BECS Staff Moves Forward on Multiple Fronts on Claims Regarding Combustion Emissions from Residential Gas-Fired Cooking Appliances.
Results of combustion emissions tests requested by the BECS Committee and conducted by the CSA Group at the end of 2019 were recently presented to AGA leadership and members upon request to address initial claims regarding nitrogen dioxide (NO2) emission rates from gas ranges as they apply to residential occupant exposures. Talking points summarizing this work and its implications are posted on the BECS Committee website and are available here. NO2 time-averaged and peak air-free concentrations from tested ranges are shown below.
As the graphed results show, oven peak and time-averaged calculations deviate much more strongly than cooktops because of thermostatic cycling of ovens. The steady-state emission rate for oven burners, set on maximum temperature, is inherently higher than for other burners on the range, but cycling of oven burners and the resulting time-averaged emission rates are directly relevant for kitchen exposures to NO2. It is also important to note that the peak rates for ovens shown above are atypical of the on-cycle emission rates, which are often lower than 100 ppm. The relationship of the time-averaged data to peak measurements suggests another important point: it is unclear what advocates opposed to gas cooking appliances are focusing upon – peak rates, which are not particularly relevant to estimating exposures or average rates, which are relevant. Furthermore, the importance of the time-averaged data may be that it could directly refute the statements of Lawrence Berkeley National Laboratory (LBNL) and others reported in the press that:
“If these [gas cooking range combustion emission concentrations] were conditions that were outdoors the EPA [Environmental Protection Agency] would be cracking down. But since it’s in people’s homes, there’s no regulation requiring anyone to fix it.”
Additional analysis of the LBNL data is focusing on how test data was taken and how it compares to time-averaged measurements.
BECS staff is working closely with the Association of Home Appliance Manufacturers (AHAM), the industry organization that represents gas range manufacturers, to share data on emission and information on usage patterns and other variables that would be used to estimate occupant exposures from source emission rates. A formal data sharing agreement is being explored with AHAM. BECS staff has drafted a proposed work scope for additional testing, including expansion of NO2 testing and adding carbon monoxide, particulate matter, and formaldehyde sampling to emissions measurement. These combustion emission products have been widely cited by electrification interests as important contributors to poor indoor air quality due to use of gas ranges. Initial contacts have been made with AHAM-recommended testing laboratories in advance of issuing a competitive request for proposals for this testing.
BECS staff continues to support individual AGA member companies in responding to attacks on natural gas cooking, ranging from responding to claims offered in local jurisdictional proposals to banning of gas cooking to state-level energy standards proceedings and proposed state initiative to restrict natural gas direct use based upon claimed indoor air quality impacts from these products. In California, staff is working with a multi-disciplinary team on responding to the Sierra Club/UCLA study report (reported in last week’s “Friday Update”) attacking natural gas use, and cooking products in particular, employing expertise in toxicology, epidemiology, appliance emissions, general indoor air quality, and state air quality policy and regulation. BECS staff will be providing the team with its analysis of the study report citations associated with claims of health effects from normal gas cooking appliances next week. Following up on discussion of these issues at this week’s AGA BECS Committee “Virtual Meeting” and work already completed in California, we will also be distributing to Committee members next week, our analysis of comments presented by Rocky Mountain Institute presented in the California Energy Standard (Title 24) proceedings for the 2022 edition of the Standard. Other AGA members interested in this 16-page analysis should contact Ted Williams ([email protected]).
AGA Files to Intervene in the Natural Resources Defense Council and Others Lawsuit Challenging DOE’s “Process Rule”.
As previously reported, on Monday, April 14th, the Natural Resources Defense Council filed a lawsuit (attached) in the U.S. Court of Appeals for the 9th Circuit challenging the Energy Department’s “process rule” that limits when the agency can create new energy efficiency standards for appliances. The DOE rulefinalized in January requires that any new energy efficiency rule must save 0.3 quadrillion BTUs over 30 years, a standard that DOE says only 60 percent of efficiency rules created over the last 30 years have met. Energy efficiency advocates slammed the rule as setting too high a bar for creating rules that would drive efficiency improvements. Politico reported that Joe Vukovich, attorney and clean energy advocate for NRDC’s Climate and Clean Energy program, said in a statement. “Household and business budgets will feel the harsh blow, as will the environment, because of this DOE’s relentless efforts to undermine the energy efficiency standards program and benefit industry.” As a reminder, AGA is on record supporting the updated DOE “Process Rule” and the rule has the support of appliance manufacturers. Yesterday, AGA filed “motion to intervene” (attached) and we will be providing updates on this legal challenge as it progresses through the court. As previously reported, the revised DOE Process Rule is an important upgrade for DOE to follow in developing appliance and equipment minimum efficiency requirements.
