AGA/American Public Gas Association (APGA) Appeals Heard  at August 31 and September 3^rd International Code Council (ICC) Hearings.

As previously reported in End Use Codes and Standards Updates, AGA and APGA filed  joint appeals 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:

·                Potential violations of federal pre-emption of minimum efficiency standards for appliances and equipment, and

·                Setting of code requirements that are outside the boundaries of the “Intent” sections of the IECC.

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 appeals 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) was heard this past 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 was heard on September 3 and the AGA/APGA presentation is attached.   The Appeals Panel recommendations on both appeals have not been provided yet and we will provide you the decisions when available.   The Appeals Panel recommendations on all appealed items will then be sent to the ICC Board for a final decision.

AGA Prepares for California Rulemaking Indoor Air Quality (IAQ) Workshop.

At the request of a California AGA member, AGA staff has begun to prepare its participation in a workshop scheduled by the California Energy Commission (CEC) for September 21^st to cover gas combustion and indoor air quality effects.  The workshop is part of CEC’s review in updating the California state energy standard, “Building Energy Efficiency Standards – Title 24” for 2022 through its “pre-rulemaking” action (Docket Numbers 19-BSTD-03 and 19-BSTD-04).  At this time, the formal public announcement for the workshop is not available.  AGA members will advise Codes and Standards concerning its level of participation, either as a presenter or as a witness.  However, the nature of AGA testimony has been discussed and will focus on IAQ and gas cooking emissions issues from a national perspective primarily.  AGA’s review of 210 citations of IAQ health effects and combustion emissions from the Sierra Club/UCLA Field School of Public Heath report, “Effects of Residential Gas Appliances on Indoor and Outdoor Air Quality and Public Health in California” are likely to be included in AGA’s presentation as well.  More information on the workshop will be provided in an upcoming “Friday Update” as well as links for AGA member participation.

Industry Groups File Comments Opposing Electrification in California Title 24 Proceeding.

An ”Industry Coalition” of seven industry groups, including the California Building Industry Association (CBIA), California Business Properties Association, Building Owners and Managers Association (BOMA) of California, California Apartment Association (CAA), International Council of Shopping Centers, California Association of Realtors, the National Association for Industrial and Office Parks (NAIOP) of California, the Commercial Real Estate Development Association and the  Commercial Real Estate Development Association, filed comments (attached) on Wednesday on testimony at an August 12^th CEC “Business Meeting” in support of building electrification in its submission to Docket Number 19-BSTD-03.  The coalition’s filing challenge claims that an all-electric baseline for buildings in California, including:

• “California homes must go all-electric to meet climate goals
• Going all-electric makes housing cheaper to build
• All-electric homes are cheaper to operate
• Going all-electric speeds up housing construction
• Californian’s want all-electric homes – many jurisdictions have already adopted mandates
• Disadvantaged communities are negatively impacted by health issues associated with gas use.”

This broad-based coalition which did not include natural gas utility participation, provides the CEC rulemaking process with direct challenges to contentions that electrification policies in the California energy code are essential to meet its policy commitments and are beneficial to California consumers in general and in the long run. While this is a California code development, the response from the “Industry Coalition”  provides substantial responses that can helpful to address similar code development activities promoting “all electric” code requirements for the built environment.

State Codes Activity Update

[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 Activity Alerts

Recent Code Body Meetings

Bills with Recent Activity