CFC · California Fire Code

What are the commissioning requirements for ESS installations?

As a homeowner: before your battery storage system can be turned on, the installer must follow an approved commissioning plan, run acceptance tests, give the fire official a commissioning report, and hand you an operation & maintenance manual — these steps are required by the California Fire Code to ensure the system and its safety systems work properly.

Last reviewed: July 6, 2026

What the code requires — plain English

Commissioning is required for newly installed energy storage systems (ESS) and for existing ESS that are retrofitted, replaced, or returning to service. A written commissioning plan approved before commissioning must describe phases, tests, acceptance criteria, training, and a decommissioning plan; the ESS must undergo initial acceptance testing and a commissioning report must be submitted to the fire code official before final approval. See § 1207.2 and § 1207.2.1 for the full requirements.

The single most important rule: you must have an approved commissioning plan before placing an ESS into service, perform the tests in that plan (including initial acceptance testing), and provide the commissioning report to the fire code official prior to final approval. § 1207.2.1


Requirements in detail

Scope — what systems require commissioning

  • All newly installed ESS and existing ESS that have been retrofitted, replaced, or previously decommissioned and are returning to service must be commissioned prior to being placed in service. § 1207.2.1
  • Retrofits: systems that are retrofitted are explicitly required to be commissioned under § 1207.3.7.

What the commissioning plan must contain (high level)

The commissioning plan must be completed and approved before commissioning begins and include at least the items below (as listed in § 1207.2.1): personnel and phase descriptions, the specific equipment and tests, test conditions, owner’s project requirements and basis of design, verification of installed equipment, integrated testing of fire/safety systems, thermal management/ventilation testing, O&M documentation delivery, staff training, service qualifications, and a decommissioning plan. § 1207.2.1

Testing, acceptance, and documentation

  • Initial acceptance testing: The ESS shall be evaluated for proper operation per the manufacturer’s instructions and the approved commissioning plan prior to final approval. § 1207.2.1.1
  • Commissioning report: A report describing the commissioning results, including the initial acceptance testing results, must be provided to the fire code official prior to final inspection and approval and retained at an approved on‑site location. § 1207.2.1.2
  • Operation & maintenance manual: An O&M manual must be provided to the owner/operator before operation and include manufacturer manuals, service contact, maintenance/calibration info, setpoints, inspection schedule, and service record log. § 1207.2.2

Decision-relevant table

Decision item Requirement / value When it applies Code Reference
Commissioning required? Yes — new ESS and retrofits/returned-to-service ESS All such installations § 1207.2.1
Commissioning plan required on construction documents Must be included with permit submittal (construction documents list) Permit application / construction documents § 1207.1.5
Required plan elements Narrative phases/personnel; list of equipment & tests; test conditions; OPR & BOD; verification; integrated fire/safety tests; thermal/ventilation tests; O&M doc; training; service personnel identification; decommissioning plan Applies to commissioning plan content § 1207.2.1 (items 1–12)
Initial acceptance testing Evaluate for proper operation per manufacturer & commissioning plan before final approval During commissioning § 1207.2.1.1
Commissioning report submittal Provide results to fire code official prior to final inspection; keep on-site After commissioning / before final approval § 1207.2.1.2
Operation & Maintenance manual Must include manuals, service contact, diagrams, setpoints, inspection schedule, service log Before ESS placed in operation § 1207.2.2
Retrofits Commissioned per § 1207.2.1; documented in service log Whenever ESS is retrofitted § 1207.3.7
Exceptions for lead‑acid / Ni‑Cd Commissioning may not be required for systems under exclusive control of communications utilities operating at less than 50 VAC and 60 VDC (other limited exceptions apply) Telecom/utility limited cases § 1207.2.1 Exceptions

Exceptions & special cases

  • The code identifies specific exceptions for lead‑acid and nickel‑cadmium battery systems used by communications utilities and certain utility / substation control power systems — these may be exempt from the full commissioning requirement or may use industry practice/other regulations in lieu of § 1207.2.1, provided they meet the stated voltage thresholds (50 VAC, 60 VDC) and are under exclusive control as described. § 1207.2.1 Exceptions
  • Retrofits are treated as a commissioning trigger: a system that is retrofitted must be commissioned per § 1207.3.7 (even if only modules are replaced) unless specifically treated as a repair under the narrow provisions for like‑for‑like lead‑acid swaps.
  • Plans and construction documents must include the commissioning plan as part of the permit package per § 1207.1.5. Failing to include it can delay permit issuance.

Common mistakes

  • Assuming commissioning is optional for any commercial ESS — commissioning is required for new installations and most retrofits (§ 1207.2.1, § 1207.3.7).
  • Not including the commissioning plan in the construction documents submitted with the permit (required by § 1207.1.5).
  • Performing tests but not producing or submitting the commissioning report (the code requires that report be provided to the fire code official prior to final inspection) — § 1207.2.1.2.
  • Treating the O&M manual as optional; the code requires delivery of the operation and maintenance manual before operation (§ 1207.2.2).
  • Overlooking integrated testing with fire and safety systems — the plan must include integrated testing for all fire and safety systems (item 6 in § 1207.2.1).

Worked example — concrete scenario

Scenario: a commercial building installs a new 100 kWh lithium‑ion ESS inside a dedicated equipment room.