AGA Files Comments on the DOE April 15, 2020 Request for Comment (RFC) Concerning Prioritization of Rulemakings.
In response to a DOE April 15, 2020 Request for Comment (RFC) concerning prioritization of its rulemakings, AGA filed timely comments today proposing that the DOE take to actions as follows:
- DOE SHOULD PRIORITIZE FINALIZING THE PENDING PETITION FOR SEPARATE PRODUCT CLASSES BEFORE ISSUING A PROPOSED RULEMAKING ON ENERGY CONSERVATION STANDARDS and
- DOE SHOULD CONSIDER INITIATING A PROCEEDING TO DEVELOP ANALYTICAL GUIDANCE FOR MINIMUM EFFICIENCY RULEMAKINGS
AGA’s comments stressed that by acting favorably on these two proposals, the DOE will finalize their July 11, 2019 purposed action that would recognize separate product classes for condensing and non-condensing vented gas heating and water heating appliances and equipment and furnaces and would improve the DOE Process Rule by which they establish minimum energy efficiency requirements. We will report on the DOE actions on our request when available.
DOE Publishes a Request for Information Pertaining to Test Procedures for Consumer Boilers – Comment Deadline is June 15.
Today, the U.S. Department of Energy (DOE) published a Federal Register notice initiating a data collection process through this request for information (RFI), to consider whether to amend DOE’s current test procedure for consumer boilers. DOE is seeking data and information pertinent to whether amended test procedures would more accurately or fully comply with the requirement that the test procedure produces results that measure energy use during a representative average use cycle for the product, and not be unduly burdensome to conduct. DOE will accept comments, data, and information regarding this RFI until June 15, 2020. Interested persons may submit comments identified by docket number EERE–2019–BT–TP–0037, by email ([email protected]), Federal eRulemaking portal (http://www.regulations.gov) postal mail, or hand delivery/courier. AGA BECS staff is reviewing the RFI and the issues the DOE is seeking information and the RFI does provide the opportunity to request the long standing position that the DOE needs to develop and establish separate product classes for vented natural gas heating and water heating appliances and equipment based on the characteristic that they are either non-condensing or condensing types.
American Council for an Energy-Efficient Economy (ACEEE) Policy Brief on State Policies and Rules to Enable Beneficial Electrification in Buildings through Fuel Switching.
As discussed and requested at the BECS committee’s May 12, 2020 virtual meeting, attached is the ACEEE Policy Brief on state policies and rules designed to enable beneficial “electrification” in buildings through fuel switching. The policy brief provides information on existing state policies within this area and according to the ACEEE, is provided “to assist regulators and program administrators as they seek to design and deliver effective programs that enable fuel switching and meet their maximum potential to achieve net carbon reduction benefits”. BECS Committee members should review the Policy Brief information and the impact of the policies and regulations impact on the threats to the direct use of natural gas their service territory and share it with appropriate departments within your organization.
State Codes Activity Update.
[This 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.]
Recent Activity Alerts
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State
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Date
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Title
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CO
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08/01/2020
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On August 1, 2020, the 2020 edition of NFPA 70 National Electric Code (NEC) will be adopted by the state of Colorado and enforced by the City and County of Denver. The 2020 NEC will become the minimum standard for electrical permits issued on or after August 1, 2020. Any project drawings logged in for review prior to August 1, 2020 will be reviewed under the 2017 NEC; project drawings logged in on or after August 1, 2020 will be reviewed under the 2020 NEC.
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Recent Code Body Meetings
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State
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Body
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Date
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Address
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Agenda
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MA
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Board of Building Regulations and Standards
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05/12/2020
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Teleconference
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IL
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Capital Development Board
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05/12/2020
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Teleconference
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CO
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Board of County Commissioners
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05/12/2020
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Teleconference
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Bills with Recent Activity
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State
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Bill #
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Bill Title
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Primary Sponsor(s)
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Last Action
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Last Action Date
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N/A
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N/A
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NO RECENT LEGISLATIVE ACTIVITY
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N/A
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N/A
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N/A
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Summary: N/A
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