Spire, Inc., American Public Gas Association (APGA) and AGA File Joint Comments on the DOE Request for Information (RFI) Pertaining to Energy Conservation Standards for Residential Water Heaters.
On Monday, Spire, Inc., the American Public Gas Association (APGA) and AGA filed joint comments (attached) on the DOE Request for Information (RFI) pertaining to Energy Conservation Standards for residential water heaters. The DOE notice initiated a data collection process to consider whether to amend DOE’s current energy conservation standards for residential water heaters. Specifically, the RFI solicited 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. A summary of the Spire Inc., APGA and AGA comments are as follows:
  • First, DOE should not adopt standards that would make atmospherically vented water heaters unavailable. Essentially the request is for separate product classes for non-condensing and condensing type gas water heaters.
  • Second, DOE should not simply assume that purchasers would decline to make economically beneficial efficiency investments in the absence of standards.
  • Third, DOE must recognize that it cannot determine the economic impact of standards for water heaters without developing a base case for analysis that reflects the impacts of actual purchasing behavior.
  • Fourth, DOE should stop using incorrect and significantly overstated energy prices for purposes of its LCC and payback analyses.
  • Fifth, DOE should collect and preferentially rely on real-world data, at least to confirm the validity of its analysis of product and installation costs.
Additionally, the Spire Inc., APGA and AGA joint comments provide specific responses to the questions raised by the DOE.  A special “shout out” to the Spire, Inc. staff who did the bulk of the drafting and development of the very detailed joint comments.  Note that a total of  13 comments were submitted on the RFI and can be found here and include comments from manufacturers, energy conservation and environmental groups. We will provide updates on the DOE actions and developments as they proceed on any potential modifications to the current minimum efficiency requirements that could negatively impact the availability of cost effective residential gas water heaters.
AGA BECS Staff Provides Recommendations for Comments on State of Minnesota Challenge of Renewable Natural Gas (RNG) Interconnection Tariff.
At the request from a member company operating in Minnesota, AGA’s Ted Williams provided draft recommendations for responding to public comments associated with indoor air quality (IAQ) submitted to the State docket associated with the proposed RNG interconnection tariff.  IAQ issues were just one of several major challenges posed for the RNG tariff.  Among familiar IAQ claims presented in other filings and public comments, the organization advocating against the tariff cited study results from a 2020 California Energy Commission sponsored study claiming potential DNA damage and mutagenicity effects from RNG from standard bench tests associated with DNA damage and mutagenicity, in this instance based upon exposures to emissions from the combustion of RNG.  AGA’s recommendations for response covered the study’s failure to take into account, for comparison purposes, displaced energy sources and emissions that would present their own risks in terms of DNA damage and mutagenicity potentials.  These would including electromagnetic fields (EMF) from substitution of gas-fired appliances to high-energy electric appliances (see the link), process-related emissions from cooking which include volatile organic compounds among other known carcinogens, combustion-related emissions resulting from upstream natural gas consumption for power generation, and combustion emissions from other carbon-based fuels at the point of use.  As a consequence, the comparison of natural gas and RNG in terms of DNA damage and mutagenicity potentials is decidedly narrow and presented without sufficient context to evaluate potential societal risk of alternatives.  As the statement filed in rate case point outs and as demonstrated in the cited report, findings with respect to even this limited comparison are tentative and require additional research. 
AGA Submits Proposed Webinar Presentation Coverage of Hydrogen and Natural Gas/Hydrogen Introduction Into Natural Gas Infrastructure.
At the request of CSA Group in support of a September webinar sponsored by Natural Resources Canada, BECS staff has submitted the scope of a proposed AGA presentation covering North American technical and policy issues associated with introducing natural gas/hydrogen blends and hydrogen as a fuel gas into the North American natural gas transmission and distribution infrastructure.  AGA participation was recommended by the Canadian Gas Association (CGA) based upon ongoing and planned end use appliance testing on natural gas/hydrogen blends, but the AGA presentation will only focus upon infrastructure issues.  The presentation will dovetail with recent CGA/AGA literature review of infrastructure issues, and CGA is expected to cover this work in its presentation on the webinar.  A principal focus of the AGA presentation would be on U. S. technical and policy issues and uncertainties.  While other North American activities to date have focused upon review of technical literature and other sources supporting introduction of natural gas/hydrogen blends and hydrogen fuel gas, this presentation would emphasize reported gaps in fundamental information relating to pipeline integrity, potential tariff and contractual barriers, gas interchangeability limits and unknowns, and potential issues of heterogeneous compositions in pipeline operations and custody transfer.  Research efforts to address these issues would be briefly summarized along with suggested strategies for moving forward for introducing these fuel gases.
AGA Staff to Present End Use Codes and Standards Overview at Next Week’s Southern Gas Association (SGA) Virtual Conference, “2020 Natural Gas Connect.”
