The EPA is  proposing an additional ESTAR certification, “NextGen”program  that is  over and above the existing ESTAR program.  It includes “incentivized electrification” as a core principle to “encourage buildings to transition to efficient electric-powered heating, water heating, and cooking”.  As a reminder, the current ESTAR program is a “performance” standard. However while it is acceptable to create an additional ESTAR certification focused on low-carbon buildings, it should be kept as a performance standard and the proposed “NextGen” program is a prescriptive,  “electrification” program.  Another major problem with the proposed program is that it is focused on a “Direct Emissions Target”, that is, site emissions.  This is a major departure from source calculations in the existing ESTAR Portfolio Manager that is the correct metric to use when assessing green house gas (GHG) emissions. If EPA is attempting to address climate change,  source emissions is the metric that needs to be used.  The move to site emissions is justified by the EPA comment that using source emissions is “very complex”  and also “might discourage electrification”. This is not a valid reason for the EPA to move in support of site energy and can actually result in promoting an increase in GHG emissions. Note that comments on the proposed NextGen program are due on March 2 and can be made on this EPA site: ENERGY STAR NextGen™ Certification for Commercial Buildings | ENERGY STAR.  AGA will be submitting comments focusing on the inappropriate switch to site energy and pausing the finalization of the program pending needed modification. BECS Committee members are encouraged to also file online comments and don’t hesitate to contact us if you have any questions on this EPA proposal including the filing procedure. 

AHAM Request For Additional Data on DOE’s SNOPR for Energy Conservation Standards for Residential Conventional Cooking Products.

As reported in last week’s Update, DOE issued a February 1st,  Federal Register supplemental notice of proposed rulemaking (SNOPR) pertaining to energy conservation standards for consumer conventional cooking products including gas and electric  cooktops and ovens. DOE will accept comments, data, and information regarding this SNOPR until April 3, 2023,  In reviewing the SNOPR for cooking products and focusing only on gas cook tops and ovens, we note that the DOE is making no proposed changes to gas ovens, retaining the current prescriptive requirement that gas ovens cannot have standing pilot lights, Since there is no change to the existing requirement for gas ovens, there is no  comments needed  on this requirement.  However, on gas cooking tops, this is a new approach from the DOE with the establishment of a Maximum Integrated Annual Energy Consumption (IAEC) factor that we are assessing since to our knowledge, has not been an approach implemented by the DOE for gas products. The original DOE efficiency test procedure for cooking products determined an Energy Factor (EF) as the efficiency metric for determining the efficiency of cooking products and this technical approach is usually used in establishing a minimum efficiency level on an annual energy usage basis.  As a follow up to the DOE webinar held on these products on January 31st, the Association of Home Appliance Manufactures (AHAM) sent in the attached February 3rd letter to DOE requesting additional and extensive information on DOE’s technical and economic analysis that was used in determining the justification for the proposed level DOE has issued in the Federal Register Notice. AGA staff continues to review the DOE justification and will provide an outline on our proposed response to DOE on the SNOPR in the near future.  

AGA Submits Comments Opposing Proposed Addendum aj To ASHRAE Standard 189.1 Would Favor Electric Applications.

In the December 23, 2022, Update on End Use Codes and Standards, we reported on a Call for Comment on Standards Proposals from ASHRAE (American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc.)  on an Addenda BSR/ASHRAE/ICC/IES/USGBC Addendum aj to BSR/ASHRAE/ICC/IES/USGBC Standard 189.1-202x, Standard for the Design of High-Performance Green Buildings Except Low-Rise Residential Buildings (addenda to ANSI/ASHRAE/ICC/IES/USGBC Standard 189.1-2020). Addendum aj adds Section 7.5.2.2 as a jurisdictional option along with normative Appendix M. If adopted by an AHJ, this section would supplement Section 7.5.2.1 and allow the electricity greenhouse gas emissions (GHG) of both the proposed design and the baseline building to be calculated using long-run marginal emission rates (LRMER). GHG emissions from direct use of fossil fuels and thermal energy in buildings would continue to be calculated using the procedures in Section 7.5.2.1. The concern for the natural gas industry is that the use of Long-Run Marginal Emission Rate within codes and standards will make it more difficult for natural gas to compete with electric products for space, water heating, etc., applications since LRMER makes highly questionable assumptions about the improvements in the future electric grid that can’t be guaranteed will ever occur. In addition,  the proposal ignores any future decarbonization of the gas distribution system from renewable natural gas and hydrogen. Thus,  prediction of GHG emissions reductions for electric applications will favor electric installations over natural gas.  AGA submitted timely comments (attached) opposing the adoption of Addendum aj outlining specific concerns with the justification for this provision in the ASHRAE 189.1 standard. We will report on the response from the ASHRAE 189.1 committee when available.