Step-by-step application of the code:

  1. Prepare a written commissioning plan and include it with your permit submittal (construction documents list requires a commissioning plan). The plan must describe phases, personnel, tests (e.g., battery charge/discharge, BMS alarms, fire detection interfaces), test conditions, OPR/Basis of Design, integrated fire/safety testing, thermal management testing, training and a decommissioning plan. § 1207.1.5 and § 1207.2.1.
  2. Obtain plan approval from the authority having jurisdiction (the plan must be approved prior to initiating commissioning). § 1207.2.1.
  3. Execute commissioning: perform initial acceptance testing per the manufacturer instructions and the approved plan — e.g., functional verification of BMS response to simulated faults, ventilation/thermal management performance at expected operating temperatures, and confirmation that fire detection signals are received by the building system. § 1207.2.1.1.
  4. Produce a commissioning report that documents all tests and results and deliver it to the fire code official prior to the final inspection/approval; keep a copy on‑site. § 1207.2.1.2.
  5. Provide the O&M manual to the owner/operator (include schematics, setpoints, maintenance schedule and service contact) and deliver staff training documented in the plan. § 1207.2.2.

If any retrofit occurs later (for example, replacing battery modules), the system must be re‑commissioned in accordance with § 1207.3.7.


Related provisions (CFC sections)

  • § 1207.2 — Commissioning, decommissioning, operation and maintenance (scope).
  • § 1207.2.1 — Commissioning: plan content, requirements and exceptions.
  • § 1207.2.1.1 — Initial acceptance testing requirement.
  • § 1207.2.1.2 — Commissioning report submittal and retention.
  • § 1207.2.2 — Operation and maintenance manual requirements.
  • § 1207.2.3 — Decommissioning (notification and decommissioning plan).
  • § 1207.1.5 — Construction documents: commissioning plan required with permit application.
  • § 1207.3.7 — Retrofitting: commissioning requirement when systems are retrofitted.

Code references

Grounded in the retrieved California Fire Code — click a citation to read the verbatim passage:

  • CFC § 1207.2.1.1 High relevance — show source text

    (Material based on NFPA 855 2023 Ed.)

    1207.2.1.1 Initial acceptance testing. During the commissioning process an ESS shall be evaluated for proper operation in accordance with the manufacturer’s instructions and the commissioning plan prior to final approval.

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    ENERGY SYSTEMS

    1207.2.1.2 Commissioning report. A report describing the results of the system commissioning, including the results of the initial acceptance testing required in Section 1207.2.1.1, shall be provided to the fire code official prior to final inspection and approval and maintained at an approved on-site location. (Material based on NFPA 855 2023 Ed.)

    1207.2.2 Operation and maintenance. An operation and maintenance manual shall be provided to both the ESS owner or their authorized agent and the ESS operator before the ESS is put into operation and shall include the following:

    1. Manufacturer’s operation manuals and maintenance manuals for the entire ESS, or for each component of the system requiring maintenance, that clearly identify the required routine maintenance actions.
    2. Name, address and phone number of a service agency that has been contracted to service the ESS and its associated safety systems.
    3. Maintenance and calibration information, including wiring diagrams, control drawings, schematics, system programming instructions and control sequence descriptions, for all energy storage control systems.
    4. Desired or field-determined control set points that are permanently recorded on control drawings at control devices or, for digital control systems, in system programming instructions.
    5. A schedule for inspecting and recalibrating all ESS controls.
    6. A service record log form that lists the schedule for all required servicing and maintenance actions and space for logging such actions that are completed over time and retained on-site.

    The ESS shall be operated and maintained in accordance with the manual and a copy of the manual shall be retained at an approved on-site location.

    1207.2.2.1 Ongoing inspection and testing. Systems that monitor and protect the ESS installation shall be inspected and tested in accordance with the manufacturer’s instructions and the operation and maintenance manual. Inspection and testing records shall be maintained in the operation and maintenance manual.

    1207.2.3 Decommissioning. The code official shall be notified prior to the decommissioning of an ESS. Decommissioning shall be performed in accordance with the decommissioning plan that includes the following:

    1. A narrative description of the activities to be accomplished for removing the ESS from service, and from the facility in which it is located.

    2. A listing of any contingencies for removing an intact operational ESS from service, and for removing an ESS from service that has been damaged by a fire or other event. (Material based on NFPA 855 2023 Ed.)

    1207.3 Equipment. ESS equipment shall be in accordance with Sections 1207.3.1 through 1207.3.9.

    1207.3.1 Energy storage system listings. ESS shall be listed in accordance with UL 9540.

  • CFC § 1207.2 High relevance — show source text

    1207.2 Commissioning, decommissioning, operation and maintenance. Commissioning, decommissioning, operation and maintenance shall be conducted in accordance with this section.

