has opposed the State Water Board’s 2018 Bay Delta Water Quality Control Plan update. Working with the Irrigation Districts, the SFPUC put forward an alternative plan known as the Tuolumne River Voluntary Agreement (TRVA). TRT and other NGOs argued that the TRVA was simply a checklist, and if the proposed measures did not result in sufficient ecosystem improvements, there was not an adequate back-up plan. The TRVA does not include SMART (specific, measurable, achievable, relevant, and time bound) biological and environmental goals, as required by the State Water Board.

Commissioner Moran acknowledged our concerns at the February 12, 2019 Commission meeting, stating, "Our draft voluntary settlement agreement does not really deal with what adaptive management looks like and what the objectives are, and we need to come to grips with that. So, I would support Commissioner Vietor's emphasis on the setting of realistic objectives and an ongoing process to assess progress and to take corrective action where that information is indicating it."

On March 26, 2019 Resolution 19-0057 was adopted. It states:

FURTHER RESOLVED, That this Commission directs staff to include specific biological outcomes in the voluntary agreement that will result in increased fish populations to make them sustainable in the lower Tuolumne River;

And:

FURTHER RESOLVED, That this Commission directs staff to work with MID and TID to develop an adaptive management process using performance measures related to the function and mechanisms of the non-flow and flow measures and resulting biological responses that would be implemented as part of a voluntary agreement for the Tuolumne River, subject to required environmental review and any required Commission approval of funding for such implementation;

On June 23, 2020, SFPUC Resolution 20-0138 was adopted. It states:

FURTHER RESOLVED, That this Commission directs staff to work with MID and TID to develop an appropriate, long-term adaptive management plan and process using performance measures related to the function and mechanism of the non-flow and flow measures and resulting in biological responses leading to increased juvenile salmonid out-migration success from the Tuolumne River to the San Joaquin River that would be implemented as part of the Tuolumne River Voluntary Agreement, subject to required environmental review and any required Commission approval of funding for such implementation;

3 Please Review the SFPUC Meeting Videos

SFPUC Commissioners come and go, and when they step off the Commission institutional knowledge is lost. None of the current Commissioners were serving at the time Resolution 19- 0057 was considered and adopted. This was a laborious process involving four iterations of the resolution over four meetings. Only one current Commissioner was serving at the time Resolution 20-0138 was adopted.

Please review the following SFPUC meeting videos for background on the resolutions.

December 11, 2018
https://sanfrancisco.granicus.com/player/clip/31998?view_id=22&redirect=true Steve Ritchie gives an update on the Bay Delta Plan (starting at 54:00) and Commissioner Vietor proposes a resolution (starting at 58:40).

February 12, 2019
https://sanfrancisco.granicus.com/player/clip/32394?view_id=22&meta_id=677616&redirect=t rue
Steve Ritchie gives an update on the Bay Delta Plan (starting at 54:35) and provides an outline for a resolution (starting at 59:36). Mr. Ritchie states, “So we’re looking for a resolution to have the Commission go on the record with policy level direction regarding the voluntary agreement process.”

March 12, 2019
https://sanfrancisco.granicus.com/player/clip/32631?view_id=22&redirect=true Ellen Levin gives an update on the draft resolution (starting at 26:55), and acknowledges that Commissioner Vietor had introduced an alternative resolution, which she discusses (starting at 53:25).

March 26, 2019
https://sanfrancisco.granicus.com/player/clip/32770?view_id=22&redirect=true The Commission discusses the resolution (starting at 1:30:44) with Commissioner Vietor commenting at 1:56:26. Resolution 19-0057 is adopted.

June 23, 2020
https://sanfrancisco.granicus.com/player/clip/36004?view_id=22&redirect=true The Commission discusses and adopts Resolution 20-0138 (starting at 2:47:49).

4 Thank you for considering my comments and request for a staff update on progress made toward the directives included in the two resolutions.

I look forward to a response.

