The AGA, APGA, NPGA, and Spire Inc., Filed Comments on the NOPR for Consumer Hot Water Boilers.

Last week, we reported that AGA, the American Public Gas Association (APGA), the National Propane Gas Association (NPGA), Spire Inc., Spire Missouri Inc., and Spire Alabama Inc., filed timely, joint comments on the DOE notice of proposed rulemaking (NOPR) pertaining to energy conservation standards for consumer (residential gas, electric and oil) hot water boilers. Attached are a copy of those comments that were not included in that report. Recall that on August 18th,  DOE published a Federal Register NOPR that set a October 13, 2023 deadline for comments, data, and information regarding this NOPR. The proposed minimum efficiency level for consumer hot water gas boilers is a 95% AFUE that would require condensing technology for compliance. The joint comments identified serious concerns with the technical analysis and economic justification that DOE developed to establish the 95% AFUE minimum efficiency level.  We will provide the DOE response to the comments submitted on the NOPR when available.

Consumer Product Safety Commission (CPSC) Votes to Publish a Proposed Safety Standard for Gas Furnaces and Boilers.

Last week, the CPSC voted to publish a proposed safety standard for residential gas furnaces and boilers.  This action is a continuation of the CPSC November 19, 2019, Federal Register Notice, “ Performance Requirements for Residential Gas Furnaces and Boilers; Advance Notice of Proposed Rulemaking” (ANOPR) that essentially proposes that a carbon monoxide (CO) sensor be installed within the residential furnace or boiler that would shut down them down in the event of excessive CO production in the exhausted combustion products from the furnace or boiler.   It is expected that CPSC will publish a Federal Register Notice in the near future and there will be a 60-day comment period that will begin upon publication in the Federal Register.  Attached is CPSC Commissioner Peter A. Feldman’s statement after the CPSC action at the October 11th meeting that provides more information on the NOPR and outlines additional material it seeks from the industry and the public on a number of issues on the proposal .  They include, What factors should the Commission use to determine when a cost-benefit relationship is reasonable and how should the Commission apply such factors in this specific rulemaking?”. Additionally, Commissioner Feldman is seeking information on  “How and which foreign standards could be feasible to apply to the US market” for the CO sensor technologies and “How can this rulemaking meet the “least burdensome” requirement for stakeholders and consumers?”

We will provide the CPSC Federal Register Notice of Proposed Rulemaking when available.

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.