FEMA’s proposed change would raise the structural risk category for solar energy to the maximum, resulting in increased structural requirements for ground-based solar energy and energy storage.

The proposed change The Federal Emergency Management Agency’s 2024 International Building Code S76-22 would require solar, storage and wind power projects to meet Risk Category 4 requirements, the strictest possible.

A total of 318 leading clean energy companies are urging voters at the International Code Council (ICC) to reject FEMA’s proposal for a code that would transform US clean energy progress and instead approve a set of compromise solutions. To read the text of the letter is here.

“The stated goal of FEMA’s proposal is to improve grid reliability, but when you make it unnecessarily difficult to build sustainable clean energy, the obvious effect is to reduce reliability,” said Abigail Ross Hopper, president and CEO of the Solar Energy Industries Association (SEIA). “This overuse occurs in a non-transparent process without input from experts on economic impact, power reliability and climate change. The U.S. solar and storage industry urges the voters of the International Code Council to consider the real-world impact of this code and approve SEIA’s compromise proposals.”

The compromise framework (S79-22 and S81-22) includes an important allocation for solar projects to be designated as Risk Category 2. According to SEIA, it balances a significant increase in structural requirements for solar installations with enough breathing space for project construction to move forward. FEMA officials themselves confirmed their support for the proposals put forward by SEIA and supported by the Distributed Wind Energy Association (DWEA), according to oral testimony on Sept. 15 and a voter guide that FEMA sent to voters on Oct. 13.

FEMA’s proposal calls for building clean energy projects to withstand devastating natural disasters far more than necessary. Most solar projects today are classified as Risk Category 1, and this proposal would move them to Risk Category 4, placing the burden of increased costs on project construction. SEIA said this harm to project economics would result in the cancellation of tens of gigawatts of clean energy projects, solar deployments, according to SEIA, thereby achieving the opposite of FEMA’s S76-22 proposal.

Some of the potential negative outcomes of the proposal include:

  • Higher embedded carbon and supply chain challenges due to increased demand for steel and concrete to reinforce damaged equipment
  • Compromise renewable energy portfolio standards and other decarbonisation targets
  • Efforts to create a clean energy economy to counter the causes of climate change have been thwarted

“FEMA’s proposal is well-intentioned but ill-considered” said Mike Bergy, president of DWEA. “It’s like saying VIP cars must be bulletproof and then requiring all cars to be bulletproof. Furthermore, FEMA is completely oblivious to the fact that the grid is its weakest link, and requiring more steel and concrete for solar and wind installations will not strengthen the grid.”

The voting period for ICC members runs from October 17 to November 1.

SEIA provides more details here.

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