Sincerely,

Peter Drekmeier
Policy Director
[email protected]

cc: Sean Elsbernd, Chief of Staff for Mayor London Breed Aaron Peskin, President of the SF Board of Supervisors

This Message Is From an External Sender
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Report Suspicious ‌
From: Nicole Sandkulla
To: Lennear, Tiffany
Cc: Herrera, Dennis J; Ritchie, Steve; Robinson, Stephen D; Miller, Katie L; Kastama, Alison A; Feitelberg, Brittany K; Francis, Tom; Schutte, Allison C
Subject: BAWSCA"s Review and Recommendations on SFPUC"s FY 23-24 Annual Report on the WSIP Date: Monday, October 28, 2024 3:13:08 PM
Attachments: 2024_Oct_28_BAWSCA_LTO_SFPUC_re WSIP 2023-24 annual report_FINAL.pdf 2024_Oct28_BAWSCA LTO_State Agencies_FINAL.pdf
Dear President Stacy and members of the Commission (c/o Tiffany Linnear, Director of Commission Affairs),
This email transmits my letter providing BAWSCA’s review and recommendations on SFPUC’s FY 2023-24 Annual Report on the Water System Improvement Program (WSIP).

Also attached is a copy of my letter providing comments to the Joint Legislative Audit Committee, Seismic Safety Commission, and State Water Resources Control Board.

Please call me directly if you have any questions or comments.

Sincerely,
Nicole Sandkulla
_________________________________________
Nicole M. Sandkulla
Chief Executive Officer/General Manager
Bay Area Water Supply and Conservation Agency
155 Bovet Road, Suite 650
San Mateo, CA

94402
Ph:

(650) 349-3000

Cell:

(650) 743-6688
EMail:

[email protected]
Website: www.BAWSCA.org

155 Bovet Road, Suite 650, ⚫ San Mateo, CA 94402 ⚫ ph 650 349 3000 ⚫ fx 650 349 8395 ⚫ www.bawsca.org October 28, 2024
Via email

The Honorable Kate H. Stacy
and Members of the Commission
San Francisco Public Utilities Commission
525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102

RE: BAWSCA Review of the SFPUC Fiscal Year (FY) 2023-24 Annual Report, Water System Improvement Program (WSIP)

Dear President Stacy and Members of the Commission,
BAWSCA has reviewed the State required WSIP FY 2023-24 Annual Report and presents the following findings and recommended actions for the Commission to direct SFPUC staff to implement.

Finding 1: The SFPUC has failed to notify the State, as required, of the changes to the WSIP scope, budget and schedule that were adopted by the Commission on April 9, 2024. The adoption of the latest WSIP baseline scope, budget and schedule on April 9, 2024 is referenced on page ES1. California Water Code Section 73502(c) requires that San Francisco notify the State of adopted scope, budget, and schedule changes to the WSIP. To date, SFPUC has not issued the required Notice of Change (NOC). With prior WSIP revisions, the NOC has typically been submitted within 5 months of the Commission action. It is unclear why there has been a delay in the timely compliance with State law.

Recommendation 1: The SFPUC should submit the required WSIP NOC to the State as soon as possible. In the future, any subsequent NOC submittals should be prioritized such that they are completed and provided to the State within 5 months of Commission action.

Finding 2: Given the ongoing uncertainty of the final design of the Alameda Creek Recapture Project (ACRP), it is likely that the additional funding will be needed beyond the recently added $5M and will require a future NOC. As discussed on page ES2, an additional $5M in WSIP funding was allocated in the adopted SFPUC FY 2024-33 10-year CIP and is earmarked for the ACRP. The level of funding needed to complete the ACRP can be estimated by obtaining detailed knowledge of the anticipated erosion control measures that must be put in place as part of ACRP construction. That detailed knowledge is still being developed by the SFPUC, and hence the $5M provided may well be inadequate given the incomplete design. If so, a future NOC will be required as the ACRP is re-designed over the next several years.