    1207.2.1 Commissioning. Commissioning of newly installed ESS and existing ESS that have been retrofitted, replaced or previously decommissioned and are returning to service shall be conducted prior to the ESS being placed in service in accordance with a commissioning plan that has been approved prior to initiating commissioning. The commissioning plan shall include the following:

    1. A narrative description of the activities that will be accomplished during each phase of commissioning, including the personnel intended to accomplish each of the activities.
    2. A listing of the specific ESS and associated components, controls and safety-related devices to be tested, a description of the tests to be performed and the functions to be tested.
    3. Conditions under which all testing will be performed, which are representative of the conditions during normal operation of the system.
    4. Documentation of the owner’s project requirements and the basis of design necessary to understand the installation and operation of the ESS.
    5. Verification that required equipment and systems are installed in accordance with the approved plans and specifications.
    6. Integrated testing for all fire and safety systems.
    7. Testing for any required thermal management, ventilation or exhaust systems associated with the ESS installation.
    8. Preparation and delivery of operation and maintenance documentation.
    9. Training of facility operating and maintenance staff.
    10. Identification and documentation of the requirements for maintaining system performance to meet the original design intent during the operation phase.
    11. Identification and documentation of personnel who are qualified to service, maintain and decommission the ESS, and respond to incidents involving the ESS, including documentation that such service has been contracted for./p>
    12. A decommissioning plan for removing the ESS from service, and from the facility in which it is located. The plan shall include details on providing a safe, orderly shutdown of energy storage and safety systems with notification to the code officials prior to the actual decommissioning of the system. The decommissioning plan shall include contingencies for removing an intact operational ESS from service, and for removing an ESS from service that has been damaged by a fire or other event.

    Exceptions:

    1. Commissioning shall not be required for lead-acid and nickel-cadmium battery systems at facilities under the exclusive control of communications utilities that comply with NFPA 76 and operate at less than 50 VAC and 60 VDC. A decommissioning plan shall be provided and maintained where required by the fire code official.
    2. Lead-acid and nickel-cadmium battery systems less than 50 VAC, 60 VDC that are in telecommunications facilities for installations of communications equipment under the exclusive control of communications utilities, and are located outdoors or in building spaces or walk-in units used exclusively for such installations that are in compliance with NFPA 76, shall be permitted to have a commissioning plan in compliance with recognized industry practices in lieu of complying with Section 1207.2.1.
    3. Lead-acid and nickel-cadmium battery systems that are used for DC power for control of substations and control or safe shutdown of generating stations under the exclusive control of the electric utilities, and are located in building spaces or walk-in units used exclusively for such installations, shall be permitted to have a commissioning plan in compliance with applicable governmental laws and regulations in lieu of developing a commissioning plan in accordance with Section 1207.2.1. (Material based on NFPA 855 2023 Ed.)
  • CFC § 12-10 High relevance — show source text

    Shall include vanadium, zinc-bromine, polysulfide-bromide and other flowing electrolyte-type technologies.
    c. Fifty gallons of lead-acid battery electrolyte shall be considered equivalent to 70 kWh.
    d. Covers nonelectrochemical technologies such as flywheel and thermal ESS.|

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    1207.1.4 Permits. Permits shall be obtained for ESS as follows:

    1. Construction permits shall be obtained for stationary ESS installations and for mobile ESS charging and storage installations covered by Section 1207.10.1. Permits shall be obtained in accordance with Section 105.6.6.
    2. Operational permits shall be obtained for stationary ESS installations and for mobile ESS deployment operations covered by Section 1207.10.3. Permits shall be obtained in accordance with Section 105.5.14.

    1207.1.4.1 Communication utilities. Operational permits shall not be required for lead-acid and nickel-cadmium battery systems at facilities under the exclusive control of communications utilities that comply with NFPA 76 and operate at less than 50 voltage alternating current (VAC) and 60 voltage direct current (VDC).

    1207.1.5 Construction documents. The following information shall be provided with the permit application:

    1. Location and layout diagram of the room or area in which the ESS is to be installed.
    2. Details on the hourly fire-resistance ratings of assemblies enclosing the ESS.
    3. The quantities and types of ESS to be installed.
    4. Manufacturer’s specifications, ratings and listings of each ESS.
    5. Description of energy (battery) management systems and their operation.
    6. Location and content of required signage.
    7. Details on fire suppression, smoke or fire detection, thermal management, ventilation, exhaust and deflagration venting systems, if provided.
    8. Support arrangement associated with the installation, including any required seismic restraint.
    9. A commissioning plan complying with Section 1207.2.1.
    10. A decommissioning plan complying with Section 1207.2.3.
    11. A fire safety and evacuation plan in accordance with Section 404.

    1207.1.5.1 Utilities applicability. Plans and specifications associated with ESS owned and operated by electric utilities as a component of the electric grid that are considered critical infrastructure documents in accordance with the provisions of the North American Electric Reliability Corporation and other applicable governmental laws and regulations shall be made available to the fire code official for viewing based on the requirements of the applicable governmental laws and regulations. (Material based on NFPA 855 2023 Ed.)

    1207.1.6 Hazard mitigation analysis. A failure modes and effects analysis (FMEA) or other approved hazard mitigation analysis shall be provided in accordance with Section 104.2.2 under any of the following conditions:

    1. Where ESS technologies not specifically identified in Table 1207.1.3 are provided.
    2. More than one ESS technology is provided in a single fire area where there is a potential for adverse interaction between technologies.
    3. Where allowed as a basis for increasing maximum allowable quantities. See Section 1207.5.2.
    4. Where required by the fire code official to address a potential hazard with an ESS installation that is not addressed by existing requirements.
  • CFC § 12-11 High relevance — show source text

    2025 CALIFORNIA FIRE CODE 12-11

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    ENERGY SYSTEMS

    1207.1.8 Fire remediation. Where a fire or other event has damaged the ESS and ignition or re-ignition of the ESS is possible, the system owner, agent or lessee shall take the following actions, at their expense, to mitigate the hazard or remove damaged equipment from the premises to a safe location.

