San Francisco Fire Commission adopts administrative bulletins but holds new energy-storage rule after industry objections

The San Francisco Fire Commission on Dec. 14 adopted most of the department's 2022 administrative bulletins but temporarily removed Administrative Bulletin 5.12, a new interpretation addressing energy storage systems in R3 (residential) occupancies, after public comment from industry stakeholders.

Public commenters urged the commission not to adopt 5.12 as written. Janine Cotter, owner of the local installer Luminalt, said the proposal “cuts to the heart of what we do” and asked the commission to hold a summit with manufacturers, installers and code committees so the department could craft workable language. Tessa Sanchez, speaking for Tesla, said the bulletin “was not developed through a consensus or evidence backed process” and recommended tabling it, arguing clauses on aggregate quantities and equivalency requests could undermine established state code interpretations. Eric Schoonbert, director of engineering at Luminal Energy, echoed the request that the provisions now in 5.12 be pursued via the formal code-amendment process with stakeholder feedback.

Fire Marshal Ken Coughlin described the bulletins as department interpretations of the California and local fire code intended to clarify how the code applies in San Francisco’s dense, zero‑lot-line context. He said the most immediate purpose of the proposed 5.12 was to address a state fire marshal request for heat detection in garages where residential battery systems might be installed, and noted the bulletin also attempts to reflect a recent state interpretation on aggregate battery capacity. Coughlin told the commission he was willing to withdraw 5.12 temporarily and return with additional stakeholder engagement.

Vice President Nakaju moved that the commission adopt the administrative bulletins while removing Bulletin 5.12 for further review; President Feinstein seconded. The roll-call vote was unanimous. The commission adopted the 2022 administrative bulletins with Bulletin 5.12 held for a future hearing, which the fire marshal said he expects to schedule in January or February.

Why this matters: Administrative Bulletins guide how the Fire Department enforces the code; Bulletin 5.12 would affect how residential battery energy storage systems are permitted and inspected in San Francisco. Industry commenters said the language as drafted risks slowing deployments; the department said it will work with stakeholders to refine the interpretation before returning to the commission.

Next steps: The Fire Department will revise its approach to Administrative Bulletin 5.12 and convene additional stakeholder discussions before returning the item to the commission for further consideration.