The International Code Council (ICC) has announced its call for committees for the development of its 2024 International Energy Conservation Code (IECC). Under the Code Council’s new framework, Leading the Way to Energy Efficiency: A Path Forward on Energy and Sustainability to Confront a Changing Climate, the IECC will be developed by the combined efforts of a Residential Energy Code Consensus Committee and a Commercial Energy Code Consensus Committee. The March 19, 2021 Press Release can be found here and includes information on how to apply for membership. AGA BECS staff will be applying for membership and we encourage BECS Committee members to consider applying to help ensure that the natural gas distribution industry is well represented on these very important code development committees that are charged to develop residential and commercial building codes that impact  the direct use of natural gas in the built environment.

Background on adoption of Addendum “a” and its effective banning of unvented gas-fired space heaters has been discussed in several prior “Friday Updates” over the course of this ASHRAE standards action, in which the Addendum was initially disapproved for publication by the ASHRAE Board of Directors and subsequently “reaffirmed” by SSPC 62.2 for Board reconsideration.  While AGA is not an appellant on the second submission of Addendum “a,” it was invited to participate as a “spokesperson” on behalf of the appellant representatives from the Vent-Free Gas Products Alliance of AHRI and the chair of the ANSI-recognized Z21.11.2 standard subcommittee responsible for that standard, “Gas-fired room heaters, volume II, unvented room heaters.”  In the first session as a spokesperson, AGA testimony outlined failures of SSPC 62.2 to formulate and modify Addendum “a” using regular standards development procedures such as consideration and review of technical justification from a cognizant technical subcommittee (Addendum “a” was never addressed by a technical subcommittee) and shortcuts taken by SSPC 62.2 to reintroduce Addendum “a” when an ASHRAE Standards Committee-recommended consensus alternative approach (the draft of which is known as Addendum “c”) was under consideration. 

 

In the second session, AGA focused on procedural issues with the SSPC 62.2 “reaffirmation” of Addendum “a.”  ASHRAE has no procedures for “reaffirmation” of the standards action that is terminated by a Board of Directors vote.  AGA’s procedural arguments focused on two points.  First, SSPC 62.2 as a body, through individual members of the SSPC, or by other parties did not appeal the Board’s action as ASHRAE procedures clearly allow, thus not making use of a basic procedural opportunity to keep Addendum “a” alive for consideration.  Second, no ASHRAE procedures cover return of standards actions terminated by a Board vote, resulting (as required by ASHRAE procedures) to apply Robert’s Rules of Order to govern SSPC actions.  Under Robert’s Rules, action on Addendum “a,” having been picked up again by the SSPC, must be handled either as “new business” or “old business” of the SSPC.  New business categorization of Addendum “a” would require the SSPC to reinstate formal standards actions procedures and voting to move it forward.  However, SSPC deliberately decided that no formal standards action was required on Addendum “a.”  Old business categorization would require a formal “motion to reconsider” Addendum “a”, discussion of that motion, and voting on the motion.  A motion to reconsider was not offered to move Addendum “a,” only a non-procedural online “reaffirmation” vote to send the Addendum back through the standards development process and to the Board.  Rebuttal testimony from SSPC 62.2 leadership did not address this second point in its response to the Appeals Board.  AGA’s conclusion is that in any case, SSPC 62.2 did not apply due process and administration of ASHRAE procedures in processing Addendum “a” for a second submittal.

 

The ASHRAE Appeals Board is meeting today to consider the testimony provided by appellants and rebuttals from SSPC 62.2 leadership.  We will provide more information on the Appeals Board deliberations and outcome in an upcoming “Friday Update.”

 

 

An internal AGA staff meeting on the CLEAN Future Act is being scheduled for next week where the BECS staff comments and other staff comments will be discussed.  Among the comments provided by BECS staff are objections to the following categories of provisions:

 

 

 

Final positions on the CLEAN Future Act will be developed by AGA legislative staff in the coming weeks.

 

 

Having conducted for AGA members serving the City of Austin with an initial review of amendments to the 2021 IECC coverage under consideration by the City, BECS  staff is now beginning drafting recommended text for the City “Energy Code,” addressing proposed amendments and existing coverage affecting the direct use of natural gas.  Public comment on the amendments are due to the City on April 15^th.  Areas of the Energy Code and amendments being reviewed for AGA-drafted amendment language include the following:

 

 

 

 

We plan to provide draft text to the serving gas utilities involved in the review of the Energy Code amendments early next week.