Battery to GARAGE window distance

Z

Zee

Senior Member
Location
CA
Can I install a battery on the exterior of an exterior wall closer than 3 ft to a window and/or a door that enters the attached garage of a dwelling unit?

Per the 2021 Mid Code Cycle Amendments for Energy Storage Systems:

ESS on the exterior side of exterior walls shall be located not less than 3 feet from doors and windows directly entering the dwelling unit. [CRC R327.4]


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Yes, if the garage is fire separated compliantly. In my opinion at least.

Think of it this way: If I would be allowed to install the batteries in the space the window goes to, then I don't have to stay 3ft away from that window.
 
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Read this and follow the references carefully.
Note that if the locations are fire-separated from the dwelling part of the home then a window into that location does not 'directly' enter the dwelling.

CHAPTER 3 BUILDING PLANNING - 2022 CALIFORNIA RESIDENTIAL CODE, TITLE 24, PART 2.5 WITH JULY 2024 SUPPLEMENT

ICC Digital Codes is the largest provider of model codes, custom codes and standards used worldwide to construct safe, sustainable, affordable and resilient structures.
codes.iccsafe.org codes.iccsafe.org

So far I've had no rejections with this approach.

Also check out R328.8.1, they've gotten very specific about when bollards are required inside the garage.

This may be rather California specific (but I know that's where you are). Not sure how much of this is in the IRC.
 
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jaggedben said:
Read this and follow the references carefully.
Note that if the locations are fire-separated from the dwelling part of the home then a window into that location does not 'directly' enter the dwelling.

CHAPTER 3 BUILDING PLANNING - 2022 CALIFORNIA RESIDENTIAL CODE, TITLE 24, PART 2.5 WITH JULY 2024 SUPPLEMENT

ICC Digital Codes is the largest provider of model codes, custom codes and standards used worldwide to construct safe, sustainable, affordable and resilient structures.
codes.iccsafe.org codes.iccsafe.org

So far I've had no rejections with this approach.

Also check out R328.8.1, they've gotten very specific about when bollards are required inside the garage.

This may be rather California specific (but I know that's where you are). Not sure how much of this is in the IRC.
Click to expand...
Looking forward to the bollards being specified. In this case .... and often..... the garage door will have little side walls that frame the garage door so to speak which in essence should protect the equipment on the wall as long as these side walls jut out past the depth of the wall mounted equipment.
I'm wondering if your link will address it .....will take a look

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So, I have since gone ahead and installed 2 Enphase IQ5P batteries. I placed them on an exterior wall about a foot from a door and window that both open into the garage. This garage is attached to the dwelling unit.

The AHJ has fired back with this twice now:

1. ESS on the exterior side of exterior walls shall be located not less than 3 feet from doors and windows directly entering the dwelling unit. The attached garage is part of the dwelling unit therefore the code requiring the 3 feet from door and window is required. [CRC R328.4(3)]

Yes I know.
So are they telling me I can place the battery directly inside the garage itself - but not on the exterior of same garage?
Silly.
I am in awe.
:unsure:

What can I point to, so they understand this is non-sensical?

To be fair, the Code wording, "....doors and windows directly entering the dwelling unit." is not exact enough. Anyone reading this, that can influence Code language in the future, please take note.

It should say "....doors and windows directly entering the habitable spaces or otherwise not allowable spaces of the dwelling unit. "
 
A garage is not part of a dwelling unit, that's their first mistake. Think of all the dwelling units in apartment buildings that don't have garages.

CHAPTER 2 DEFINITIONS - 2022 CALIFORNIA RESIDENTIAL CODE, TITLE 24, PART 2.5 WITH JULY 2024 SUPPLEMENT

ICC Digital Codes is the largest provider of model codes, custom codes and standards used worldwide to construct safe, sustainable, affordable and resilient structures.
codes.iccsafe.org codes.iccsafe.org

Note the separate definition of Dwelling UNIT and its use in R328.4. The definition does not include garages or parking. If the garage can be fire separated from the dwelling unit (R302.6, as referenced in R328.4) then the garage is not part of the dwelling unit.

But yes, I think a nice move would be to tell them you propose to instead install the ess inside the garage in accordance with 328.4(2). (I assume the garage is fire separated, or can be made so.) Then ask them again how it makes sense that you can install inside the garage but not outside on the same wall. You are completely correct in that reasoning.

You want to do a lot of business in this jurisdiction? If so I would guess it's a fight worth fighting.
 
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Thanks.

Yes, this jurisdiction is my bread and butter.
Most houses have almost no allowable wall space for batteries, due to so many windows.
So garages (inside and outside) are usually our best or only option.

So this is crucial to resolve.
Going forward, it's all batteries all the time now.
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Yes, it's an all new remodeled garage and ADU with plenty of separation/fireproofing.
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Not that it matters per Code, but: it's on a stucco wall, and they are the safer LFP batteries.
I mean, what is the hazard?:unsure:
 
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I explained my reasoning and yours, and the AHJ's supervising PE agreed!

Good to know logic prevails.

Thank you for the help.

FWIW:
"Thank you for the thorough code analysis and logical assessment of the intent of the code and concerns under consideration. After review of your analysis, the ICC Code Commentary language, and a discussion amongst the plan check team we have determined that your conclusions are correct. We agree that the code allows for ESS to be installed adjacent to windows and doors into garages separated from dwelling unit living spaces in accordance with CRC R302.6 because the openings would not be directly entering the dwelling unit, and the fire protection would be addressed by the modified fire separation.
 
Congratulations on encountering an AHJ who is reasonable and who is able to change their stance without feeling like they are losing face. They are not all like that.
 
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