Recommendation 2: Language in future WSIP Annual Reports should be amended to discuss the uncertainty of how best to address erosion control needs into the The Hon. Kate Stacy, President
October 28, 2024

Page 2 of 3 ends

final ACRP design and implementation plan until further detailed ACRP design information and more definitive cost estimates are available.

Finding 3: Three well sites that are a part of the Regional Groundwater Storage and Recovery Project (RGSR Project) will have their rehabilitated pumps stored in a remote warehouse rather than be reinstalled in the well itself. Since the SFPUC’s Level of Service (LOS) Goals are predicated on the assumption that all WSIP constructed facilities will be in-service, it is critical to confirm that the assets can be utilized when and if needed. BAWSCA is concerned that storing pumps without having a solid plan for their maintenance while in storage could prove problematic.

Recommendation 3: The SFPUC should identify the staffing needs, technical requirements, and timeframe necessary for each deactivated well / pump to be brought online to support dry year supply needs within a timely fashion.

Aside from these three findings and associated three recommendations for the Commission’s consideration, BAWSCA also has several minor comments and suggested document corrections which will be shared with SFPUC staff directly as they do not require Commission action at this time.

BAWSCA continues to support the SFPUC’s WSIP efforts and continues to be pleased at the progress made toward the completion of WSIP.

Sincerely,

Nicole Sandkulla
CEO/General Manager

NS/TF/le

cc: Assembly Member Gregg Hart, Chair, Joint Legislative Audie Committee Senator John Laird, Vice Chair, Joint Legislative Audit Committee David Rabbitt, Chair, Alfred E. Alquist Seismic Safety Commission Debra Garnes, Vice Chair, Alfred E. Alquist Seismic Safety Commission Mr. Stefan Cajina, Chief, North Coastal Section, Division of Drinking Water, State Water Resources Control Board
Vlad Rakhamimov, Staff Engineer, North Coastal Section, Division of Drinking Water, State Water Resources Control Board
Marco Pacheco, San Francisco District Engineer, Division of Drinking Water, State Water Resources Control Board
Darrin Polhemus, Deputy Director, Division of Drinking Water, State Water Resources Control Board
The Hon. Kate Stacy, President
October 28, 2024

Page 3 of 3 ends

Daniel Newton, Assistant Deputy Director, Northern California Drinking Water Field Operations Branch, State Water Resources Control Board
Annde Ewertsen, Executive Director, Alfred E. Alquist Seismic Safety Commission Jia Wang -Connelly, Senior Structural Engineer, Alfred E. Alquist Seismic Safety Commission
Dennis Herrera, General Manager, SFPUC
Steven Ritchie, Assistant General Manager - Water Enterprise, SFPUC Stephen Robinson, Assistant General Manager – Infrastructure, SFPUC Katie Miller, Director, Water Capital Programs, SFPUC
Alison Kastama, BAWSCA Liaison, SFPUC
BAWSCA Board of Directors
BAWSCA Water Management Representatives
Allison Schutte, Hanson Bridgett, LLP, Legal Counsel

155 Bovet Road, Suite 650, ⚫ San Mateo, CA 94402 ⚫ ph 650 349 3000 ⚫ fx 650 349 8395 ⚫ www.bawsca.org October 28, 2024
Via email

Assembly Member Gregg Hart - Chair
Senator John Laird - Vice Chair
Joint Legislative Audit Committee
1020 N Street, Room 107
Sacramento, CA 95814

David Rabbitt, Chair
Debra Garnes, Vice-Chair
Alfred E. Alquist Seismic Safety Commission
2945 Ramco Street, Suite 195
West Sacramento, CA 95691

Mr. Stefan Cajina, Chief
North Coastal Section, Division of Drinking Water
State Water Resources Control Board
850 Marina Bay Parkway, Bldg P, Second Floor
Richmond, CA 94804

RE: BAWSCA Review of the SFPUC Fiscal Year (FY) 20 23-24 Annual Report, Water System Improvement Program

Dear Assembly Member Hart, Senator Laird, Chair Rabbitt, Vice-Chair Games, and Chief Cajina,

BAWSCA has reviewed the San Francisco Public Utilities Commission (SFPUC) Water System Improvement Program (WSIP) Annual Report for Fiscal Year 2023-24, dated September 1, 2024 (Annual Report). Attached is BAWSCA’s comment letter to the SFPUC, which includes a request that the Commission direct staff to implement the identified recommendations.

