AGA Comments on the DOE June “Workshop on the Future of Building Energy Codes”
As previously reported, the U.S. Department of Energy (DOE), Building Technologies Office held a virtual stakeholder workshop on June 22nd and 24th to “highlight leading advancements in energy codes, bringing together key stakeholders from across the design and construction industry to discuss recent code updates, upcoming trends, as well as opportunities and challenges that states and local governments face in code implementation.” Today, AGA filed comments (attached) on the Workshop that expressed our concern that in its role of providing technical and economic analysis support for the model energy code development process and support for states in adopting the latest versions of those model codes, DOE should not support inclusion of provisions into those codes that were not adopted during the development process of those codes. AGA is concerned with some stakeholder’s announced efforts to include provisions in the state adoption process of either or both the International Energy Conservation Code (IECC) or ASHRAE 90.1, that would add provisions that discourage or eliminate the option of natural gas for homes and businesses and could have the undesired effect of increasing overall energy use and removing an often viable economic and environmental energy source. Recall back on June 26, we reported that the National Building Institute (NBI) had announced a program that would advance energy model code provisions that would support “electrification “ and aimed at removing applications of natural gas in homes and buildings. One approach that they were touting was to promote energy code provisions that were recently denied in the development of the 2021 International Energy Conservation Code (IECC) that would incorporate these failed provisions along with the provisions in the 2021 Edition of the IECC. This would be accomplished by providing an “overlay” to the IECC with the denied provisions and offering these changes in state adoption proceedings. At that time, the NBI announced that they have joined with RMI (formerly known as the Rocky Mountain Institute) to promote a Codes-for-Climate Initiative that will accelerate this effort throughout North America. It is anticipated that the NBI -RMI efforts will be to interject the “overlay” as part of the proposals to update energy codes during state and local energy code adoption proceedings. Their Press Release states the following verifying that the “overlay” will be a central part of their efforts: “Codes for Climate will start with new construction, where ambitious climate-aligned codes are easiest to implement and most impactful, then move to address building performance standards and other policy options that will dramatically reduce emissions from existing buildings. Using NBI’s recently released Building Decarbonization Code overlay to the 2021 IECC as a starting point, code language will be developed to meet the urgency of achieving a 1.5°-degrees Celsius target in new construction by 2030.” This effort would basically ignore and overturn the ICC governmental consensus development process that the ICC went through to develop the 2021 IECC and needs to be challenged where ever it is promoted. The AGA comments to DOE are meant to alert them not to engage in supporting the RMI-NBI “overlay” efforts that are directed at adding model energy code provisions for restricting or prohibiting natural gas applications in homes and businesses.
Comments Requested on BECS Committee Information Document, “What We Are For: AGA Positions on Building and Energy Codes and Standards.
We are in the process of updating the AGA BECS Committee Information Document, “What We Are For: AGA Positions on Building and Energy Codes and Standards” (attached) that has been used to provide specific information on AGA’s and the committee’s activities and positions on a variety of end use codes and standards issues. The document has been helpful in identifying issues and explaining AGA’s reasons for positions on a variety of end use codes and standards issues that the BECS Committee is responsible for addressing.
DOE Unified Agenda Provides Schedule for Rulemakings on Residential Furnaces, Commercial Water Heaters and Residential Cooking Products.
Today’s Federal Register provides the Department of Energy’s schedule in the development of possible revised minimum efficiency requirements for a number of covered products including residential gas furnaces, commercial water heaters, cooking products and weatherizes gas furnaces. The schedule indicates the following actions on appliances of interest to the gas industry:
- Non-Weatherizes Residential Gas Furnaces – Notice of Proposed Rule Making (NOPR) March, 2022
- Cooking Products – Supplemental Notice of Proposed Rule Making (SNOPR) January, 2022
- Commercial Water Heaters – Notice of Proposed Rule Making (NOPR) January, 2022
- Weatherized Gas, Oil, and Electric Furnaces – Request for Information December, 2021
The schedule is helpful in anticipating the timeframe that responding to the DOE rulemaking activities will need to be made with the understanding that there is usually some delays in the published schedule.
State Codes Activity Update.
Attached 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. Please review the update and determine if there are state code activities that impact your service territory or organization.