    1207.1.8.1 Fire mitigation personnel. Where, in the opinion of the fire code official, it is essential for public safety that trained personnel be on-site to respond to possible ignition or re-ignition of a damaged ESS, the system owner, agent or lessee shall dispatch within 15 minutes one or more fire mitigation personnel to the premise, as required and approved, at their expense. These personnel shall remain on duty continuously after the fire department leaves the premise until the damaged energy storage equipment is removed from the premises, or earlier if the fire code official indicates the public safety hazard has been abated. (Material based on NFPA 855 2023 Ed.)

    1207.1.8.2 Duties. On-duty fire mitigation personnel shall have the following responsibilities:

    1. Keep a diligent watch for fires, obstructions to means of egress and other hazards.

    2. Immediately contact the fire department if their assistance is needed to mitigate any hazards or extinguish fires.

    3. Take prompt measures for remediation of hazards in accordance with the decommissioning plan per Section 1207.2.3.

    4. Take prompt measures to assist in the evacuation of the public from the structures. (Material based on NFPA 855 2023 Ed.)

    1207.2 Commissioning, decommissioning, operation and maintenance. Commissioning, decommissioning, operation and maintenance shall be conducted in accordance with this section.

    1207.2.1 Commissioning. Commissioning of newly installed ESS and existing ESS that have been retrofitted, replaced or previously decommissioned and are returning to service shall be conducted prior to the ESS being placed in service in accordance with a commissioning plan that has been approved prior to initiating commissioning. The commissioning plan shall include the following:

    1. A narrative description of the activities that will be accomplished during each phase of commissioning, including the personnel intended to accomplish each of the activities.
    2. A listing of the specific ESS and associated components, controls and safety-related devices to be tested, a description of the tests to be performed and the functions to be tested.
    3. Conditions under which all testing will be performed, which are representative of the conditions during normal operation of the system.
    4. Documentation of the owner’s project requirements and the basis of design necessary to understand the installation and operation of the ESS.
    5. Verification that required equipment and systems are installed in accordance with the approved plans and specifications.
    6. Integrated testing for all fire and safety systems.
    7. Testing for any required thermal management, ventilation or exhaust systems associated with the ESS installation.
    8. Preparation and delivery of operation and maintenance documentation.
    9. Training of facility operating and maintenance staff.
    10. Identification and documentation of the requirements for maintaining system performance to meet the original design intent during the operation phase.
    11. Identification and documentation of personnel who are qualified to service, maintain and decommission the ESS, and respond to incidents involving the ESS, including documentation that such service has been contracted for./p>
  • CFC § 1207.2.1. High relevance — show source text

    The quantities and types of ESS to be installed. 4. Manufacturer’s specifications, ratings and listings of each ESS. 5. Description of energy (battery) management systems and their operation. 6. Location and content of required signage. 7. Details on fire suppression, smoke or fire detection, thermal management, ventilation, exhaust and deflagration venting systems, if provided. 8. Support arrangement associated with the installation, including any required seismic restraint. 9. A commissioning plan complying with Section 1207.2.1. 10. A decommissioning plan complying with Section 1207.2.3. 11. A fire safety and evacuation plan in accordance with Section 404.

    1207.1.5.1 Utilities applicability. Plans and specifications associated with ESS owned and operated by electric utilities as a component of the electric grid that are considered critical infrastructure documents in accordance with the provisions of the North American Electric Reliability Corporation and other applicable governmental laws and regulations shall be made available to the fire code official for viewing based on the requirements of the applicable governmental laws and regulations. (Material based on NFPA 855 2023 Ed.)

    1207.1.6 Hazard mitigation analysis. A failure modes and effects analysis (FMEA) or other approved hazard mitigation analysis shall be provided in accordance with Section 104.2.2 under any of the following conditions:

    1. Where ESS technologies not specifically identified in Table 1207.1.3 are provided.
    2. More than one ESS technology is provided in a single fire area where there is a potential for adverse interaction between technologies.
    3. Where allowed as a basis for increasing maximum allowable quantities. See Section 1207.5.2.
    4. Where required by the fire code official to address a potential hazard with an ESS installation that is not addressed by existing requirements.

    1207.1.6.1 Fault condition. The hazard mitigation analysis shall evaluate the consequences of the following failure modes. Only single failure modes shall be considered.

    1. A thermal runaway condition in a single electrochemical ESS unit.

    2. A mechanical failure of a nonelectrochemical ESS unit.

    3. Failure of any battery (energy) management system or fire protection system within the ESS equipment that is not covered by the product listing failure mode effects analysis (FMEA).

    4. Failure of any required protection system external to the ESS, including but not limited to ventilation (HVAC), exhaust ventilation, smoke detection, fire detection, gas detection or fire suppression system. (Material based on NFPA 855 2023 Ed.)

