With the ongoing travel restrictions on many BECS Committee members,  we have cancelled the next BECS Committee on site meeting that had been scheduled for September 10-11, 2020 in Salt Lake City. We are planning  to host a 3 to 5 hour webinar or similar program for the BECS Committee during that time period, tentatively scheduled for September 9^th  to continue to provide the BECS membership with updates on key, end use codes and standards issues, provide the opportunity for committee members to provide feedback and present priority items,  answer questions, develop strategies, etc.,  all to help ensure that the direct use of natural gas is not adversely impacted by end use codes and standards actions that would prohibit or limit natural gas applications in homes, businesses and transportation.  We will provide details  (Agenda, specific date, time, call-in or  program registration information, etc.) of the revised codes and standards program in the near future.

 

As previously reported in Codes and Standards Updates, AGA and APGA filed a joint appeal addressing four code actions that presented two major issues, which AGA and APGA contend should have been prevented to be published by the ICC staff during the Group B Code Development process:

The AGA and APGA appeals are seeking removal of specific proposed code provisions in the next edition (2022) of the International Energy  Conservation Code (IECC) that are detrimental to natural gas applications.  Yesterday, the ICC posted the official Notice of Appeal Hearings which is attached. Conducted virtually via Webex Event, the hearings will begin August 27, 2020. The  AGA and APGA joint appeal on potential violations of federal pre-emption has also been appealed by AHRI and National Association of Home Builders (NAHB). That appeal will be heard on August 31^st. The  AGA and APGA joint appeal on the provisions that we believe violated the intent of the IECC (requiring electrical hookups in the proximately of the water heater and furnace) and has also been appealed by the Leading Builders of America (LBA) and (NAHB). That appeal will be heard on September 3.   Note that the public can submit written comments and request participation on all of the appeals. For the first AGA/APGA appeal  written comments and request for participation is August 17 and for the second appeal is August 19. All written comments and request for participation will be posted on the Notice of Appeal Hearings website.

On Monday, BECS staff will participate in a meeting of the AHAM Engineering Committee to discuss planning for testing of  combustion emissions from residential gas ranges.  AGA and AHAM have been meeting weekly since May to discuss results of CSA Group testing of ranges for NO₂ emissions and future testing, but this will be the first interaction of AGA involving the AHAM membership.  AGA participation in the virtual meeting will focus on NO₂ emissions testing completed in the end of 2019 by CSA Group under AGA sponsorship and addressing issues in the developed data for ovens and testing quality assurance measurement for the NO₂ emissions testing to come.  Time permitting, testing for other emission products including CO, particulate matter, formaldehyde, and acrolein will also be discussed.  Following that discussion, technical consensus on the future testing will be shared with the Propane Education Research Council (PERC), which has expressed interest in participating in the testing program.  AGA has maintained communications with PERC since its interest was originally expressed in May.  The work plan for testing, originally drafted in May has been updated to cover additional products to be tested and emissions data to be gathered.  It is envisioned that the work plan will be finalized in August in advance of requesting proposals from qualified testing laboratories to perform the work.

 

Following concerns expressed regarding proposed limits for total sulfur for the draft ASTM D03 standard for NGV fuel quality, Ted Williams met with representatives from GTI, NGV America, and other groups to discuss compromise positions on maximum total sulfur concentrations (grains per 100 standard cubic feet –SCF–and parts per million by volume — ppmv) and technical requirements expressed by engine manufacturers versus interstate pipeline tariff allowance guidance provided in sources including AGA Report 4A.  Engine manufacturers have claimed that maximum total sulfur levels needed to be approximately one-tenth the tariff guidance recommendations and supporting data in order to maintain operation of ultra-low NO_x engine exhaust catalytic systems.  AGA staff has suggested a compromise  on total sulfur limits based upon the 2013 “Natural Gas Quality Management Manual” developed by the AGA Transmission Measurement Committee.  According to principal contributors to the Manual, Report 4A tariff maximums for total sulfur do not represent modern experience in gas transmission systems, even where excursions in total sulfur levels occur.  AGA member participation in the ASTM D03 discussions confirm this observation, supporting the case for the AGA proposal of a compromise.  Currently, manufacturers of ultra-low NO_x engines appear to support a total sulfur limit of 1 grain per 100 SCF  or 16 ppmv versus Report 4A guidance for between 20 and 40 grains (320 to 640 ppmv).  AGA will propose an upper bound of 2 grains, or 32 ppmv to account for normal excursions in total sulfur that might occur from pipeline gas variability.  Separately, Codes and Standards staff hosted a virtual meeting of the BECS Committee NGV Research Issues Task Force to discuss the issue of total sulfur and the divergence of Report 4A guidance from engine manufacturer claims.  We are following up on Task Force recommendations coming out of that meeting while it prepares a summary of the justification for the compromise position, which came about after the Task Force meeting.  Codes and Standards staff will briefly present the compromise offer at the NGV Technology and Development Committee next Tuesday but will follow up with a more detailed discussion of it at a soon-to-take-place Committee Gas Quality Working Group meeting.

 

Following up on AGA staff discussions with A. O. Smith, technical and policy staff from the water heater manufacturer will meet with Codes and Standards staff on Wednesday to discuss its appliance testing and AGA’s work in the area.  It is envisioned that the discussions will focus on renewable natural gas (RNG) testing covering natural gas/hydrogen blends and landfill gas.  BECS staff is supporting the testing of appliance operations on natural gas/hydrogen blends and has encountered issues claimed for burner operations on landfill gases.  It is expected that the meeting will clarify if the nature of A. O. Smith’s testing efforts goes beyond standards requirements  for safety certification performance testing.

 

In a July 21^st ruling, the Massachusetts Attorney General’s found that “…the Town [Brookline] cannot add an additional layer of regulation to the comprehensive scope of regulation in the State Building Code…no matter how well intentioned the Town’s action…” While this ruling would be limited to precedent it might establish in the Commonwealth of Massachusetts (and assuming it stands up to further legal challenge), it does present some options for challenging other bans in jurisdictions where minimum codes (including those based upon national model codes) are based upon established and potentially preemptive building code legal frameworks and procedures.  In those cases, new legislative protections for the direct use of natural gas may not be essential to turning back bans.  Codes and Standards staff continues to pay increased attention to state and local code adoption processes and engagement of AGA members there since increased gas utility involvement in these processes may have additional value in assisting state and local jurisdictional officials and interests in pushing back against non-procedural code efforts.  Other jurisdictional efforts might not be able capitalize on precedence as in the Massachusetts situation, but it would draw attention of established code interests toward resisting so-called “stretch code” actions that originate outside of the existing processes.

 

[This is a weekly feature of the “Friday Update” covering state code calendar activities as presented by the online utility “Fiscal Note,” which is sponsored by APGA and AGA Code and Standards.]