AGA, APGA, NPGA, Spire Inc., Spire Missouri Inc., Spire Alabama Inc., and Atmos Energy File Topics for Consideration at the DOE  
September 6 Webinar on the Model Used to Justify the Proposed 95% AFUE Minimum Efficiency Requirement for  Consumer Furnaces.

 

In preparation to the DOE webinar on Tuesday, September 6, 2022, from 1:00p.m. to 3:00 p.m., this past week,  AGA, APGA, NPGA, Spire Inc., Spire Missouri Inc., Spire Alabama Inc., and Atmos Energy filed the attached, August 29^th request of a list of topics that we are requesting to be considered at the webinar and allocating adequate time for consideration for those topics.  The topics are designed to obtain additional information, identify errors that have come to light in the model and seeks clarification on the model that was used to justify the DOE proposal for a 95% AFUE for residential and manufactured home gas furnaces.

BECS Committee members are encouraged to register for the webinar.  Click here to register.  The  LCC Spreadsheet is available via the docket. Additional webinar registration information, participant instructions, and information about the capabilities available to webinar participants is published on DOE’s website: https://energy.gov/eere/buildings/public-meetings-and-comment-deadlines.

Please don’t hesitate to contact with us if you have any questions on the DOE proposed consumer furnace rulemaking.

 

Update on HUD Proposed Changes to the Manufactured Home (MH) Construction and Safety Standards including Proposals Impacting Natural Gas Applications.

In the July 21, 2022 Update on end Use Codes an Standards, we reported on the July 19^thHUD Federal Register Notice that is  proposing changes to the Federal Manufactured Home Construction and Safety Standards (the Construction and Safety Standards) requesting public comments by September 19, 2022.  The proposal is adopting the fourth and fifth group of recommendations made to HUD by the Manufactured Housing Consensus Committee (MHCC) and includes many changes that impact the installation of fuel gas into manufactured homes. These include updating the references for gas appliance standards and components that are permitted in newly built manufactured homes, references to the installation codes for MH’s including the National Fuel Gas Code (ANS 223.1/NFPA 54), interior fuel gas materials (steel, copper, CSST, etc.) and specific installation requirements, etc.  Even though there are proposals to update many of the reference standards and codes, they proposed references are still outdated when compared to current versions. AGA BECS staff reviewed the proposal and will provide recommendations on updating the outdated reference standards that are applicable for gas appliances and components. Our review did not uncover any other proposed revisions that would negatively impact natural has or propane applications. We have contacted both the Manufactured Housing Institute (MHI) and CSA International for feedback on the proposal but have not received a response at this time. We did not receive any comments from BECS committee members and unless we receive comments, will assume there is no concern with the proposal from the committee members.

On July 15^th, we reported that AGA, APGA and NPGA filed timely comments on the DOE RFI pertaining to energy conservation standards for miscellaneous gas products.  (See June 10, 2022 BECS Committee Update on End Use Codes and Standards).  Our joint comments questioned the DOE proposal  that would establish minimum efficiency requirements for the products listed in the RFI noting that they are neither “necessary” nor “appropriate” within the  provisions in the U.S. Code  ( 42 U.S.C. Section 6292(b)(1)(A)).  We also pointed out that  DOE  failed to provide sufficient explanation on how it intends to identify the exact products for which the RFI seeks to collect information to inform future rulemakings, as well as why (and how) the agency believes that it would be appropriate to regulate each of these products.”  Our joint comments also noted that comments on the DOE proposal are difficult for stakeholders to provide the department  with meaningful information on appliance feasibilities, market dynamics, or potential consumer behavior without a clear definition of the appliances subject by the department,  to the future rulemaking. We also objected to the DOE decision to reduce the comment period to 30 days that deviates  from the 75-day normal comment period and urged the DOE to implement the recommendations from the recent National Academies of Sciences, Engineering, and Medicine (“NASEM report”) into all steps of its rulemakings, whether for test procedures or energy conservation standards. Finally,  we urged DOE to hold a public meeting to help the agency constructively and efficiently provide clarity on its proposed actions with respect to these products and address stakeholder concerns. Unfortunately, on August 26, DOE issued a pre-publication Federal Register notice that  determined that miscellaneous gas products (MGPs), which are comprised of decorative hearths and outdoor heaters, qualify as covered products under Part A of Title III of the Energy Policy and Conservation Act, as amended (EPCA). DOE has determined that coverage of MGPs is necessary and appropriate to carry out the purposes of EPCA, and that the average U.S. household energy use for MGPs is likely to exceed 100 kilowatt-hours per year. This will result in DOE beginning the process of developing proposals for these gas products that will begin by identifying the specific products the department plans to initiate rulemakings. We will provide additional information on DOE’s activities as they begin.

For your information, the Hydrogen Heating Network’s inaugural live virtual conference, Hydrogen Heating: International Industry Perspectives, will be held September 20, 2022. The forum will share challenges and progress made to enable Hydrogen and Hydrogen blends, for use in homes and buildings to reduce greenhouse gas emissions. Registration is required (Hhn Registration).

Topics for discussion:

Please feel free to distribute the notice, attached, to those within your organizations involved with hydrogen blending.