    1207.1.6.2 Analysis approval. The fire code official is authorized to approve the hazardous mitigation analysis provided that the consequences of the hazard mitigation analysis demonstrate:

    1. Fires will be contained within unoccupied ESS rooms or areas for the minimum duration of the fire-resistance-rated separations identified in Section 1207.7.4.
    2. Fires involving the ESS will allow occupants or the general public to evacuate to a safe location. (Material based on NFPA 855 2023 Ed.)

    1207.1.6.3 Additional protection measures. Construction, equipment and systems that are required for the ESS to comply with the hazardous mitigation analysis, including but not limited to those specifically described in Section 1207, shall be installed, maintained and tested in accordance with nationally recognized standards and specified design parameters.

  • CFC § 1207.2.1. High relevance — show source text

    A decommissioning plan for removing the ESS from service, and from the facility in which it is located. The plan shall include details on providing a safe, orderly shutdown of energy storage and safety systems with notification to the code officials prior to the actual decommissioning of the system. The decommissioning plan shall include contingencies for removing an intact operational ESS from service, and for removing an ESS from service that has been damaged by a fire or other event.

    Exceptions:

    1. Commissioning shall not be required for lead-acid and nickel-cadmium battery systems at facilities under the exclusive control of communications utilities that comply with NFPA 76 and operate at less than 50 VAC and 60 VDC. A decommissioning plan shall be provided and maintained where required by the fire code official.
    2. Lead-acid and nickel-cadmium battery systems less than 50 VAC, 60 VDC that are in telecommunications facilities for installations of communications equipment under the exclusive control of communications utilities, and are located outdoors or in building spaces or walk-in units used exclusively for such installations that are in compliance with NFPA 76, shall be permitted to have a commissioning plan in compliance with recognized industry practices in lieu of complying with Section 1207.2.1.
    3. Lead-acid and nickel-cadmium battery systems that are used for DC power for control of substations and control or safe shutdown of generating stations under the exclusive control of the electric utilities, and are located in building spaces or walk-in units used exclusively for such installations, shall be permitted to have a commissioning plan in compliance with applicable governmental laws and regulations in lieu of developing a commissioning plan in accordance with Section 1207.2.1. (Material based on NFPA 855 2023 Ed.)

    1207.2.1.1 Initial acceptance testing. During the commissioning process an ESS shall be evaluated for proper operation in accordance with the manufacturer’s instructions and the commissioning plan prior to final approval.

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    1207.2.1.2 Commissioning report. A report describing the results of the system commissioning, including the results of the initial acceptance testing required in Section 1207.2.1.1, shall be provided to the fire code official prior to final inspection and approval and maintained at an approved on-site location. (Material based on NFPA 855 2023 Ed.)

    1207.2.2 Operation and maintenance. An operation and maintenance manual shall be provided to both the ESS owner or their authorized agent and the ESS operator before the ESS is put into operation and shall include the following:

    1. Manufacturer’s operation manuals and maintenance manuals for the entire ESS, or for each component of the system requiring maintenance, that clearly identify the required routine maintenance actions.
    2. Name, address and phone number of a service agency that has been contracted to service the ESS and its associated safety systems.
    3. Maintenance and calibration information, including wiring diagrams, control drawings, schematics, system programming instructions and control sequence descriptions, for all energy storage control systems.
    4. Desired or field-determined control set points that are permanently recorded on control drawings at control devices or, for digital control systems, in system programming instructions.
    5. A schedule for inspecting and recalibrating all ESS controls.
  • CFC § 1207.1.7. High relevance — show source text
    1. Clearances to buildings are permitted to be reduced to 3 feet (914 mm) where a weatherproof enclosure constructed of noncombustible materials is provided over the ESS, and it has been demonstrated that a fire within the enclosure will not ignite combustible materials outside the enclosure based on large-scale fire testing complying with Section 1207.1.7.

    1207.8.4 Exterior wall installations. ESS shall be permitted to be installed outdoors on exterior walls of buildings when all of the following conditions are met:

    1. The maximum energy capacity of individual ESS units shall not exceed 20 kWh.
    2. The ESS shall comply with applicable requirements in Section 1207.
    3. The ESS shall be installed in accordance with the manufacturer’s instructions and their listing.
    4. Individual ESS units shall be separated from each other by at least 3 feet (914 mm).
    5. The ESS shall be separated from doors, windows, operable openings into buildings or HVAC inlets by at least 5 feet (1524 mm).

    Exception: Where approved, smaller separation distances in Items 4 and 5 shall be permitted based on large-scale fire testing complying with Section 1207.1.7. (Material based on NFPA 855 2023 Ed.)

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    1207.9 Special installations. Rooftop and open parking garage ESS installations shall comply with Sections 1207.9.1 through 1207.9.6.

    TABLE 1207.9—SPECIAL ESS INSTALLATIONS Col2 Col3 Col4
    COMPLIANCE REQUIRED COMPLIANCE REQUIRED ROOFTOPSa OPEN PARKING GARAGESb
    Feature Section Section Section
    All ESS installations 1207.4 Yes Yes
    Clearance to exposures 1207.9.3 Yes Yes
    Fire suppression systems 1207.9.4 Yes Yes
    Maximum allowable quantities 1207.5.2 Yes Yes
    Maximum enclosure size 1207.5.6 Yes Yes
    Means of egress separation 1207.5.8 Yes Yes
    Open parking garage installations 1207.9.6 No Yes
    Rooftop installations 1207.9.5 Yes No
    Size and separation 1207.5.1 Yes Yes
    Smoke and automatic fire detection 1207.5.4 Yes Yes
    Technology-specific protection 1207.6 Yes Yes
    a. See Section 1207.9.1.
    b. See Section 1207.9.2.
    a. See Section 1207.9.1.
    b. See Section 1207.9.2.
    a. See Section 1207.9.1.
    b. See Section 1207.9.2.
    a. See Section 1207.9.1.
    b. See Section 1207.9.2.

