We are planning  to host a 3 to 5 hour virtual BECS Committee meeting on Thursday, September 17^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. This will also provide the opportunity for members to ask questions, develop strategies, etc., 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.  Note that this is a change from the tentative September 9^th date previously listed that proved to be a conflict for a number of members. We will provide details  (agenda, time, call-in and program registration information, etc.) of the revised codes and standards program in the near future.

 

As previously reported in End Use 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.  The ICC Notice of Appeal Hearings is attached. Conducted virtually via Webex Event,  the AGA and APGA joint appeal on alleged violations of federal pre-emption has also been appealed by AHRI and National Association of Home Builders (NAHB). That appeal (AGA/APGA’s Presentation attached) will be heard this Monday, 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.   All written comments and request for participation are posted on the Notice of Appeal Hearings website.

For AGA’s internal Hydrogen Task Group, Codes and Standards staff presented a summary of ongoing, proposed, and planned technical work and gas quality policy analysis considerations associated with natural gas and hydrogen blends.  The summary is posted in the BECS Committee area of the AGA website under “Presentations.”  The summary, which will be discussed at the upcoming September 17^th meeting of the BECS Committee covers recently-completed “exploratory” testing of residential appliance operability on methane/hydrogen blends discussed in prior “Friday Updates,” planned testing on “used appliances” operability on more realistic natural gas/hydrogen blends, proposed accelerated testing of end use equipment materials and components to natural gas/hydrogen mixtures, analysis of gas interchangeability envelopes for hydrogen mixtures, and past literature review of hydrogen in end use equipment, safety, and hydrogen introduction planning covering work already completed up to Year 2005.

The California Title 24 update, to comprise the 2022 edition of the California Code, is currently receiving comments from a wide variety of stakeholder and are posted here.  The SoCalGas comments submitted last Friday, presented in three filings, cover technical analysis of indoor air quality arguments presented in written comments in response to a March 26, 2020 pre-rulemaking workshop, technical analysis of pre-rulemaking proposals for California 2022 Energy Code compliance metrics, and policy comments on the Energy Code compliance metrics approach.  Codes and Standards staff provided a detailed review of the indoor air quality arguments discussed in the first submission, focusing upon claims of electrification advocates attacking natural gas combustion used for cooking that the use of natural gas cooking appliances cause unacceptable indoor air quality.  Details of this review have been discussed in previous “Friday Updates.”  SoCalGas’s engagement in this rulemaking runs in parallel with its lawsuit covering CEC’s failure to comply with its agreement to meet provisions of the Natural Gas Act, discussed in the

August 7^th “Friday Update.”

In a stunning move this week, the ASHRAE SSPC 62.2 Committee voted to abandon work on Addendum “c” to Standard 62.2, which represented the consensus work of unvented heater industry and allied industry interests, the ASHRAE Standards Committee members, and opponents of unvented heaters to develop Standard requirements for heater sizing and features based upon maintaining adequate indoor air quality.  At the same time, the Committee announced measures to seek reconsideration of the long-dismissed Addendum “a” by the ASHRAE Board of Directors and the Standards Committee.  These two ASHRAE leadership bodies had acted to return Addendum “a” to SSPC 62.2 effectively terminating work on the document, which would have effectively banned unvented gas fired heaters.  AGA was one of three SSPC member organizations that voted in the negative to stop work on Addendum “c,” reasoning as follows:

“The ballot to withdraw or otherwise stop processing of Addendum ‘c’ lacked any proactive response to move forward with developing requirements for unvented combustion gas heaters.  Proactive measures might have included forwarding the analyses prepared by industry and SSPC members Sherman, Fairey, and Crawford to a responsible SSPC subcommittee such as Indoor Air Quality in order to resolve technical inconsistencies and arguments, but such possible additional actions were not included in the ballot.  Instead, the action was to simply stop processing Addendum ‘c,’ which is based upon the compromise alternative that a cross-interest working group including representatives from the Standards Committee, unvented combustion heater and allied industry interests, and opponents of unvented combustion heaters had developed.  The proponents of the ballot instead argued for the SSPC to challenge ASHRAE staff, Board, and Standards Committee decision making to reinstate action on the now long-dismissed Addendum ‘a,’ for which persistent technical and procedural arguments remain.  The net effect of this action (the halt of Addendum ‘c’ and the effort to reactivate Addendum ‘a’) will be to prolong development of requirements for unvented combustion gas heaters, which the proponents of the ballot would appear to oppose on its face.

In discussion of the ballot to suspend activity on Addendum ‘c,’ proponents of the ballot argued that neither the Board nor the Standards Committee offered explanations for it actions on Addendum ‘a.’  It had been established months ago that neither body had an obligation to provide explanations for their actions, leaving, by default, the obvious reason that the appellants arguments that failure of the SSPC to respond to negative public comments and other procedural errors were the reason for their final action on Addendum ‘a.’  To date, these procedural complaints stand, and the SSPC has not proposed any remedial action to resolve these errors in voiding the Addendum “c” compromise alternative. Colloquially, we are right back ‘in the soup.’”

Following distribution of these negative vote reasons, SSPC 62.2 will have an opportunity to reconsider its votes as well as include the votes of Committee members who did not vote during this week’s virtual meeting.  However, it is unlikely that the vote tally will reverse the outcome from this week’s meeting.

[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.]

 

Recent and Upcoming Activity Alerts

 

Recent and Upcoming Code Body Meetings

Bills with Recent Activity