The International Codes Council (ICC) Announces Pre-Order Availability of the 2021 IECC while a Pro-Electrification Provision is Under  AGA/APGA Appeal.
As a reminder,  AGA, APGA, the National Association of Home Builders (NAHB) and several other organizations are appealing several Final Actions of ICC on the 2021 IECC.  Appeals are to be heard at the end of August and early September and additional information on the appeals and the schedule is attached.  However, AGA recently became aware of the following announcement from ICC regarding pre-ordering of the 2021 International Energy Conservation Code (IECC):
(Excerpt from ICC 2021 IECC Ordering Information)
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The IECC addresses energy efficiency on several fronts including cost savings, reduced energy usage, conservation of natural resources and the impact of energy usage on the environment. Key changes include:
IECC, Commercial
  • Extended requirements for envelope leakage testing and verification.
  • Structural and efficiency changes to Section C406 expand options.
  • New provisions for controlled receptacles, electric vehicles (EV) and requirements for EV-ready and EV-capable spaces, and metering.
  • Elimination of “mandatory” and “prescriptive” language with the addition of new required provisions tables in C407.
  • Increased lighting efficacy and decreased lighting power density requirements.
  • A Commercial Zero Code renewable appendix was approved.
Note that the highlighted “key change” indicates that the 2021 IECC, Commercial edition will include provisions for electric vehicle “EV-ready and EV-capable spaces”.  That  provision is the subject of the AGA/APGA appeal ( CE217)  that will be heard next month and it is troublesome that the promotional announcement is being touted as containing this provision. AGA staff is following up with the ICC staff expressing deep concern with the announcement that suggests that the provision has been included in the document prior to the appeal hearing  that is scheduled for September 3rd.  
The U.S. Department of Housing and Urban Development (HUD) has requested nominations for individuals to serve on the Manufactured Housing Consensus Committee (MHCC).  The MHCC makes recommendations on the HUD National Manufactured Housing Construction and Safety Standard that includes provisions for the installation of natural  gas appliances and components. Attached is the Federal Register that provides details of the committees activities and responsibilities. Note that HUD will accept nominations until August 31, 2020 and nominations must be submitted through this website . BECS Committee members interested in potentially participating in the MHCC and who would like to learn more about the requirements and duties of participants should not  hesitate to contact us.  
EIA Report Emphasizes Residential and Commercial Market Importance for U. S. Natural Gas Local Distribution Companies.
In a report issued last week covering EIA’s Natural Gas Annual Respondent Query System, the importance of residential and commercial customers to AGA member companies is highlighted over sales via “transported” volumes to industrial and electric power sector customers.  Eighty-six percent (86%) of industrial deliveries and 94% of electric power sector deliveries are directly from pipeline companies, bypassing AGA member company local distribution company (LDC) systems.  In contrast, almost all deliveries to the residential sector and 86% of “sales volumes” (i.e., custody transfers from LDC to residential customers) come from LDCs.  “Transportation volumes” to these customers constitute most of the remaining deliveries.  Overall, 90% of U. S. residential and commercial customer natural gas or approximately 22 billion cubic feet per date (Bcf/d) is delivered through LDC systems.  From a perspective of end use codes and standards, maintaining the efficacy of residential and commercial consumer sectors through reasonable and balanced opportunities for consumers to use natural gas represents a vital continuing need of AGA member companies.  The critical nature of these markets is illustrated in financial press coverage such as the “Bank of America Utilities 2Q20 Gas LNG Preview, which identified as “key takeaways” in its article, “LDC De-Rating:  De-Carbonization Risks Front and Center” emphasizing the potential impacts of de-carbonization goals [at this time, this Bank for America article appears to be available only to subscribers and Bank of America customers].
Southern California (SoCal) Gas Sues the California Energy Commission for Its Failure to Support Natural Gas End Use.
This week, media reports covered the lawsuit available here refer to the California’s 2013 action of the Natural Gas Act, requiring the California Energy Commission (CEC) to “identify strategies to maximize the benefits obtained from natural gas as an energy source.”  The lawsuit has been joined by Clean Energy Fuels Corporation, which is a major player in the California natural gas vehicle (NGV) movement.  The lawsuit contends that CEC has not made good on this requirement of the Natural Gas Act adoption and by not identifying “strategies and options to maximize to benefits of natural gas and renewable gas.”  Renewable gas, SoCal Gas’s preferred terminology referred to elsewhere as “renewable natural gas” or (RNG), represents a key strategic element of the company’s plans for its future in the California energy market.  In a separate lawsuit, the two companies (SoCal Gas and Clean Energy Fuels) are suing the California Air Resources Board (ARB) seeking to overturn California’s newly approved “advanced clean trucks” rule, which seeks to put 300,000 “zero-emission trucks” on California roads by 2035.  The emphasis upon zero-emission trucks puts natural gas-fueled trucks at a disadvantage.  Details on this California rule and this second lawsuit are available from NGV America.