    1207.9.1 Rooftop installations. For the purpose of Table 1207.9, rooftop ESS installations are those located on the roofs of buildings. (Material based on NFPA 855 2023 Ed.)

  • CFC § 1207.8.2 High relevance — show source text

    1207.8.2 Installations near exposures. For the purpose of Table 1207.8, installations near exposures include all outdoor ESS installations that do not comply with Section 1207.8.1 remote outdoor location requirements. (Material based on NFPA 855 2023 Ed.)

    1207.8.3 Clearance to exposures. ESS located outdoors shall be separated by a minimum of 10 feet (3048 mm) from the following exposures:

    1. Lot lines.

    2. Public ways.

    3. Buildings.

    4. Stored combustible materials.

    5. Hazardous materials.

    6. High-piled stock.

    7. Other exposure hazards.

    Exceptions: (Material based on NFPA 855 2023 Ed.)

    1. Clearances are permitted to be reduced to 3 feet (914 mm) where a 1-hour free-standing fire barrier suitable for exterior use and extending 5 feet (1524 mm) above and 5 feet (1524 mm) beyond the physical boundary of the ESS installation is provided to protect the exposure.

    2. Clearances to buildings are permitted to be reduced to 3 feet (914 mm) where noncombustible exterior walls with no openings or combustible overhangs are provided on the wall adjacent to the ESS and the fire-resistance rating of the exterior wall is a minimum of 2 hours.

    3. Clearances to buildings are permitted to be reduced to 3 feet (914 mm) where a weatherproof enclosure constructed of noncombustible materials is provided over the ESS, and it has been demonstrated that a fire within the enclosure will not ignite combustible materials outside the enclosure based on large-scale fire testing complying with Section 1207.1.7.

    1207.8.4 Exterior wall installations. ESS shall be permitted to be installed outdoors on exterior walls of buildings when all of the following conditions are met:

    1. The maximum energy capacity of individual ESS units shall not exceed 20 kWh.
    2. The ESS shall comply with applicable requirements in Section 1207.
    3. The ESS shall be installed in accordance with the manufacturer’s instructions and their listing.
    4. Individual ESS units shall be separated from each other by at least 3 feet (914 mm).
    5. The ESS shall be separated from doors, windows, operable openings into buildings or HVAC inlets by at least 5 feet (1524 mm).

    Exception: Where approved, smaller separation distances in Items 4 and 5 shall be permitted based on large-scale fire testing complying with Section 1207.1.7. (Material based on NFPA 855 2023 Ed.)

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    ENERGY SYSTEMS

    1207.9 Special installations. Rooftop and open parking garage ESS installations shall comply with Sections 1207.9.1 through 1207.9.6.

  • CFC § 1207.3.7 High relevance — show source text

    1207.3.7 Retrofits. Retrofitting of an existing ESS shall comply with the following:

    1. A construction permit shall be obtained in accordance with Section 105.6.6.
    2. New batteries, battery modules, capacitors and similar ESS components shall be listed.
    3. Battery management and other monitoring systems shall be connected and installed in accordance with the manufacturer’s instructions.

    2025 CALIFORNIA FIRE CODE 12-13

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    ENERGY SYSTEMS

    1. The overall installation shall continue to comply with UL 9540 listing requirements, where applicable.
    2. Systems that have been retrofitted shall be commissioned in accordance with Section 1207.2.1.
    3. Retrofits shall be documented in the service records log. (Material based on NFPA 855 2023 Ed.)

    1207.3.7.1 Retrofitting lead acid and nickel cadmium. Changing out or retrofitting of lead-acid and nickel-cadmium batteries with other lead-acid and nickel-cadmium batteries in the following applications shall be considered repairs where there is no increase in system size or energy capacity greater than 10 percent of the original design.

    1. At facilities under the exclusive control of communications utilities that comply with NFPA 76 and operate at less than 50 VAC and 60 VDC.

    2. Battery systems used for DC power for control of substations and control or safe shutdown of generating stations under the exclusive control of the electric utility, and located outdoors or in building spaces used exclusively for such installations.

    3. Batteries in uninterruptible power supplies listed and labeled in accordance with UL 1778 and used for standby power applications only.

    (Material based on NFPA 855 2023 Ed.)

    1207.3.8 Replacements. Replacements of ESS shall be considered new ESS installations and shall comply with the provisions of Section 1207 as applicable to new ESS. The ESS being replaced shall be decommissioned in accordance with Section 1207.2.3. (Material based on NFPA 855 2023 Ed.)

