Reminder, Comments on the AGA Draft Response to the ASHRAE Proposed 2^nd Public Review of Addendum bk to the ASHRAE 90.1 Energy Standard for Sites and Buildings Except Low-Rise Residential Buildings Due Tuesday.  ASHRAE June Journal Article Cites Concerns with Mandating Electric Space Heating Heat Pumps in the Prescriptive Path of the Standard.   

On Wednesday, we requested BECS Committee member comments on the ASHRAE on the 2^nd Public Review of proposed Addendum bk to the ASHRAE 90.1 Energy Standard for Sites and Buildings Except Low-Rise Residential Buildings that would if approved, negatively impacts natural gas applications in commercial buildings covered by the ASHRAE 90.1 Energy Standard.  Addendum bk would require that compliance in the prescriptive path of the standard be based on space heating heat pumps as the primary system thus excluding federally approved natural gas heating systems (natural gas furnaces and boilers) as a primary system that is currently permitted in this compliance path. We attached the draft comments (also attached here) and requested your review and provide us with your comments on the latest draft respond to the 2^nd Public Review of Addendum bk by this Tuesday, June 24.

In an interesting development,  the June 2025 ASHRAE Journal included an article on pages 42 to 50, published by Steve Kavanaugh, Ph.D.,  professor emeritus of mechanical engineering at the University of Alabama, titled  “ Decarbonizing with Heat Pumps—Most Do, Some Don’t”. The Conclusion section of the article states the following:

• In areas with high emission rates of CO2/kWh, the use of electric “Air Source Heat Pumps (ASHPs) is counterproductive to decarbonization efforts, and the benefits of Gound Source Heat Pumps (GSHPs) are marginal. This is especially true in colder climates.

• The discrepancy between the projected performance of cooling equipment (which are heat pumps) and the actual output is a significant concern for decarbonization efforts with heat pumps that both cool and heat.

• The significant growth of wind and solar generation capacity is encouraging in terms of the reduction of both carbon emissions and cost of fuel (fossil and nuclear). However, the minimal improvement of national emission rates of CO2/kWh is disconcerting.

The article expresses the same concerns that mandating electric heat pumps as proposed in Addendum bk can be counterproductive and essential supports our position that the baseline should not mandate electric heat pumps and permit other heating products such as federally approved natural gas furnaces or boilers should be retained as an option as a primary heating system in the compliance path approach.