AGA Assists California Members in Responding to Attacks on Natural Gas.

This week, AGA’s Ted Williams analyzed written testimony of Rocky Mountain Institute (RMI) and Sierra Club calling for bans of residential gas-fired cooking appliances and other gas appliances submitted in proceedings to revise the California Energy Standard, Title 24, for issuance of the 2022 edition of building energy requirements by the California Energy Commission (CEC).  AGA provided its written analysis on Wednesday for member consideration in filing comments.  The analysis covered claims, led by the RMI comments, associated with negative indoor air quality (IAQ) attributed to gas-fired cooking appliance operation and included three general criticisms of the submittals, including the following:
  • Lack of concurrence of the claims with public positions of cognizant federal health and safety agencies regarding gas-fired cooking appliances and IAQ.  Public information from the U. S. Consumer Product Safety Commission (CPSC), the U. S. Environmental Protection Agency (EPA), and the Federal Interagency Committee on Indoor Air Quality (CIAQ) do not identify gas-fired cooking appliances as a significant source of negative IAQ.
  • Misdirection of comments on IAQ claims to the revision proceedings for Title 24, which covers building energy efficiency, instead to the California Air Resources Board (ARB), where indoor air quality source control is regulated.  Comments of RMI and other organizations on IAQ clearly are intended to bolster arguments for electrification of residential buildings in California and are part of a broader effort to ban gas appliances in new residential construction and renovations.
  • Inconsistency of the claims with analysis sponsored by CEC on adequacy of Title 24 residential ventilation requirements that demonstrate the current ventilation requirements are adequate to address most IAQ issues associated with building construction and residential activity patterns, including gas-fired cooking.  Since Title 24 requirements apply to new construction and renovations, the ventilation requirements would address IAQ claims in those California residential occupancies.
In addition, Ted’s 16-page analysis addresses seven specific claims presented in the RMI comments linked to eight key technical papers covering air quality and health effects including coverage of childhood asthma and disproportionately-threatened and disadvantaged residential consumers.  The eight technical papers were reviewed during the course of developing the analysis. Once member comments are filed in the Title 24 proceeding, AGA will disseminate the filed comments and the analysis.
Sierra Club/UCLA Webinar Presents Results on Study, “Effects of Residential Gas Appliances on Indoor and Outdoor Air Quality and Public Health in California.”
On Tuesday, Sierra Club and the UCLA Fielding School of Public Health presented results of the subject study sponsored by Sierra Club covering the impact of gas-fired appliances (principally those using natural gas) on residential IAQ and potential health-related “co-benefits” resulting from electrification of residential end uses and claims of consequent reductions in combustion emissions in residential occupancies.  BECS Codes and Standards staff was invited to participate on the webinar by SoCal Gas, for which AGA is providing support on related issues before the CEC and as discussed in the story above.  The study report is available here.   In response to the study, Ted Williams is teaming up with utility expertise in epidemiology, toxicology, indoor air quality, appliance testing, and California air quality policy and regulations to review the study, which was released in conjunction with the webinar.  No sponsor-initiated review and comment process for the report is implemented for the report at this time, and it is anticipated that the report will be submitted to the ongoing CEC proceeding for updating Title 24 energy standard requirements for the 2022 edition.  However, the report may also be used to support proposed changes to California requirements promulgated by the states Air Resources Board (ARB).
AGA staff is currently focusing on providing support by reviewing the technical literature citations for IAQ and health effects claims in the report associated with operation of gas-fired appliances. Through AGA’s initial review of the report’s 323 citations, 210 citations are related to these claims while others cover air quality background information nationally and for California.  These IAQ-related citations are being reviewed using the following criteria at the start of a  more in-depth analysis of the report:
  • Technical relevance to the IAQ claims as presented
  • Degree of support of claims
  • Misapplications of research findings, as identified.
An initial “spot check” of citations in the report prior to the webinar identified problems in use of citations relating to requirements of the National Fuel Gas Code (ANSI Z223.1/NFPA 54) for unvented combustion appliances, appliance testing results for unburned methane as “combustion emissions,” and missing references to vented appliance “backdrafting” studies. These initial observations suggested that a more detailed review of the citations was warranted at the outset, even while study results presented on the webinar and in the report were found to have potentially significant analytical errors, such as inferring residential occupant exposures to combustion products from presented “peak” concentration measurements. Once the citation review is complete,  we will go on to the review of analytical results, an activity that others on the review team are expected to have begun initially and independently. Results of the reviews will be shared among the review team.
Use of the report reviews in California proceedings will follow anticipated submissions of the report to those proceedings.  Broader dissemination of the report review will be available once the reviews are completed and made publicly available and will be announced in a forthcoming “Friday Update.”
DOE Issues a Pre-Publication Request for Information Pertaining to Energy Conservation Standards for Air Cooled Commercial Package Air Conditioning and Heating Equipment and Commercial Warm Air Furnaces .
This past Monday, April 27th, the U.S. Department of Energy (DOE)  issued a pre-publication Federal Register notice initiating a data collection process through this request for information (RFI), to consider whether to amend DOE’s current energy conservation standards for air-cooled commercial package air conditioning and heating equipment (ACUACs and ACUHPs) and commercial warm air furnaces (CWAFs). This RFI solicits information from the public to help DOE determine whether amended standards for ACUACs, ACUHPs, and CWAFs, subsets of covered commercial equipment, would result in significant additional energy savings and whether such standards would be technologically feasible and economically justified. DOE will accept comments, data, and information regarding this RFI until 30 days after the notice has published in the Federal Register. DOE will send a follow-up email to announce the closing date once the notice has published. Interested persons may submit comments identified by docket number EERE-2019-BT-STD-0042, by email (, Federal eRulemaking portal ( postal mail, or hand delivery/courier.  AGA BECS staff is reviewing the RFI and requesting comments from the BECS Committee on any comments that should be sent to DOE in response to the RFI specifically on the  commercial warm air gas furnaces. 
State Codes Activity Update.
[This is a new 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.  No alerts, meetings, or bills related to building codes were identified by Fiscal Note for the Week of April 27 – May 1.]