The March 17, 2021 Federal Register Notice (attached) from the U.S. Department of Energy (DOE) is forecasting the representative average unit costs of five residential energy sources for the year 2021 pursuant to the Energy Policy and Conservation Act (Act). The five sources are electricity, natural gas, No. 2 heating oil, propane and kerosene. Below is the representative cost for the 5 sources in terms of Per Million BTU’s and in dollars:

 

Electricity ………………………..……………….$39.01 per million Btu or    13.31cents/kWh

Natural Gas ………………………..…………… $10.64 per million Btu or   $1.064/therm or $11.56/MCF

No. 2 Heating Oil ………………………..……. $19.73 per million Btu or   $2.71/gallon

Propane ………………………..………………….$19.21 per million Btu or   $1.75/gallon  

Kerosene ………………………..………………. $23.35 per million Btu or    $3.15/gallon  

 

These costs become effective on April 16, 2021  and are used in determining the estimated annual operating cost of appliances covered in the Federal Trade Commission appliance labeling rule. FTC Energy cost labels (yellow stickers) that are required on some appliances  use the representative energy cost to provide consumers information on the annual operating cost of the specific appliance.  Note that the estimated national average cost of electricity remains over 3.6 times more than the cost of natural gas and this natural gas cost advantage for consumers needs to be considered by proponents for “electrification” and natural gas bans in their continued push for electrification by not allowing or supporting removal of natural gas appliances from homes and businesses

In the January 15, 2021 BECS Committee Update on End Use Codes and Standards, we reported that “DOE Withdraws Onerous Proposed Residential Gas Furnace and Commercial Gas Minimum Efficiency Requirements”. The BECS Committee strongly supported this DOE action since it provided recognition that there should separate product classes for vented condensing and non-condensing type gas fired residential furnaces and commercial water heaters that would also be applicable for other types of residential and commercial vented gas appliances and equipment.  On Tuesday March 16, the Attorney Generals of  12 states and the city of New York  filed a petition yesterday in the 2^nd Circuit seeking review of DOE’s January 15, 2021 issuances regarding: 1) withdrawal of the then pending furnace rule (86 Fed. Reg. 3873); and final interpretive rule on the product classes (86 Fed. Reg. 4776).  Additional information from the New York state Attorney Generals website on the petition can be found here:  AGs of NY . AGA BECS staff will continue to monitor this activity and is prepared to respond to any DOE proposed changes to the DOE final rule on residential gas furnaces and gas commercial water heaters.

 

The AGA BECS Committee originated project to develop Standard 715 completed First Draft Technical Committee balloting closing in February and is now open for public comments, which are due May 11, 2021.  At this time, it is anticipated that the publication of the completed standards is May, 2022. As the Technical Committee work moves forward, Committee Inputs are being considered for the May 11^th deadline as well, and AGA staff is leading Task Group 1 of the Committee’s work for considering developing coordination of NFPA 715 with the National Fuel Gas Code (NFGC), NFPA 54/ANSI Z223.1, the latter of which AGA serves as the ANSI secretariat.  It is envisioned that this coordination will be implemented by adding references to the NFGC, but specific requirements for installation of combustible gas detectors will be within the Task Group’s scope.  Task Group proposals to implement these measures in the NFGC are due as Public Inputs to NFPA by June 1, 2021.  The AGA-led Task Group activity plans to implement meetings to discuss the Public Input approach no later than two weeks from today, March 19^th.  Separately, AGA staff is participating in Task Group 4, which is considering among various topics proposed changes to the detection threshold for combustible gas detectors (Chapter 9 of the draft) and detection systems (Chapter 5).  AGA is working with other AGA member utilities represented on the TC to develop a recommended approach for pursuing these changes along with correlated proposals to be submitted to the Underwriters Laboratories (UL) Standard 1484, which covers listing of combustible gas detection devices and design performance.

Proposals to NFPA 30A,”Code for Motor Fuel Dispensing Facilities and Repair Garages,” which covers repair garages for compressed natural gas (CNG) and liquefied natural gas (LNG) repair activities, is open to present new proposals for the 2024 edition through June 1, 2021.  In response, CSA Group is scheduling a Public Input Development Working Group meeting in the coming weeks, which will combine effort of the Canadian B401 Committee responsible for the Canadian “Maintenance Facilities Code” and members of the NGV America Maintenance Facilities Working Group to begin the task of drafting proposals for updating the NFPA 30A coverage.  The objective of this virtual Working Group meeting is to discuss proposals to NFPA 30A. 

In development of proposals to the 2021 edition of NFPA 30A, changes proposed by CSA Group and NGV America were based upon technical requirements promulgated in Standard B401-18, “Maintenance Facilities Code” for Canada in an effort to both tailor repair garage requirements for new and existing garages performing maintenance operations dedicated to NGV (CNG and LNG) fleets and mixed fuel (conventional as well as NGVs) fleets.  NFPA 30A, 2021 edition incorporates 15 of 16 Public Inputs based on B401 technical requirements proposed by CSA Group and NGV America.  The sixteenth Public Input covering electrical classification within 18 inches of the garage ceiling was not accepted.

