AGA Draft Responses to ASHRAE Proposed Addenda bi and bk to the ASHRAE 90.1 Energy Standard for Sites and Buildings Except Low-Rise Residential Buildings – Comments by Noon EST on Monday, January 27th Please

Back on January 3rd, we reported on 2 ASHRAE proposed Addenda bi and bk to the ASHRAE 90.1 Energy Standard for Sites and Buildings Except Low-Rise Residential Buildings that would if approved, negatively impact natural gas applications in commercial buildings covered by the ASHRAE 90.1 Energy Standard. The two addenda are identified as Addenda bi and Addenda bk.  Specific information and access to the addenda are provided below.   Addenda bi would change the compliance metric requirement from a cost basis to a site energy consumption basis that disregards the energy losses of electricity from generation to the end use. Addenda bk would require that compliance in the prescriptive path of the standard be based on space heating heat pumps as the primary system thus excluding federally approved natural gas heating systems (natural gas furnaces and boilers) as a primary system that is currently permitted in this compliance path. AGA has developed draft responses (attached) to both addenda pointing out technical and legal issues associated with both addenda and requesting that they both be disapproved.

Please review both draft responses and provide us with your feedback by noon EST on this Monday, January 27. We plan to submit our final comments by COB on Monday.

Below is Specific Information on and access to ASHRAE 90.1 Addenda bi and bk

ASHRAE Proposing Addenda to the ASHRAE 90.1 Standard for Public Review that Negatively Impact Natural Gas Applications – Comments Due January 27, 2025

ASHRAE has posted 2 addenda,  bi and bk (below),  to the 90.1 Energy Standard for Sites and Buildings Except Low-Rise Residential Buildings that if approved , would negatively impact the direct use of natural gas in commercial buildings.  The drafts can be reviewed at: http://osr.ashrae.org/.  Also attached are bi and bk for easy access. The public review runs for a 45-day period starting December 13, 2024, and ending January 27, 2025. They are provided as follows:

1st Public Review of BSR/ASHRAE/IES Addendum bi to ANSI/ASHRAE/IES Standard 90.1-2022, Energy Standard for Sites and Buildings Except Low-Rise Residential Buildings

Addendum bi replaces the metric for determining compliance with Appendix G from energy cost to site energy use.

AGA Concern – addenda would change the compliance metric requirement from a cost basis to a site energy consumption basis that disregards the energy losses of electricity from generation to the end use.

1st Public Review of BSR/ASHRAE/IES Addendum bk to ANSI/ASHRAE/IES Standard 90.1-2022, Energy Standard for Sites and Buildings Except Low-Rise Residential Buildings

Addendum bk establishes that compliance with Section 6.5 (prescriptive HVAC) and 6.3 (for the simplified HVAC approach) requires HVAC systems serving building areas with both heating and cooling to be “space heating heat pump primary” systems.

AGA Concern – Requires that compliance in the prescriptive path be based on space heating heat pumps as the primary system thus excluding federally approved natural gas heating systems as a primary system that is currently permitted in this compliance path.