As detailed in the Annual Report, the overall WSIP program has had significant achievements associated with project completion since its’ inception. However, there remain two key projects that have yet to be implemented: the Alameda Creek Recapture Project (ACRP), located in the Sunol Valley Region; and the Regional Groundwater Storage and Recovery Project (RGSR Project), located in the San Francisco (Regional) Region.

The ACRP’s construction was halted in April 2023 due to the need to revisit the project’s overall design. The RGSR Project, which was broken into three phases, has proven to be a difficult project to construct. The SFPUC is committed to addressing the challenges associated with implementing those two key projects, yet admits that the time required to complete increases significantly. Specifically, the WSIP is now scheduled to be completed by June 30, 2032, extending the completion date by approximately 5 years.

Both the ACRP and RGSR Projects are key components of the WSIP, in that each is needed to achieve the WSIP Level of Service (LOS) Goals for Water Supply Reliability.

October 28, 2024

Page 2 of 3 ends

BAWSCA offers the following key findings and recommendations regarding the status and progress of the WSIP for the State’s consideration:

Recommendation 2: Language in future WSIP Annual Reports should be amended to discuss the uncertainty of how best to address erosion control needs into the final ACRP design and implementation plan until further detailed ACRP design information and more definitive cost estimates are available.

October 28, 2024

Page 3 of 3 ends

Please call me if BAWSCA can provide further assistance in the State’s review of the SFPUC’s FY 2023-24 Annual Report, or if you would like to discuss BAWSCA’s comment letter to the SFPUC. I can be reached by phone at (650) 743-6688 or via email at [email protected].

BAWSCA sincerely appreciates the time and attention given by the State in helping ensure the SFPUC’s progress in implementing the critically important WSIP continues.

Sincerely,

Nicole Sandkulla
Chief Executive Officer/General Manager

NS/TF/le

Enclosure

cc: SFPUC Commissioners
Dennis Herrera, General Manager, SFPUC
Stephen Robinson, Assistant General Manager - Infrastructure, SFPUC Steven Ritchie, Assistant General Manager - Water Enterprise, SFPUC Katie Miller, Director, Water Capital Programs, SFPUC
Alison Kastama, BAWSCA Liaison, SFPUC
Vlad Rakhamimov, Staff Engineer, North Coastal Section, Division of Drinking Water, State Water Resources Control Board
Marco Pacheco, San Francisco District Engineer, Division of Drinking Water, State Water Resources Control Board
Darrin Polhemus, Deputy Director, Division of Drinking Water, State Water Resources Control Board
Daniel Newton, Assistant Deputy Director, Northern California Drinking Water Field Operations Branch, State Water Resources Control Board
Annde Ewertsen, Executive Director, Alfred E. Alquist Seismic Safety Commission Jia Wang-Connelly, Senior Structural Engineer, Alfred E. Alquist Seismic Safety Commission
BAWSCA Board of Directors
BAWSCA Water Management Representatives
Allison Schutte, Legal Counsel, Hanson Bridgett, LLP

This Message Is From an External Sender
This message came from outside your organization. Report Suspicious From: Peter Drekmeier
To: Lennear, Tiffany
Subject: Re: Biological Goals & Adaptive Management
Date: Monday, November 4, 2024 7:43:27 AM
Attachments: SFPUC Resolution 19-0057 - 3-26-19.pdf
TRVA Resolution 20-0138.pdf
Hi Tiffany,
I hope you had a nice weekend.

