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)

By Christian Roselund

On 20 September 2022 U.S. rental car company Hertz announced that it will order up to 175,000 EVs from Chevrolet, Cadillac, Buick, GMC and BrightDrop over the next five years. This will include a range vehicle types, from compact vehicles to trucks, sport utility vehicles, and luxury cars, and builds on Hertz’s 2021 commitment to buy 100,000 Teslas. Hertz currently has around 20,000 Teslas for rent in the United States and Canada out of a fleet of 424,000 vehicles and plans for EVs to make up one-quarter of its fleet by the end of 2024.

This latest procurement will begin with delivery of Chevrolet Bolt EVs and Bolt EUVs in the first quarter of 2023. General Motors, which owns the Chevrolet brand and made the announcement with Hertz, plans to scale production of EVs in the United States through 2023 and 2025. The car maker says that the opening of Ultium Cells battery cell factories in Ohio, Tennessee, and Michigan will enable this move.

In addition to the purchase of EVs, Hertz has signed an MOU to launch a nationwide charging network with bp pulse, the EV charging arm of the oil major. These chargers would initially serve Hertz customers, but later expand to ride-sharing drivers and the public, with the first chargers deployed in the first half of 2023. Canary Media reports that these chargers would be mostly at airports but would also be deployed in city centers.

Source: Hertz and GM Plan Major EV Expansion (Hertz)

News coverage: Hertz wants to turn its airport rental-car lots into EV-charging hubs (Canary Media)

By Christian Roselund

As part of its plan to meet federal ozone standards, the California Air Resources Board voted on 22 September, 2022 to move forward on a package of measures including a ban the sale of fossil fuel-fired heating units for homes and businesses starting in 2030. The Zero-Emission Standard for Space and Water Heaters will accompany a host of other measures, including regulation on both light- and heavy-duty vehicles, off-road equipment, and even pesticides in reaching these targets.

Despite being one of many measures to combat ozone, this strikes at the heart of natural gas usage and greenhouse gas emissions from buildings in California. The state’s analysis finds that space and water heating comprise nearly 90% of all building-related gas demand.

CARB plans to work with other state agencies and the U.S. Department of Energy to develop this standard, which would apply to new commercial and residential buildings. It would not require retrofits in existing buildings but would apply to the replacement of burned-out units. As noted by Grist, this move to require replacements to be zero-emissions “opens a new front in the war on
fossil fuels.”

CARB notes that it expects the new rule to rely heavily on heat pump technologies. The agency’s move follows bans on gas appliances in new construction in more than 50 California cities and counties, including the cities of Los Angeles, San Diego, San Francisco, and San Jose. This movement has gone nationwide, with Washington D.C., New York, and Seattle following suit in banning the installation of some or all gas appliances in new buildings. These bans will take effect between 2022 in 2027, depending on the city and the scale of the building.

News: California’s 2030 ban on gas heaters opens a new front in the war on fossil fuels (Grist)

Source: Proposed 2022 State Strategy for the State Implementation Plan (California Air Resources Board)

By Anjali Joshi

The Inflation Reduction Act’s (IRA) support for the growth of the EV battery industry in the United States has led to a stream of new battery investments in the country. In addition to Tier 1 suppliers like LGES and Panasonic, new market players like Kontrolmatik have increased their planned battery cell production capacity in the United States.

However, the country needs to invest in mining activities as well to create a stable and secure battery supply chain. Additionally, the IRA requires EV to have a minimum level of domestic content to qualify for the tax credits under the IRA. These two factors are driving a wave of investment in mineral extraction and processing to support planned battery manufacturing plants in the country.

As the latest in these announcements Piedmont Lithium recently announced its plans to set up a new lithium hydroxide plant, with a planned annual production capacity of 30,000 metric tons, in McMinn County, Tennessee.

Canada’s more attractive regulatory environment has also been attracting suppliers to establish their presence in North America. Mine permitting times are shorter in Canada as compared with the United States. Furthermore, the Canadian government has proposed C$3.8 billion funding to support the country’s mining sector, including critical mineral projects.

As such, the country has witnessed a tremendous growth in terms of investments by different battery market supplies, from the US$5 billion Stellantis and LGES investment in a Windsor battery, to the US$500 million investment by General Motors and POSCO Chemical on battery material production factory in Bécancour, Quebec.

According to a report by Clean Energy Canada, between 2020 and June 2022 the country attracted over US$13.8 billion in investments along the EV battery supply chain, including:

• US$1 billion for EV battery material extraction and materials processing
• US$5.2 billion for EV battery cell and module manufacturing
• US$6.6 billion for EV assembly
• US$1 billion for EV battery components and recycling

The influx of investments continues with some additional major battery announcements, including Umicore’s US$1.5 billion plan to build a cathode active battery materials facility in Kingston, Ontario, and recent deals of the Canadian government with Volkswagen and Mercedes-Benz to secure Canadian EV battery raw materials and battery manufacturing in the country.

The three projects – Critical Elements Lithium’s Rose project, Sayona Mining’s Authier project, and Sayona and Piedmont Lithium’s La Corne Mine, all in Quebec – are expected to add over 50,000 tonnes of lithium carbonate equivalent production. Nemaska Lithium’s Whabouchi mine in Quebec is another project with 52,500 tonnes of expected annual output from 2025.

Source: CEA Research

By Christian Roselund

New York and Massachusetts have both confirmed that they will follow California in requiring that by 2035, all new automobiles sold must be all-electric. New York Governor Kathy Hochul made this announcement via press release on 29 September and directed New York’s Department of Environmental Conservation to develop draft rules to implement the mandate. These include a requirement that a minimum of 35% of new cars sold in 2026 are zero-emissions.

Meanwhile, Massachusetts state officials confirmed that it will follow California’s timeline in a webinar held by the non-profit Ceres. In the same webinar, Washington State officials stated that they would follow a timeline “similar to Massachusetts,” and Oregon Governor Kate Brown has also noted that her state is working on a rule to phase out gas-powered cars. To implement the rules these states must now draft and pass regulations to implement these pledges, as California has done.

Once these regulations are finalized, 70.2 million Americans – 21% of the nation’s population – will reside in states with phase-out dates for the sale of new internal combustion engine vehicles. And there is the potential for more to follow, as 13 or other states have adopted at least part of California’s Advanced Clean Cars 2 rule.

These regulations will provide a strong signal to automakers to shift production away from internal combustion engines and towards electric vehicles. The United States lags well behind China and Europe in electric vehicle adoption. In 2021, battery electric vehicles represented only 3.4% of new light-duty vehicle sales in the United States, compared to 10% in Europe and 12% in China.

News coverage: ‘We want to … get those EVs in the state as soon as possible:’ Wash., Mass. vow to adopt Calif. car plan (UtilityDive) Source: Governor Hochul Drives Forward New York’s Transition to Clean Transportation (New York Governor Kathy Hochul)