BECS Staff  Plans Discussions of Hydrogen/Natural Gas Blends and Renewable Natural Gas (RNG) Appliance Testing with a Major U. S. Water Heater Manufacturer. 

In anticipation of the introduction of hydrogen/natural gas  bends and renewable natural gas (RNG) into natural gas distribution systems, the BECS Committee has been supporting evaluation testing of gas appliances with different gas supplies to help ensure appliances will operate correctly with the varies different gas supply bends.  As part of this effort, AGA BECS staff has had initial discussions with the A. O. Smith Corporation to schedule a review with the companies technical staff to go over a summary of AGA’s  recently-completed and planned testing of appliances on natural gas/hydrogen blends and anecdotal experiences of a major commercial food service equipment manufacturer with gases containing trace amounts of landfill gas constituents.  AGA will seek information on A. O. Smith’s plans and activities in appliance performance testing and in anticipation of common interests and efforts Identified, AGA would offer to work with A. O. Smith on future testing needs. The BECS Committee has always been supportive of working with gas appliance manufacturers to coordinate testing efforts that evaluate gas appliance operations with certain variations of natural gas supplies.

 

AGA to Provide Comments on Proposed Expanded Natural Gas/Hydrogen Appliance Testing. 

In a similar program regarding gas appliance testing noted above, the CSA Group is working with a consortium of Canadian interests to respond to their proposal for additional testing, which would extend coverage of residential appliance operability to “used” appliances and higher concentrations of hydrogen in natural gas/hydrogen blends. This proposed work, discussed in earlier “Friday Updates,” will build upon testing of Appliance Engineering, Inc. sponsored by CSA Group, AHRI, and AGA that address as-manufactured residential appliances operability on blends announced by several U. S. gas utilities as targets for “power-to-gas” initiatives.  That work is intended as “exploratory” and to inform the ANSI-recognized Z21/Z83 Technical Committee on additional testing or standards development going forward to address these gases.

 

In response to a request by Spire Inc., AGA’s Ted Williams has reviewed the DOE technical information supporting its final rule on commercial packaged boiler minimum efficiency standards to identify shortcomings in DOE’s life-cycle cost (LCC) justification for its proposed minimum efficiencies.  Based upon the Spire request and fundamental legal and analytical review work provided by its outside counsel, AGA’s review has focused upon DOE’s implementation of claimed “marginal energy prices” to account for potential costs savings from higher minimum efficiencies for covered products across the product category.  The review work supports Spire’s claims that the DOE justification of its proposed minimum efficiency standards lack “clear and convincing evidence” of consumer savings.  Ted reviewed the Technical Support Document (TSD) spreadsheet implementation of natural gas prices that claim to be based upon marginal natural gas prices but found that, beyond lack of transparency of the analysis, the data used by DOE for deriving energy prices was deficient for justifying their characterization as “marginal gas prices.”  Spire had already demonstrated that the DOE marginal gas prices for the State of Missouri, Spire’s historically principal operational jurisdiction, were inconsistent with actual Spire rates.  Spire Inc.  is a party along with the AHRI and APGA in contesting the final rule in federal court (see the May 22^nd, 2020 “Friday Update”).  AGA has filed as an intervenor in the court proceeding in support of the positions of Spire Inc, APGA and AHRI.  The subject rule is being challenged by Spire, Inc., AGA, and APGA as intervenors in a court case instigated by energy efficiency advocates successfully challenging DOE’s failure to promulgate a final rule regarding minimum efficiencies for commercial packaged boilers.

 

[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.]