    1207.3.9 Reused and repurposed equipment. Equipment and materials shall only be reused or reinstalled as permitted in Section 104.9.1. Storage batteries previously used in other applications, such as electric vehicle propulsion, shall not be reused in applications regulated by Chapter 12 unless approved by the fire code official and unless the equipment is refurbished by a battery refurbishing company approved in accordance with UL 1974. (Material based on NFPA 855 2023 Ed.)

    1207.4 General installations requirements. Stationary and mobile ESS shall comply with the requirements of Sections 1207.4.1 through 1207.4.12.

    1207.4.1 Electrical disconnects. Where the ESS disconnecting means is not within sight of the main electrical service disconnecting means, placards or directories shall be installed at the location of the main electrical service disconnecting means indicating the location of stationary storage battery system disconnecting means in accordance with the California Electrical Code .

    Exception: Electrical disconnects for lead-acid and nickel-cadmium battery systems at facilities under the exclusive control of communications utilities and operating at less than 50 VAC and 60 VDC shall be permitted to have electrical disconnects signage in accordance with NFPA 76.

  • CFC § 304.8 High relevance — show source text

    a_| |In detached garages and detached accessory structures|200|| |In detached garages and detached accessory structures|600|Detached garage or detached accessory structure is
    a minimum 10 feet away from property lines and
    dwellings.| |Outdoors on the ground|200|ESS is a minimum 3 feet away from property lines
    and dwellings.| |Outdoors on the ground|600|ESS is a minimum 10 feet away from property lines
    and dwellings.| |For SI: 1 foot = 304.8 mm
    a. Noncombustible wall surface shall extend in accordance with all the following:
    1. A minimum of 5 feet horizontally from the edge of the ESS.
    2. A minimum of 1 foot vertically below the bottom edge of the ESS.
    3. A minimum of 8 feet vertically above the ESS, or to a noncombustible eave, whichever is less.
    The code official is authorized to approve reductions of installation requirements based on large-scale fire testing complying with Section 1207.1.5.|For SI: 1 foot = 304.8 mm
    a. Noncombustible wall surface shall extend in accordance with all the following:
    1. A minimum of 5 feet horizontally from the edge of the ESS.
    2. A minimum of 1 foot vertically below the bottom edge of the ESS.
    3. A minimum of 8 feet vertically above the ESS, or to a noncombustible eave, whichever is less.
    The code official is authorized to approve reductions of installation requirements based on large-scale fire testing complying with Section 1207.1.5.|For SI: 1 foot = 304.8 mm
    a. Noncombustible wall surface shall extend in accordance with all the following:
    1. A minimum of 5 feet horizontally from the edge of the ESS.
    2. A minimum of 1 foot vertically below the bottom edge of the ESS.
    3. A minimum of 8 feet vertically above the ESS, or to a noncombustible eave, whichever is less.
    The code official is authorized to approve reductions of installation requirements based on large-scale fire testing complying with Section 1207.1.5.|

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    ENERGY SYSTEMS

    1207.11.5 Electrical installation. ESS shall be installed in accordance with the California Electrical Code. Inverters shall be listed and labeled in accordance with UL 1741 or provided as part of the UL 9540 listing. Systems connected to the utility grid shall use inverters listed for utility interaction. (Material based on NFPA 855 2023 Ed.)

    1207.11.6 Fire detection. ESS installed in Group R-3 and R-4 occupancies shall comply with the following:

    1. Rooms and areas within dwelling units, sleeping units, basements and attached garages in which ESS are installed shall be protected by smoke alarms in accordance with Section 907.2.11.
    2. A listed heat alarm shall be installed in locations where smoke alarms cannot be installed based on their listing.
  • CFC § 3.3 High relevance — show source text
    1. Definitions section.

    3.3 Enforcement:

    At their discretion, the inspector confirms demonstrated compliance at Plan Intake by: a) Receipt of a copy of the commissioning specifications, or b) Receipt of a form signed by the owner or owner’s representative or designer of record attesting that the owner-approved commissioning specifications are included in the construction documents.

    Reference: 4 Commissioning plan

    CALGreen Section 5.410.2.3, Commissioning plan.

    4.1 Intent:

    The Commissioning Plan (Cx Plan) establishes the commissioning process guideline for the project and commissioning team’s level of effort by identifying the required Cx activities to ensure that the Owner’s Project Requirements (OPR) and the Basis of Design (BOD) are met. The Cx Plan also includes a commissioning schedule from design to occupancy.

    4.2 Compliance Method:

    Compliance is demonstrated by preparation of a project-specific Cx Plan that includes the elements listed in the code section above. The following gives guidance for developing the components of the commissioning plan:

    1. General project information - Provide project-identifying information including but not limited to the following: i. Project name, owner, location. ii. Building type, building area. iii. Project schedule. iv. Contact information of individual/company providing the commissioning services.

    2. Commissioning goals – Document the commissioning goals, including but not limited to: i. Meeting CALGreen code requirements for commissioning. ii. Meeting OPR and BOD requirements. iii. Carrying out requirements for commissioning activities as specified in plans and specifications.

