As grid reliability experts, companies, and key stakeholders in the clean energy industry, we write to communicate our deep concern regarding a proposed change to codes that could negatively impact the deployment of job-creating clean energy projects nationwide. Non-utility-owned large-scale photovoltaic (PV) facilities and most wind turbine generator systems (WTGS) are permitted and inspected through local County building departments, using the International Building Code (IBC) as the locally adopted construction code applicable to these non-building structures. A code change proposal under consideration for the future 2024 IBC would significantly affect the deployment of PV and wind facilities by unnecessarily driving up construction costs without achieving its intended benefit of grid resiliency and reliability. For the reasons stated below, the signed organizations request your vote for disapproval of Proposal S76-22 and as further detailed below.
The Federal Emergency Management Agency (FEMA)‘s Applied Technology Council Seismic Code Support Committee (FEMA-ATC SCSC) submitted Proposal S76-22, which increases the structural Risk Category (RC) of most ground mounted large-scale solar and wind projects to the same RC as Essential Services Facilities (including hospitals, fire stations, and police stations). FEMA-ATC SCSC believes that increasing structural loads on all “public utility facilities providing power generation” will achieve increased reliability of the grid, resulting in fewer power outages. However, Proposal S76-22 is written by structural engineers, not grid reliability experts with experience in the core factors of grid resiliency and the interaction of the power generating facility and transmission and distribution systems; both of which are unrelated to structural design loads.
Approximately 95% of large-scale ground-mounted PV facilities are designed, permitted, and inspected as RC I (one). FEMA Proposal S76-22 would increase the RC to IV (four), thereby increasing required wind loads by roughly 33 percent and seismic and snow loads by roughly 50 percent. For hurricane-prone regions or regions with high snow loads, this means projects could be deemed economically unviable; mainly due to a lack of PV modules tested and rated for those higher loads and also for increased equipment needed.
Additionally, nearly all wind turbines in the U.S. are designed and permitted to RC II (two), based on to ASCE/AWEA Recommended Practice RP2011. An increase to RC IV would increase extreme wind design loads for turbines by a minimum of 20% and increase seismic design loads by 50%. These changes will result in limits on the ability to transport the required larger tower sections given road, rail and bridge height and weight constraints. It could also create artificial constraints on the height of wind turbines, thus decreasing the electricity they generate, which undermines project economics and will result in facilities not being built. The wind industry expects that the proposal would only increase the amount of construction material needed for wind turbines and therefore overall cost by 30% or more, without the actual increase in grid power resilience it promises.
The net effect of Proposal S76-22 would be the opposite of the stated intent. Grid reliability and grid recoverability are not based on the survivability of structures, but on grid planning and redundancy. Since grid reliability is already under the auspices of the North American Electric Reliability Corporation (NERC), its regulatory forum is where such integrated considerations should also be debated. Their expert opinions and research should be consulted along with industry stakeholders and AHJs with broad and deep experience in these topics.
As companies and stakeholders that employ the clean energy workforce and deploy renewable technologies including solar, wind, and storage to enable a clean energy economy, the undersigned strongly encourage ICC Governmental Member Voting Representatives to vote as follows
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