When I sent my most recent letter regarding biological goals and adaptive management, I forgot to include the two resolutions I referenced.

Could you please include the two resolutions (attached) along with my letter in the correspondence log?
Thank you!
-Peter
-----------------------
Peter Drekmeier
Policy Director
Tuolumne River Trust
[email protected]
On Oct 23, 2024, at 12:43 PM, Peter Drekmeier <[email protected]> wrote:

Thank you, Tiffany.

I had a feeling it might just be a glitch.
-Peter
-----------------------
Peter Drekmeier
Policy Director
Tuolumne River Trust
[email protected]
On Oct 23, 2024, at 12:38 PM, Lennear, Tiffany <[email protected]> wrote:

Greetings Peter,
Thank you very much for the kind compliment. It is truly appreciated.

I checked the Commissioner inbox, and your email was delivered. I will check with our IT staff to learn why you received the automated message reply below.

Thank you for bringing the matter to my attention, and please know that your correspondence will be shared with the Commission.

Have a fabulous day!

Kind regards,

Tiffany Lennear
Director of Commission Affairs
San Francisco Public Utilities Commission
525 Golden Gate Avenue
San Francisco, CA 94102
<image001.jpg>

From: Peter Drekmeier <[email protected]
>
Sent: Wednesday, October 23, 2024 12:18 PM
To: Lennear, Tiffany <[email protected]>
Subject: Fwd: Undeliverable: Biological Goals & Adaptive Management

Hi Tiffany, Good seeing you in action yesterday. You handled things well. I wanted to make you aware that it looks like an email I send to the Commission email address earlier today bounced. Please let me know if I should resend my email to Hi Tiffany,

Good seeing you in action yesterday. You handled things well.

I wanted to make you aware that it looks like an email I send to the Commission email address earlier today bounced.

Please let me know if I should resend my email to you directly.

Thanks.

-Peter
-----------------------
Peter Drekmeier
Policy Director
Tuolumne River Trust
[email protected]
Begin forwarded message:

From: <[email protected]>
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Management
Date: October 23, 2024 at 10:56:42 AM PDT
To: <[email protected]
>

Your email couldn't be forwarded
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Ask the recipient's email admin to add you to the accept list for the recipient.

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RESOLVER.RST.RestrictedToRecipientsPermission; not authorized to send to recipient because the sender isn't on the recipient's list of senders to accept mail from From: Peter Drekmeier <[email protected]
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Subject: Biological Goals & Adaptive Management
Date: October 23, 2024 at 10:53:39 AM PDT
To: [email protected]
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Dear Commissioners,

Once again, welcome to the three new Commissioners and congratulations to Commissioners Stacy and Arce for their new roles as President and Vice President.

Attached is a letter I submitted on September 5 regarding the issue of biological goals and adaptive management that I raised at yesterday’s meeting.

Thank you.

-Peter

-----------------------
Peter Drekmeier
Policy Director
Tuolumne River Trust
[email protected]

PUBLIC UTILITIES COMMISSION

City and County of San Francisco

RESOLUTION NO. 19-0057

WHEREAS, The Bay-Delta ecosystem is in a state of crisis with the populations of most species of salmon at record lows, fish populations such as Delta smelt on the brink of extinction, and current water
quality, water quantity and habitat conditions unable to support their recovery; and

WHEREAS, The San Francisco Public Utilities Commissio n (SFPUC) has obligations to meet the water supply needs of its residents and Wholesal e Customers and has obligations under the Raker Act and Fourth Agreement to the Modesto and Turl ock Irrigation Districts (MID and TID), as well as commitments for various environmental water releases and a desire to provide water for future growth in its service area; and

WHEREAS, On December 1 2, 2018, the State Water Board approved Resolution No. 2018-0059, adopting
the Substitute E nviron mental Document and amendments to th e Water Quality Control Plan for the San Francisco Bay-Sacram ento/San Joaquin Delta Estuary ("Phase 1 Amendments"); and

