AGA and the American Public Gas Association (APGA) Jointly File Appeal of ICC Actions on International Energy Conservation Code (IECC) Pro-Electrification Code Provisions.

AGA and APGA has filed a joint appeal addressing four code actions that presented two major issues, which AGA and APGA contend should have been prevented by 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 April 17, 2020 Codes and Standards Update provides additional details on the gas industries concerns with the four proposals.)  The joint appeal is directly associated with staff actions in the ICC process, which is a specific appealable class of routes to appeal presented in the ICC appeals procedures documented in ICC “CP1-03, Appeals.”  The appeal document is provided here on the AGA committee webpage for the BECS Committee. AGA’s and APGA’s members would be directly and materially affected by state or local adoption of the requirements of these proposals by disadvantaging the competitiveness of natural gas end use applications.  The associations are requesting that the provisions approved in the listed code change proposals above not be included in the next edition of the IECC based on the Associations’ contention that the ICC staff improperly processed-the four subject proposals.  From CP1-03, it is understood that ICC has 30 days to respond to the appeal, with a response coming from the ICC Appeals Board.  It is AGA’s understanding that other organization have filed appeals of the IECC validated actions on procedural grounds.
 
AGA Initiates Discussion with Association of Home Appliance Manufacturers (AHAM) on Emissions Testing of Residential Gas-Fired Cooking Appliances.
On a Thursday conference call with AHAM technical staff, AGA Codes and Standards staff discussed the background of the current electrification advocacy attack on residential gas-fired cooking appliances based upon concerns on combustion emissions and their alleged impacts upon indoor air quality (IAQ).  AGA had presented a draft work scope for appliance testing for emissions of carbon monoxide, nitrogen dioxide, particulate matter, and formaldehyde in combustion products from the normal operation of these appliances and coverage of these emissions in other studies cited by the electrification advocacy groups in public releases and regulatory filings in the State of California. The draft work scope identifies minimum requirements for instrumentation for measurements as well as targeted data presentations that could be used to compare results of these with other studies and to develop residential kitchen exposure estimates.  Technically-qualified and experienced contractors for consideration in a competitive request for proposals (RFP) were also discussed.  AHAM staff will meet with other staff today to discuss development of a testing program, currently proposed as a joint AGA/AHAM project, and potential expansion of the sponsorship program to other organizations. AHAM technical staff reported that following the Friday meeting, it will present the concept of the proposed testing program to the AHAM range membership for approval in the next week or two.
DOE Issues a Pre-Publication Request for Information Pertaining to Energy Conservation Standards for Residential Water Heaters.
Today, the U.S. Department of Energy (DOE)  issued a pre-publication Federal Register notice initiating a data collection process through this request for information (RFI), to consider whether to amend DOE’s current energy conservation standards for residential water heaters. This RFI solicits information to help DOE determine whether amended standards for consumer water heaters would result in significant energy savings and whether such standards would be technologically feasible and economically justified.
  • DOE will accept comments, data, and information regarding this RFI until 45 days after the notice has published in the Federal Register. DOE will send a follow-up email to announce the closing date once the notice has published.
  • Interested persons may submit comments identified by docket number EERE-2017-BT-STD-0019, by email (ConsumerWaterHeaters2017STD0019@ee.doe.gov), Federal eRulemaking portal (http://www.regulations.gov) postal mail, or hand delivery/courier.
The BECS Committee will be discussing the RFI at its upcoming meeting on May 12, 2020 to determine any action as deemed necessary.
Codes and Standards Participates in CSA Group Virtual Meeting to Kick Off Development of a North American Standards for Combined Heat and Power (CHP) Systems and Appliances.
On Thursday, CSA Group-Canada hosted the first meeting the technical subcommittee (TSC) of the ANSI-recognized Z21/Z83 consensus committee to develop a bi-national standard for CHP systems.  The BECS Committee is the originator of the standards project, discussed in prior “Friday Updates” to address the lack of standards for CHP systems and appliances, which present a major barrier to broad market adoption of CHP technologies in commercial and residential markets.  The kick-off meeting focused upon refining the standard project scope, chiefly in targeting the technologies and applications that the new standard would address.  Size ranges for CHP systems to be covered in terms of thermal and electrical capacities and sequencing of technology coverage remain as scope issues to be finalized.  The TSC will meet monthly to move the project forward.
 
Codes and Standards Presentation on ASHRAE COVID-19 Guidance for Buildings is Accepted for Presentation on June 11th in the Energy Solutions Center (ESC) “June Webathon.”
Codes and Standards staff had proposed presenting the ASHRAE guidance in following with its participation in review and comment of the ASHRAE Epidemic Task Force (ETF) and its recommendations for guidance approved by the ASHRAE Board of Directors.  The following description of the Codes and Standards presentation was submitted in its proposal to ESC on April 20th:
“In response to the COVID-19 pandemic, the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) formed an Epidemic Task Force (ETF) to develop guidance for operation of the range of building types to help reduce exposure to the virus for building occupants.  With respect to residential occupancies, debate centered upon measures reaching beyond the ASHRAE-wide call for increased building ventilation and measures that might produce unintended consequences with respect to general operability and life safety.  As ASHRAE consideration of virus transmission mitigation moves into development of standards requirements, such as within ASHRAE Standard 62.2, these issues will be debated again and feedback provide to ASHRAE leadership through the EFT.  The presentation summarizes the development of this experience and outstanding technical issues presented by potentially-overreaching guidance and requirements.”
Since the proposal was submitted, ASHRAE has continued to refine its guidance, and the Codes and Standards presentation is being revised to capture the latest guidance.  Information on ASHRAE guidance is available from the ASHRAE homepage:  www.ashrae.org.  Information on registration for the ESC June Webathon is available to ESC members.  Non-members should contact ESC to request participation.
 
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.]
 
Priority Activity Alerts
State
Date
Title
CO
4/30/2020
This guidance allows for the continuity of operations on critical infrastructure such as roads, rails, airports, housing (especially low-income housing), energy infrastructure and water infrastructure. The state urges any small scale construction projects (e.g. home renovations) to be reasonably deferred without penalty. For large scale and public investment, projects should be evaluated on a case by case basis, in light of the guidance below, related to the stay-at-home order
 
Recent Code Body Meetings
State
Body
Date
Address
Agenda
MA
Energy Advisory Committee Meeting
05/04/2020
Teleconference
IN
Fire Prevention & Building Safety Commission
05/06/2020
Teleconference
OK
Wagoner County Board of Commissioners
05/04/2020
307 E Cherokee St, Wagoner, OK 74467
CA
Zoning Administrator Commission
05/06/2020
Teleconference
CA
Planning Commission Meeting
05/07/2020
Teleconference
 
Bills with Recent Activity
State
Bill #
Bill Title
Primary Sponsor(s)
Last Action
Last Action Date
N/A
N/A
NO RECENT LEGISLATIVE ACTIVITY
N/A
N/A
N/A
Summary: N/A