 

For this Working Group meeting, it is anticipated that the following potential actions would be taken in developing Public Inputs:

 

·                Reconsideration of proposing changes in electrical classification (discussed above as Public Input 16) for the 2021 edition

 

·                Potential proposals based upon modifications to NGV coverage in B401, now published as B401.1.21, “Natural Gas Vehicle (NGV) Maintenance Facilities Code”

 

·                Potential proposals based upon new coverage under B401 for maintenance facilities covering propane-fueled vehicles, now published as B401.2.21, “Propane Vehicle Maintenance Facilities Code”

 

·                Other potential proposals for greater alignment with CSA Group standards activities, such as defueling operations and other active areas of standards development, and additional coverage of repair garages

 

·                Project experience that can be cited as a justification for Public Inputs, such as projects implementing B401 requirements (and if applicable NFPA 30A, 2021 edition requirements.)

 

·                Other issues and action items.

 

It is anticipated that outcomes of the Working Group meeting will be Public Input drafting assignments and deadlines for drafts.  Representatives from the broader AGA membership and in particular the AGA BECS Committee are invited to participate in this meeting or in final reviews of the generated Public Inputs.  Interested members should contact Ted Williams ([email protected]).

 

Following up on discussion of self-powered gas-fired heating appliance field testing and uninterruptible power supplies (UPS) in the March 12^th “Friday Update,” BECS staff  is soliciting AGA member interest in a webinar in the coming weeks to discuss UPS systems application to power gas-fired heating appliances as an emergency response measure for addressing outages such as those experience two weeks ago in the State of Texas.  UPS systems would not replace the concept of self-powered appliances since they would address only temporary power outages, “brown outs,” and rolling blackouts and not provide other benefits of self-powered appliances such as providing emergency power during sustained power outages or for other applications or opportunities such as optimizing use of power options during periods of high energy prices.  However, UPS systems scaled for powering gas-fired heating appliances could provide more cost-effected solutions and be optimized for the heating appliances power needs, providing another margin of reduced installed cost.  It is expected that designs for systems of this scale (reduced from whole-house UPS systems) are likely to be available on the market before the next heating season.  The webinar would discuss UPS design and sizing criteria for operating gas-fired heating systems (including space and water heating), operating hour targets, appliance integration, codes and standards traceability and approval requirements, and installation and servicing requirements.  AGA members interested in participation on the webinar should contact Ted Williams ([email protected]).

 

As discussed in the March 5^th “Friday Update,” AGA submitted comments to CEC on the Staff Workshop, “Randomized Trial Study to Determine the Impact of Gas Stove Interventions on Children with Asthma” held virtually on March 2, 2021.  Specific comments summarized in the March 5^th “Update” are provided in AGA’s comment letter available on the CEC Docket here.  Of particular interest may be the introductory points of biased considerations of childhood asthma studies and arguments and the use of these studies in presuming that replacement of gas-fired cooking products represents an “intervention” option for addressing childhood asthma while neglecting documented causes in the public health agency literature and practitioner recommendations.

 

 

AGA’s Ted Williams  joined the ASTM D22 full committee as a voting member in 2020.  However, with expanding interest in related subject matter such as measurement of combustion emissions from gas-fired appliances, membership in D22 subcommittees, specifically D22.05, “Indoor Air Quality,” is likely to be supportive of AGA emissions measurement activities such as gas-fired cooking appliance measurements for NO₂, carbonyl materials, particulate matter, and other combustion products.  Additionally, BECS staff involvement is likely to help advance standards development for specific measurement protocols and equipment not currently covered by other reference methods that have a regulatory status but lack ready applicability among field practitioners.  AGA’s current involvement in D22 is focused on development of validation protocols for field methane emission measurements in support of efforts to quantify natural gas leakage, mainly focusing on urban areas.

 

 

As discussed in prior “Friday Updates,” the subject March 17^th webinar covered two major projects sponsored by AHRI, including the appliance testing project cosponsored by CSA Group and AGA as well as AHRI.  Over 500 participants took part in the webinar audience.  Presenters was hosted by Xudong Wang, Vice President of Research at AHRI and Stephen Memory, Director of the Corporate Technology Center, A. O. Smith Corporation and included presentations from Dr. Paul Needly, Managing Director of Enertek International (U. K.) for the AHRI-funded project and Josip Novkovic, Program Manager for Fuels and Appliances for CSA Group and Ted Williams of AGA for the jointly funded appliance testing project. The slides for the introductory remarks and the presentations, as well as the full video of the webinar are available here.  Questions and comments on the webinar are invited and should be directed to the presenters.  Additionally, AHRI recorded questions taken from the audience during the webinar, and those will be address separately.