WHEREAS, Also in resolution No. 2018-0059, the State Wat er Board instructed its staff to (1) "assist the California Natural Resources Agency i n completing a Delta watershed-wide agreement, including potential
flow and non-flow measures for the Tuolumne River, and
associated analyses no later than March 1 , 2019," and (2) "incorporate the Delta watershed-wide agreement, including potential amendments to implement agr eements related to the Tuolumne River, as an alternative for a future, comprehensive Ba y-Delta Plan update that addresses the reasonable protection of beneficia l uses across the Delta watershed, with the goal that comprehensive amendments to the Bay-Delta Plan across th e Delta watershed may be presented to the State Water Board for consideration as early as possible after December 1 , 2019"; and

WHEREAS, In January 2019, the City and County of San Francisco joined a lawsuit in the interest of protecting its rights and interests and those of its Wholesale Customers and because the State's proposed flow regime would limit its abilit y to meet its supply obligations and significantly impact the over 2.7 million people served by the Hetch Hetchy Regional Water System, and on February 14, 2019, the Bay Area Water Supply an d Conservation Agency (“BAWSCA”) filed a motion to intervene in that lawsui t “to protect its member agencies’ substantial interests in ensuring that they continue rec eiving a reliable and affordable supply of high quality water from the Tuolumne River”; and

WHEREAS, On March
1 , 2019, the SFPUC joined numerous other entities including th e California Department of Fish and Wild life and the Cal ifornia Department of Water Resources in submitting to the State Water Board a "Project Descr iption for Proposed Voluntary Agreements," which included a proposal for management of th e Tuolumne River ("Proposed

Tuolumne River Project Description”); and

WHEREAS, This Commission expects the terms of any vol untary agreement for the Tuolumne River that may ultimately be finalized would allow the SFPUC to maintain the (1) Water Supply Level of Service Goal and Objectives and (2) Sustai nability Level of Service Goal and Objectives adopted in Commission Resolution No. 08-0200; and

WHEREAS, The Proposed Tuolumne River Project Descript ion includes a number of flow and non-flow measures (“Discretionary Actions”) that may require MID and TID to conduct environmental review under CEQA as “lead agencies” that ma y require the SFPUC and its wholesale customers to participate in such environmental re view as “responsible agencies”, and this Resolution does not commit the SFPUC or the Whole sale Customers to approve or carry out any Discretionary Actions until any required CEQA review i s complete. In considering any proposed Discretionary Actions, the SFPUC and Wholesal e Customers retain absolute discretion to: (1) make such modifications to any of the proposed Discretionary Actions as may be necessary to mitigate any significant environmental impacts; (2) sele ct feasible alternatives to the proposed Discretionary Actions that avoid any significant adverse impacts; (3) require the implementation of specific measures to mitigate any significant adverse environmental impacts as part of the decision to approve the Discretionary Actions; (4) balan ce the benefits of the proposed Discretionary Actions against any significant environmental impacts before taking final actions to approve the proposed Discretionary Actions if significant impacts cannot be avoided; or (5) determine not to proceed with the proposed Discretionary Actions; and

WHEREAS, The SFPUC continues to negotiate with various stakeholders to further develop and detail a
voluntary agreement; and

WHEREAS, This Commission seeks to memorialize its vie ws and direction regarding its commitment to meeting its water supply obligations and the health of the Bay-Delta ecosystems in this resolution; now, therefore, be
it

RESOLVED, That this Commission supports the SFPUC's part icipation in the negotiation process for a voluntary agreement for the Tuolumne River and the D elta watershed-wide agreement and urges staff to complete said negotiations as rapidly as possible to improve the health of the fisheries and to maintain the reliability of its water supply; and be it

FURTHER RESOLVED, That this Commission urges the Sta te Water Resources Control Board to work in a collaborative and transparent manner to develop achievable and sustainable biological goals for the Delta and its tributaries; and be it

