AGA Comments in Response to the ASHRAE Proposed 2nd Public Review of Addendum bk to the ASHRAE 90.1 Energy Standard for Sites and Buildings Except Low-Rise Residential Buildings Due.

On Monday, AGA submitted the attached comments on the ASHRAE on the 2nd 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.  The AGA comments requested disapproval of Addendum bk. We provided our justification for disapproval by providing a number of procedural issues by ASHRAE that we contend conflicted with federal requirements (OMB A-119), federal preemption and the ANSI Essential Requirements for the development of Addendum bk.  They include the following:

• ASHRAE Must Follow Due Process Principles Fundamental to Proper Model Consensus Code Development by Avoiding Conflicts of Interest with the Standard Development Committees It Administers
• Proposing Electric Heat Pumps as the Baseline in Addendum bk can be Counterproductive for Energy Usage Reductions and Potential Decarbonization Efforts of the ASHRAE 90.1 Standard.
• Adhering to Due Process Code Development Principles Helps Avoid Improper Conduct by Market Participants
• Addendum bk is Preempted by Federal and State Law
• Addendum bk Will Result in Code Provisions in Violation of the Energy Policy Conservation Act
• Addendum bk Will Result in Code Provisions in Violation of State Energy Choice Legislation and State Utility Regulations

The ASHRAE Standing Standard Project Committee (SSPC) 90.1 will now be reviewing all public comments on Addendum bk and providing a decision on the addendum in the near future. We appreciate the members who provided input on our draft comments and will provide the ASHRAE response on Addendum bk when available.

International Energy Conservation Code (IECC)  Committee Action Hearings Complete – Update on Code Proposals Impacting Natural Gas Applications and Next Steps.

Since the beginning of the year, we have been reporting on the International Code Councils (ICC)  process in developing the 2027 Edition of the IECC.  The IECC committee action hearings concluded this past Monday, June 30.  The Committee Action Report for proposals to the Commercial code is available from the IECC website (ICC-CS_AE TECHNICAL SERVICES GROUP – Documents).  The Residential Committee Action report is expected to be published by July 4.  There were two major positive successes for the gas industry: Code changes resulting in recognition of and appropriate energy credits for gas-fired heat pumps and gas-fired heat pump water heaters were approved by both the commercial and residential consensus committees.  In addition, the simulated building performance path that established separate thresholds for mixed-fuel homes and all-electric homes has been revised to reestablish fuel neutrality and instead focus on climate zone.

However, AGA BECS staff has identified several challenges that will require attention during the second phase of the IECC revision process.  On the commercial side, a proposal in the performance section was accepted that would essentially make electric heat pumps the primary heating source for all new construction.  (This is similar to what has been proposed in Addendum bk to ASHRAE 90.1, and which AGA has challenged for a number of reasons outlined in today’s Update on Addendum bk).  There were multiple proposals on nonelectrical submetering in commercial buildings.  While the subgroup supported removing the requirement based on a lack of cost effectiveness, the consensus committee decided to maintain the provision based on fuel neutrality.  Finally on the commercial side, a new appendix was added regarding a “single conservation objective.”  This a nonmandatory appendix that was proposed and approved with no evidence of energy conservation or cost effectiveness.

Challenges on the residential side include a proposal to incorporate a CO2-equivalent index as an alternative to the Energy Rating Index (ERI).  The CO2-e index applies a rating to a design for “operational carbon.”  This proposal was disapproved by the residential consensus committee during this first phase, but we expect it to be reintroduced for phase #2.  Finally, AGA will file comments during the second phase to challenge a new provision that will require electrical infrastructure sized to meet the load of an electric heat pump wherever gas-fired space heating equipment is installed in new homes. AGA and other stakeholders have opposed this provision in previous IECC development cycles as increasing residential and commercial costs with no benefits.  We will provide updates and suggested actions on proposals as they proceed during the next model energy code development phase.

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.

NOTE:  Also attached is the AGA June 30, 2025, Energy Markets Analysis that provides important statistical information on the global use of natural gas that can be helpful in providing fact-based information on the benefits that the use of natural gas contributes to the energy needs of the world.