    3. Systems to be commissioned – See BOD a. An explanation of the original design intent - Document the performance objectives and design intent for each system listed to be commissioned in a written narrative

          - Refer to the OPR and BOD documents
      

    b. Equipment and systems to be tested, including the extent of tests i. Provide a list of equipment and systems to be tested

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    COMPLIANCE FORMS, WORKSHEETS AND REFERENCE MATERIAL

    ii. Describe the range and extent of tests to be performed for each system component, and interface between systems c. Functions to be tested - Provide example functional test procedures to identify the level of testing detail required

           See (Section 5.410.2.4) FPT guidance for more information
    

    d. Conditions under which the test shall be performed - Identify the conditions under which the major operational system functions are to be tested, including: i. Normal operations and part-load operations. ii. Seasonal testing requirements. iii. Restart of equipment and systems after power loss. iv. System alarm confirmations. e. Measurable criteria for acceptable performance - Include measurable criteria for acceptable performance of each system to be tested 4. Commissioning team information - Provide a contact list for all commissioning team members, including but not limited to: i. Owner, owner’s representative. ii. Architect, engineers. iii. Designated commissioning representative. iv. General contractor, subcontractors and construction manager. 5. Commissioning process activities, schedules and responsibilities i. Establish prescribed commissioning process steps and activities to be accomplished by the Cx team throughout the design to occupancy. ii. For each phase of the work, define the roles and responsibilities for each member of the Cx team. iii.

  • CFC § 1207.8.1. High relevance — show source text

    See Section 1207.8.1.
    b. See Section 1207.8.2.
    c. Where approved by the fire code official, fire suppression systems are permitted to be omitted.
    d. In outdoor walk-in units, spacing is not required between ESS units and the walls of the enclosure.|a. See Section 1207.8.1.
    b. See Section 1207.8.2.
    c. Where approved by the fire code official, fire suppression systems are permitted to be omitted.
    d. In outdoor walk-in units, spacing is not required between ESS units and the walls of the enclosure.|a. See Section 1207.8.1.
    b. See Section 1207.8.2.
    c. Where approved by the fire code official, fire suppression systems are permitted to be omitted.
    d. In outdoor walk-in units, spacing is not required between ESS units and the walls of the enclosure.|a. See Section 1207.8.1.
    b. See Section 1207.8.2.
    c. Where approved by the fire code official, fire suppression systems are permitted to be omitted.
    d. In outdoor walk-in units, spacing is not required between ESS units and the walls of the enclosure.|

    1207.8.1 Remote outdoor installations. For the purpose of Table 1207.8, remote outdoor installations include ESS located more than 100 feet (30 480 mm) from buildings, lot lines, public ways, stored combustible materials, hazardous materials, high-piled stock and other exposure hazards. (Material based on NFPA 855 2023 Ed.)

    1207.8.2 Installations near exposures. For the purpose of Table 1207.8, installations near exposures include all outdoor ESS installations that do not comply with Section 1207.8.1 remote outdoor location requirements. (Material based on NFPA 855 2023 Ed.)

    1207.8.3 Clearance to exposures. ESS located outdoors shall be separated by a minimum of 10 feet (3048 mm) from the following exposures:

    1. Lot lines.

    2. Public ways.

    3. Buildings.

    4. Stored combustible materials.

    5. Hazardous materials.

    6. High-piled stock.

    7. Other exposure hazards.

    Exceptions: (Material based on NFPA 855 2023 Ed.)

    1. Clearances are permitted to be reduced to 3 feet (914 mm) where a 1-hour free-standing fire barrier suitable for exterior use and extending 5 feet (1524 mm) above and 5 feet (1524 mm) beyond the physical boundary of the ESS installation is provided to protect the exposure.

    2. Clearances to buildings are permitted to be reduced to 3 feet (914 mm) where noncombustible exterior walls with no openings or combustible overhangs are provided on the wall adjacent to the ESS and the fire-resistance rating of the exterior wall is a minimum of 2 hours.

    3. Clearances to buildings are permitted to be reduced to 3 feet (914 mm) where a weatherproof enclosure constructed of noncombustible materials is provided over the ESS, and it has been demonstrated that a fire within the enclosure will not ignite combustible materials outside the enclosure based on large-scale fire testing complying with Section 1207.1.7.

Frequently asked questions

Who must approve the commissioning plan before testing starts?

The commissioning plan must be approved by the authority having jurisdiction (plan approval is required prior to initiating commissioning) as required by § 1207.2.1.

Is a commissioning report required even for small residential ESS?

The code requires a commissioning report for systems subject to Chapter 12 ESS provisions; residential installations are governed by siting and sizing limits (see the Residential Code), but if covered by Chapter 12 commissioning triggers, a commissioning report is required per § 1207.2.1.2. Confirm applicability with the local fire code official.

Can I use manufacturer test certificates in place of a commissioning report?

Manufacturer test data can be part of the commissioning documentation, but the code requires a commissioning report describing the commissioning results (including initial acceptance testing) be provided to the fire code official prior to final approval — § 1207.2.1.2.

Are telecom lead‑acid battery systems always exempt from commissioning?

Not always. The code provides specific exceptions for lead‑acid and nickel‑cadmium systems under the exclusive control of communications utilities operating at less than 50 VAC and 60 VDC; those limited systems may not require the full commissioning treatment or may follow NFPA 76 / recognized industry practice as specified in § 1207.2.1.

If I retrofit only battery modules, do I still need to commission?

Yes — the code treats retrofits as requiring commissioning under § 1207.3.7, except in narrowly defined like‑for‑like repairs for certain lead‑acid applications.

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