FURTHER RESOLVED, That this Commission finds that a comprehensive approach to the management of habitat, flow, and other factors in the Bay-Delta w atershed is required to protect native fish and wildlife species while concurrently protecting water supply reliability, and the Commission urges all Delta water users on a ll the tributaries to do their fair share to accomplish those goals as SFPUC should not bear a disproportionate water supply burden in

protecting the Bay-Delta ecosystem; and be it

FURTHER RESOLVED, That this Commission expects that all new contributions of flow and non-flow measures under the voluntary agreement for the Tuolumne River and the Delta watershed-wide agreement are in addition to flow obligati ons and required mitigation measures through State or Federal actions existing as of the date of this resolution; and be it

FURTHER RESOLVED, That this Commission directs staf f to include specific biological outcomes in the voluntary agreement that will result in increased fish populations to make them sustainable in the lower Tuolumne River; and be it

FURTHER RESOLVED, That this Commission directs staff to continue to coordinate with BAWSCA given the direct impact of the Phase I Amendments and any voluntary agreement may have on the Wholesale Customers; and be it

FURTHER RESOLVED, That this Commission directs staff to continue to work with and inform other stakeholders about the voluntary agreement process; and be it

FURTHER RESOLVED, That this Commission urges the St ate Water Resources Control Board to make the appropriate findings that any required SFPUC contributions to Delta outflow from the Tuolumne River be used for the protection and recovery of Delta fisheries and not to augment exports south of the Delta or of fset obligations by others to meet water quality objectives; and be it

FURTHER RESOLVED, That this Commission urges early implementation of a new proposed flow schedule for Don Pedro Reservoir and certain Lower Tuolumne River non-flow measures, subject to completion of environmental review for such measure s, if necessary under the California Environmental Quality Act ("CE QA"); and be it

FURTHER RESOLVED, That this Commission directs staf f to expeditiously pursue with MID and TID planning and environmental review for early impleme ntation of flow and certain non-flow measures included in the Proposed Tuolumne River Project Description for the Tuolumne River, subject to any required future Commission approval of funding for implementation of such measures; and be it

FURTHER RESOLVED, That this Commission directs staff to work with MID and TID to develop an adaptive management process using per formance measures related to the function and mechanisms of the non-flow and flow measures and re sulting biological responses that would be implemented as part of a voluntary agreement for the Tuolumne River, subject to required environmental review and any required Commission approval of funding for such implementation; and be it

FURTHER RESOLVED, That this Commission directs staff to proceed with planning efforts to explore economically and environmentally feasible alternative water supply options to meet various SFPUC needs and obligations, including off-setting enviro nmental obligations for instream flows, subject to required environmental review and subsequent

Commission approval of any future water supply projects in consultation with BAWSCA; and be it

FURTHER RESOLVED, That this Commission urges the State Water Board to commence environmental and independent scientific review of the Pro posed Tuolumne River Project Description at its earliest opportunity; and be it

FURTHER RESOLVED, That this Commission directs staff to provide monthly updates to this Commission on progress toward achieving res ults with regard to diversification of its water supplies, early implementation of flow an d non-flow measures, and the completion of voluntary agreements resulting in mor e sustainable fish populations .

I hereby certify that the foregoing resolution was adopted by the Public Utilities Commission at its meeting of March 26, 2019.

Secretary, Public Utilities Commission

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July 16, 2020 BAWSCA Board Meeting Agenda Packet Page 47 July 16, 2020 BAWSCA Board Meeting Agenda Packet Page 48 July 16, 2020 BAWSCA Board Meeting Agenda Packet Page 49 July 16, 2020 BAWSCA Board Meeting Agenda Packet Page 50 July 16, 2020 BAWSCA Board Meeting Agenda Packet Page 51

CleanPowerSF Sfpuc CommissionNovember 12, 2024

CleanPowerSF Sfpuc Commission
November 12, 2024