Residential International Energy Conservation Code Public Review Closed.
The Public Review Period for the Residential International Energy Conservation Code closed on December 16, 2022. The Public Review Draft contained several new provisions that are not beneficial to the natural gas industry, including:
  1. Electric-Ready provisions in the base code. Along with electric-ready provisions, the draft of the base code included solar-ready and electric vehicle provisions. AGA submitted comments to move all these provisions to an optional appendix and not a mandatory part of the base code.
  2. All-Electric Adoptable Appendix. AGA submitted comments to delete this appendix in its entirety.
  3. Energy Efficiency Levels Above the Federal Minimum. AGA submitted comments stating that the code should not violate federal preemption by including efficiency levels that are above those specified by the Federal Government.
  4. Total Simulated Building Performance. AGA submitted comments objecting to different requirements for electric vs. gas-fired equipment. Additionally, AGA commented that all tables from ASHRAE 189.1, and not some, should be referenced in this section.
  5. AGA submitted comments on Pilot Light definitions suggesting that the definitions be in alignment with those in industry standard that is referenced in the Public Review draft.
  6. AGA submitted several editorial comments.
AGA’s comments have been uploaded to the AGA BECS community site, under the Library tab (International Energy Conservation Code – Residential folder).
 
IECC Residential Monograph for Public Comments and Code Changes to the IECC R Public Comment Draft #1 is now posted.
Supplementing the above report, yesterday, the IECC Code Change proponents were notified by ICC staff that  “the monograph of public comments/code changes to the Public Comment Draft #1 for the IECC-Residential, Chapter 11 of the IRC, and Chapter 15 of the ICC Performance Code is now posted on the IECC-R Committee website. Here is the link. Also attached is a spreadsheet indicating the initial assignment of code change proposals/comments to the IECC-R subcommittees. “ A total of 435 public comment were submitted, including AGA’s comments and a number from BECS Committee representatives.  Over the next month, all comments will be sent to various subcommittees of the Residential Consensus committee for review and recommendations that will be sent to the main committee for consideration.  ICC staff will contact commentors prior to the consensus meeting to make them aware that their proposal is on an upcoming agenda. If present, commentors will have the opportunity to speak on proposal(s) during the consensus meeting. Action on code change proposal/comment will require a 2/3 majority of the Consensus Committee. Results will be posted following the consensus meeting on energy.cdpaccess/live.  
 
Proposed Addendum aj To ASHRAE Standard 189.1 Would Favor Electric Applications – Comments Due January 30.  
Below is a Call for Comment on Standards Proposals from ASHRAE (American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc.)  on an Addenda BSR/ASHRAE/ICC/IES/USGBC Addendum aj to BSR/ASHRAE/ICC/IES/USGBC Standard 189.1-202x, Standard for the Design of High-Performance Green Buildings Except Low-Rise Residential Buildings (addenda to ANSI/ASHRAE/ICC/IES/USGBC Standard 189.1-2020). Addendum aj adds Section 7.5.2.2 as a jurisdictional option along with normative Appendix M. If adopted by an AHJ, this section would supplement Section 7.5.2.1 and allow the electricity greenhouse gas emissions of both the proposed design and the baseline building to be calculated using long-run marginal emission rates (LRMER). GHG emissions from direct use of fossil fuels and thermal energy in buildings would continue to be calculated using the procedures in Section 7.5.2.1.
The concern for the natural gas industry is that the use of Long-Run Marginal Emission Rate within codes and standards will make it more difficult for natural gas to compete with electric products for space, water heating, etc., applications since LRMER makes highly questionable assumptions about the improvements in the future electric grid that can’t be guaranteed will ever occur. In addition,  the proposal ignores any future decarbonization of the gas distribution system from renewable natural gas and hydrogen. Thus,  prediction of GHG emissions reductions for electric applications will favor electric installations over natural gas.  AGA BECS staff will be drafting a response to the proposal and BECS members are also requested to review the proposal for discussion at the upcoming January 11-12, 2023, BECS Committee meeting in San Diego. We will also be providing additional information on the LRMER greenhouse gas determination program particularly on the concerns with the assumptions used to determine GHG emissions.
 
Update on the CSA Group Position Statement on Hydrogen/Natural Gas Blending.
As reported in the December 9th Update , on November 22, the CSA Group issued a position memorandum, “Use of Hydrogen and Natural Gas Mixtures in Products Certified for Natural Gas in Canada and the US”, stating:
·       At present, there are no accepted standards in Canada or the US for fuel burning products using mixtures of natural gas and hydrogen, for either residential or industrial applications
·       In the absence of accepted standards, CSA Group does not currently offer certification programs for products and appliances that burn a mixture of natural gas and hydrogen
·       CSA Group’s current certification programs only apply to products that burn natural gas in accordance with existing accepted standards
·       CSA certification of a product is void when it is used outside the parameters of the applicable standards – which would include the use of fuels other than natural gas, such as a mixture of natural gas and hydrogen
The full memorandum can be read at: https://www.csagroup.org/article/use-of-hydrogen-and-natural-gas-mixtures-in-products-certified-for-natural-gas-in-canada-and-the-us/
 
On December 13, CSA Group held an industry forum to discuss the memo and options moving forward. The CSA Group has one working group under the auspices of the Joint Technical Committees for natural gas and propane appliances and accessories. Additionally, a new technical sub-committee is being formed to develop a stand-alone standard for testing appliances and accessories with hydrogen blends.
CSA provided four options to move forward:
1)    Develop a new standard to use as a companion standard to the appliance and accessories standards for testing with a hydrogen/natural gas blend.
2)    Develop an Interim Requirement (also known as TIL, ORD, or bench standard) that could be used in the interim while a new standard is developed, or existing standards are amended.
3)    Amend existing standards to include hydrogen/natural gas as an accepted test gas.
4)    Request an interpretation from the Joint Technical Committees to determine if the existing Test Gas B or C could be used as the hydrogen-blend to test appliances and accessories.
 
Currently, CSA Group has not determined a timeline to resolve the use of hydrogen blend in certified appliances and accessories. However, time is essential considering utilities in both the US and in Canada have initiated pilot programs, and jurisdictions in both countries are requesting utilities to implement these programs.
DOE Issues a Final Determination Not to Amend Standards for Commercial Warm Air Furnaces. 
Today, the U.S. Department of Energy (DOE) issued a Federal Register Notice with a final determination pertaining to energy conservation standards for commercial warm air furnaces (CWAFs). The Energy Policy and Conservation Act (EPCA), standards for various consumer products and certain commercial and industrial equipment, including CWAFs. EPCA also requires DOE to periodically review standards to determine whether more stringent, amended standards would be technologically feasible and economically justified, and would result in significant additional energy savings. In the case of CWAFs, DOE has determined that it lacks clear and convincing evidence that amended energy conservation standards would be economically justified. As such, in this final determination, DOE has determined not to amend the energy conservation standards for CWAFs. This Final Determination will be effective once the notice has been published in the Federal Register. DOE will send a follow-up e-mail once the notice publishes to announce the effective date. Find product information for Commercial Warm Air Furnaces including current standards and test procedures, statutory authority, waivers, exceptions and contact information.
 
State Codes Activity Update.
Attached 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. Please review the update and determine if there are state code activities that impact your service territory or organization.