Proposed Code Change Could Constrict Solar, Wind Deployment
By Christian Roselund
A proposal to place electricity generating facilities in the highest “risk category” in building codes could greatly increase costs and limit deployment of solar and wind, according to analyses by CEA and American Clean Power Association (ACP). Proposal S76-22 to the 2024 International Building Code (IBC) would place “public utility facilities providing power generation” in Risk Category (RC) IV, the same category as hospitals, fire stations, and other essential services.
Currently, power generation for emergency backup is already in RC IV and “power generating stations” are in the less strict RC III. However, Solar Energy Industries Association notes that most solar power plants are built to RC I and most wind farms RC II. This proposal would move all “public utility facilities providing power generation” to RC IV.
A preliminary assessment by CEA’s Engineering Services team indicates that this would greatly increase the structural requirements and thus the cost of building solar projects. In its comments on the proposal, ACP has stated that the change will make it “cost and logistically prohibitive” to deploy wind turbines.
Structural Integrity and Grid Reliability
The IBC serves as the model building code for most of the United States; parts of the Caribbean, Latin America, and the Middle East; and a few other nations. Updated editions are published on a three-year cycle following a process of proposals, responses to these proposals, and are votes by members of the International Code Council.
A group of advisors to the Federal Emergency Management Agency (FEMA) proposed S76-22. In their proposal, members of the FEMA Applied Technology Council (ATC) – Seismic Code Support Committee stated that this move would improve consistency in the assignment of risk categories and noted the critical role that electricity plays in recovery after disasters. FEMA-ATC also claims that this will have minimal effect on the cost of deploying solar and wind.
However, in their comments trade groups representing the solar and wind industries and the U.S. Department of Energy’s National Renewable Energy Laboratories (NREL) argue that this concern is misguided and that the impact on costs and renewable energy deployment will be much greater than FEMA-ATC claims. These organizations further argue that S76-22 would reduce reliability and resilience in the aftermath of disasters, not improve it.
The arguments of the opposing organizations are similar, noting that increased costs imposed by higher structural requirements would reduce installation of renewables, with NREL disputing the figures for cost increases put forward by FEMA-ATC. The organizations pointed to the specific advantages of distributed renewable installations versus large conventional power plants during disasters, noting that what matters more than the structure of individual installations is the resilience of the system.
The record of previous disasters supports the arguments increased structural requirements will do little to prevent future outages following disasters. In its comments, ACP noted that the most common cause of the failure of all forms of generation – including wind and solar – during natural disasters is the failure of transmission lines serving generators, not the installations themselves. And where renewables do fail, it is usually not due to structural deficiencies. For example, a significant number of wind turbines failed during the 2021 Texas Power Crisis, but this was largely due to the failure to winterize these turbines.
In its comments opposing S76-22, NREL’s Jeroen van Dam noted that the organization is “not aware of existing data that show that if wind plants would have been designed to Risk Category IV the grid would have stayed on line or recovered quicker in the wake of natural disasters.” Van Dam also noted that deploying more renewable energy is critical to mitigating climate change, which is increasing the severity in extreme weather events.
Counter Proposals & Mobilizations
Solar Energy Industries Association (SEIA) also submitted comments opposing S76-22 and put forward two counterproposals of its own. S79-22 would assign ground-mounted solar installations to the RCI code, and S81-22 would make this change and assign rooftop solar installations to the same risk category the building they are installed on.
While ACP has been working mostly through official channels, SEIA has openly mobilized its members to support its proposals and oppose S76-22, including circulating an industry sign-on letter. S76-22, S79-22, and S81-22 are currently being voted on by International Code Council (ICC) Government Members. Voting lasts from 10 – 24 October 2022.
Source: IBC – Structural 2022 Group B Public Comment Agenda (International Code Council)