Rocky Mountain Institute (RMI) Identifies New Area of “Research” in its Promotion of Electrification.
This week, RMI hosted a webinar on residential gas cooking and its arguments for eliminating gas cooking and transitioning to electric cooking. Codes and Standards participated in the webinar.  The cited information from RMI refer to its previously-published document, “Heath Effects From Gas Stove Pollution,” and did not provided much new information.  However, RMI announced that, in work with Harvard University’s T. H. Chan School of Public Health, it would be publishing results from the School’s anticipated peer-reviewed study of building combustion appliance emissions impacts on ambient (outdoor) air quality and its health effects.  The Harvard study is currently undergoing peer review and will be released in “two or three months,” according to the principal investigator, Dr. Jonathan Buonocore. Beyond the current study, Dr. Buonocore hopes to examine land use and other environmental impacts of natural gas use in future work.  This “new” emphasis on outdoor air quality demonstrates a return of RMI to its broader attack on natural gas use in favor of electrification and begins to put its work back into fuller context.  Having seen residential gas cooking emissions as a point of leverage against natural gas use, RMI appears to have determined to use its work to date in combination with increased public outreach and coalition building to make the indoor air quality case against natural gas. Going forward, Codes and Standards staff has identified two opportunities for AGA analysis and advocacy to respond to RMI and Dr. Buonocore:
·                Challenge RMI and Dr. Buonocore’s statements about economically-disadvantaged consumers by exposing the costs of converting from natural gas cooking to electricity, including electrical system costs, appliance replacement expenses, and higher energy costs.
·                Analyze the full fuel cycle emissions impacts of transitioning to 100% electricity for residential cooking use the readily-available federal data sources including U. S. Energy Information Administration (EIA) forecasts for grid electricity (instead of the RMI presumption of all-renewable electricity) and U. S. Department of Energy minimum efficiency estimates for full fuel cycle emissions and residential cooking product shipments.
These two analytically-based approaches are available for initiation prior to Dr. Buonocore’s peer-reviewed work is published and RMI’s potential development of related advocacy messaging.
Codes and Standards Meets with A. O. Smith Corporation to Discuss Water Heater Testing and Renewable Natural Gases (RNGs).
On Wednesday, BECS staff and A. O. Smith technical and policy staff discussed ongoing  gas appliance testing and means of addressing RNGs (including hydrogen-blended natural gas) in atmospheric and power burner appliances, principally residential gas water heaters.  The discussion focused upon definitions of various gases, to which BECS staff  provided background on ASTM D03 Committee “Gaseous Fuels” work on establishing stable consensus definitions for biogas, biomethane, and RNG.  Within the proposed RNG definition, ASTM is proposing criteria that relate to current terminology for describing “merchantable gases” recognized by the Federal Energy Regulatory Commission (FERC) and which are expected to expedite recognition of RNGs that have linkages to specific technical requirements.  BECS staff and A. O. Smith staff committed at the meeting to work together by sharing information in the near term including the following:
·                Providing A. O. Smith with a copy of Codes and Standard’s 2004 literature search and CD, “Hydrogen Literature Search:  1970-1995 – End Use Focus”
·                Providing BECS staff with background on University of California-Davis and European work on hydrogen systems and appliance designs
·                Providing A. O. Smith with the draft ASTM definition for RNG and background information on how the criteria within the definition can be used to evaluate gases for appliance use.
Since A. O. Smith is a member of the AHRI technical committee reviewing the CSA Group appliance testing involving natural gas/hydrogen blends and operability, exchange of information around that work is unnecessary.  AGA discussed its proposal to CSA Group on accelerated testing of critical appliance and equipment components for durability in response to molecular hydrogen, and while there was interest from A. O. Smith in this work, no specific actions were called for since the proposal is still under consideration.
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 Activity Alerts
Upcoming Code Body Meetings
Building Standards Commission
Fire Prevention & Building Safety Commission
Bills with Recent Activity
Bill #
Bill Title
Primary Sponsor(s)
Last Action
Last Action Date
SB 1371
Maintenance of codes
Andreas Borgeas (R) Maria Durazo (D) Lena Gonzalez (D) Brian Jones (R) Bill Monning (D) Henry Stern (D) Tom Umberg (D) Bob Wieckowski (D) Senate Committee on Judiciary
In Assembly; July 30 hearing postponed by committee
Summary: This bill would make non substantive changes in various provisions of law to effectuate the recommendations made by the Legislative Counsel to the Legislature.