At the invitation of SGA and Spire Inc., Ted Williams will present an overview of end use codes and standards issues and their critical contribution to the continuing direct use of natural gas at the SGA Virtual Conference, “2020 Natural Gas Connect” on Thursday, July, 16th.   In addition, Southern Company Gas and BECS Committee member Andrea Papageorge  will participate as the session host.  Details of the event are available here.  At the request of the sponsors, the AGA presentation will focus upon end use codes and standards basics for a general gas industry audience with some references to currently-active issues such as the AGA and American Public Gas Association (APGA) appeal 4 onerous provisions being considered for adoption in the 2021 International Energy Conservation Code (IECC).  In addition to the link provided above, individuals who are interested in participating in the event and wanting more detailed information on the event program should consider contacting Tom Schultz of Spire Inc., (Thomas.Schultz@spireenergy.com ) or Andrea Papageorge of Southern Company Gas (apapageo@southernco.com ).
AGA, Association of Home Appliance Manufacturers (AHAM), and Propane Education Research Council (PERC) Complete Memorandum of Understanding (MOU) for Information and Data Handling Associated to Gas-Fired Cooking Emissions Testing.
This week in an effort spearheaded by AGA’s Office of General Counsel, a MOU covering upcoming emissions testing of residential gas-fired cooking appliances was executed covering the handling of the testing program information among the three organizations anticipated to sponsor the testing and issues of program governance.  The MOU does not cover development of the testing program scope of work or other technical aspects of the program but establishes the working relationship of the three organizations.  With completion of the MOU, the three organizations have engaged in preliminary discussions of the technical program and are working out details for the establishment of a technical working group to organize the project and oversee its execution.  It is anticipated that organization of the technical working group will be completed in the next few weeks, where upon the finalization of a scope of work, solicitation of the primary testing organization, and other details of implementing the specific testing, will be undertaken.  With the addition of PERC and with support of the AHAM membership, the general boundaries of the testing program in terms of number of gas-fired appliances to be tested should be agreed to by the time of the first technical group meeting.  AGA anticipates that the technical working group will meet weekly until the testing program is set up and underway.
BECS Staff Begins Review of Appliance Engineering, Inc. (AEI) Technical Report on Appliance Testing Operation on Natural Gas/Hydrogen Mixtures.
Under its contract with CSA Group, the major sponsor of the testing program along with AHRI and AGA, AEI delivered its draft report on the testing and test results of natural gas/hydrogen appliance testing  for sponsor review.  AGA BECS staff will begin review of the draft report early next week.  In parallel and at the request of CSA Group, BECS staff is taking the lead in developing a summary report on the testing program.  As background, the BECS Committee requested the initial testing program and is a principal proponent of the testing program and AGA staff has essential background on the drivers behind initiatives to introduce natural gas/ hydrogen mixtures into North American natural gas systems.  As discussed in earlier “Friday Updates,” this program is exploratory in natural and not intended to produce definitive results regarding appliance compatibility with the natural gas/hydrogen mixtures tested (5% and 15% hydrogen by volume).  Instead, the reporting is intended to inform the ANSI-accredited Z21/Z83 Technical Committee on potential further testing or possible standards actions.  In parallel and with support of CSA Group, additional testing of older “used” appliances and their operational response to high concentrations of hydrogen in natural gas is being discussed.   The draft report review of AGA is expected to be completed by the end of next week and the drafting of CSA Group report completed in early August.
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 and Upcoming Activity Alerts
The purpose of this meeting is to discuss the adoption of the 2020 State Electrical Code. Public comments welcome. The Occupancy of the Board Room will be limited to 10 people with priority given to Committee members. This meeting will be available remotely via phone conference by dialing (571) 317-3122 and entering Access Code: 199-852-685.
Florida Fire Prevention Code Hearing
Hearing will include: RULE NO: 69A-3.012, RULE NO: 69A-60, 7th Edition FFPC NFPA 1 Florida Specific Amendments, and 7th Edition FFPC NFPA 101 Florida Specific Amendments
Recent and Upcoming Code Body Meetings
Fire Prevention & Building Safety Commission
Fire Prevention and Building Code Council
California Building Standards Commission
Bills with Recent Activity
Bill #
Bill Title
Primary Sponsor(s)
Last Action
Last Action Date
Community Affairs, Department of; consider amending the state minimum standard codes to allow tall mass timber construction types; direct
John Corbett (R) Jon Burns (R) Tom McCall (R) Terry England (R) Lynn Smith (R) Dominic LaRiccia (R) John Wilkinson (R)
Passed Senate; House Sent to Governor
Summary: This bill directs the Department of Community Affairs to review of the tall mass timber provisions of the 2021 International Building Code, approved by the International Code Council, for the purpose of considering whether the department, with the approval of the board, shall amend the Georgia state minimum standard codes to include provisions for tall mass timber as contained in the 2021 International Building Code for construction types IV-A, IV-B, and IV-C.
Relative to municipal authority regarding the state building code
Sharon Carson (R)
Sine Die – Failed; Vacated and Laid on Table MA VV 06/30/20
Summary: This bill requires the building code review board to review and approve local amendments to the state building code and requires the board to maintain and publish a catalog of local amendments. The bill requires the fire marshal to review and approve local fire safety codes and ordinances and requires the fire marshal, with the assistance of the board of fire control, to maintain and publish a catalog of local fire safety codes and ordinances. The bill also prohibits municipalities from imposing a fee to appeal the decision of a code compliance official.