Gas Industry Response to the September 24th DOE Request for Comments on Its Proposed “Interpretive Rule” on Product Classes and Consumer Utility.
As reported in the September 25, 2020  “Update on End Use Codes and Standards”, DOE’s Office of Energy Efficiency and Renewable Energy (EERE) issued a “Supplemental Proposed Interpretive Rule” requesting comments on its July 11, 2019 “Notice of Interpretive Rule” in which it granted a gas industry petition provision requesting an interpretive rule on whether venting systems for various product categories of gas-fired appliance represent consumer “features” and unique product utility.  The petition, discussed in a November 1, 2018 notice of the petition, was authored by American Public Gas Association, Spire, Inc., the Natural Gas Supply Association, AGA, and the National Propane Gas Association, sought the DOE interpretation on whether loss of such features would constitute a loss of consumer features and utility, which would be unlawful under the Energy Policy and Conservation Act, Sections 6295 and 6313.  The September 24, 2020  Supplemental Notice again requested comments, providing only additional background and discussion of comments DOE received and considerations effecting how DOE might pursue rulemaking on gas furnaces and water heaters.  In the notice, DOE suggested pursuing a broader approach to addressing venting “alternatives” across combustion appliances and equipment in light of its interpretative rulemaking, but it provided no proposals for specific appliances and equipment or for how venting systems would be addressed. 
On Monday, AGA, the American Public Gas Association (AGA), Spire Inc., the National Propane Gas Association (NPGA), the Natural Gas Supply Association (NGSA), the National Association of Home Builders (NAHB), and the Plumbing-Heating-Cooling Contractors – National Association (PHCC) filed timely joint comments (attached) on the DOE Notice of supplemental proposed interpretive rule; Request for Comment requesting:  1. Withdraw of the proposed rules for furnaces issued in 2015 (Fed. Reg. 13120, March 12, 2015 Docket No. EERE–2014–BT–STD–0031–0032) and Commercial gas water heaters (Fed. Reg. 34440 May 31, 2016 Docket No. EERE–2014–BT–STD–0042) based on the fact that these proposals would eliminate some types of gas appliances from the market that the law does not permit to happen and 2. Finalizing the initial DOE proposed finding that separate product classes for non-condensing and condensing type gas-fired  furnaces, commercial waters and other types of vented gas appliances and equipment be issued.
We will provide the DOE response to the comments when available.
Canadian Gas Association (CGA) Joins Jointly Sponsored Residential Cooking Appliance Emissions Testing Program.
Late last week, CGA agreed to join the testing program to be sponsored by AHAM, PERC, and AGA to test combustion emissions of carbon monoxide (CO), nitrogen dioxide (NO2), particulate matter, formaldehyde, and acrolein from gas cooking appliances.  At the request of CGA and with agreement of AHAM and AGA, test planning is being revised to include additional combustion performance tests operating on blends of natural gas and 15% hydrogen by volume.  With these additional changes to the testing program and needs to revise bids for the work on this modified scope, it is now envisioned that testing will begin in December.  The addition of CGA to the sponsorship of the testing program will extend the “reach” of the program technically and to Canadian involvement in appliance testing.  First order emissions testing on natural gas/hydrogen blends have been addressed in a separate exploratory program sponsored by CSA Group, AHRI, and AGA, although that program did not include cooking appliances or the more extensive focus on combustion emissions that this program will include.
AGA Sponsors an Initial Modeling Study of Potential Residential Occupant Exposures to Emissions from Residential Natural Gas Cooking Appliances.
This week, AGA signed a contract with the consultancy NORESCO, Boulder, CO to develop and execute a “phase 1” two-chamber residential indoor air quality (IAQ) model to estimate potential occupant exposures to combustion emissions from residential natural gas ranges and using the CONTAM modeling platform developed and supported by the National Institute of Standards and Technology (NIST).  CONTAM is a widely applied and validated modeling platform for IAQ modeling, taking into account air change rates, chemical reactivity, and transport of source emissions to calculate pollutant concentration development over time from steady state and transient sources to approximate occupant exposures.  The phase 1 activity will use NO2 data developed by CSA Group under AGA sponsorship as the emission source rates to set up the modeling for future concentration calculations using the jointly sponsored residential cooking appliance emissions testing program under a “phase 2” modeling program.  Modeling under phase 1 will start in December and be completed in fourteen weeks.  Phase 2 modeling, to be contracted separately, will begin after data from the jointly sponsored testing program is taken and validated for modeling use.
AGA to Sponsor a Meeting to Discuss Outcomes of the NFPA 715 Standard, “Standard for the Installation of Fuel Gases Detection and Warning Equipment,” First Draft Meeting.
The First Draft meeting of the NFPA 715 Technical Committee, begun this week and now carrying into next week, is producing a number for notable changes in the Draft via Public Inputs received and Technical Committee responses.  AGA staff, members, and allied organizations are represented on the NFPA 715 Technical Committee and participated in the First Draft meeting deliberations.  AGA will invite members of the AGA BECS Committee and allied organization representatives to participate in the meeting once the Public Input meeting results are completed and approved for discussion. It is anticipated that this meeting will take place in December, given the extension of the First Draft meeting into next week and the upcoming Thanksgiving Holiday week.
AGA Monitors “US Asthma Summit 2020” for Concerns Over Natural Gas Combustion.
On Friday, AGA’s Ted Williams participated in the Summit, which was sponsored by the Allergy & Asthma Network, the American College of Allergy, Asthma & Immunology, and a number of major pharmaceutical and health care industry interests.  The four-hour Summit had over 1,500 registrants and topics discussed included racial disparity and societal inequities associated with asthma development and exacerbation, strategies for control of asthma and asthma-related outcomes in term of prevalence, impacts, and consequences, the six-step EXHALE set of strategies of the Centers for Disease Control (CDC) for reducing asthma attack frequency and severity, patient and practitioner response to asthma triggers, asthma education content and qualification, interactions of COVID-19 subjects with asthma triggers and other environmental factors, extension asthma mitigation measures to COPD and other respiratory ailments.  A clear theme of the Summit was that the asthma community has moved forward into response and education and not expansion into identification of new asthma triggers and environmental factors. While indoor environmental factors were referred to, in no presentations or discussions were natural gas combustion sources mentioned as causes of asthma development or asthma exacerbation.  This focus is consistent with other national asthma event discussions over the past year, illustrating that current claims presented by electrification advocates and their allies are outside the mainstream of public health efforts addressing asthma.
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
Persons wishing to be considered for a position on a Code Advisory Committee (CAC), must submit an application and supporting documents by: December 4, 2020.
The 2020 Minnesota Statutes have been published; RE: CHAPTER 326B. CONSTRUCTION CODES AND LICENSING.
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