Industry Blogs

By Laura Urbanek

The Department of Energy is continuing its assault on the appliance energy efficiency standards program, with a proposed interpretive rule out this week that could freeze in place the standards for residential furnaces and commercial water heaters that use natural gas or propane. This shortsighted proposal could waste substantial amounts of fossil fuels and cost consumers billions in wasted energy costs. It’s a massive shift by DOE, which had already addressed this issue multiple times, as recently as 2016.

Fossil (aka “natural”) gas and propane are popular fuel sources for space heating and water heating in the United States, but when burned inside homes and businesses they emit climate-altering pollution and can impact indoor air quality. About half of homes are heated with fossil gas, and most of those homes used a gas furnace. Space heating represents the largest energy expense for the average U.S. household, accounting for about 45% of energy bills.

Standards for residential natural gas furnaces were last meaningfully updated in 1992, which means that many homeowners are already wasting climate-harming fossil fuels when they heat their homes. More efficient standards for furnaces, alone, could cumulatively save consumers $24 billion on their utility bills by 2050, while reducing harmful carbon pollution by nearly 85 million metric tons (equivalent to the annual emissions from 22 coal-fired power plants). But with this proposal, these savings are all but guaranteed to be lost, as DOE yet again prioritizes industry interests over the health and well-being of consumers and the planet.

Last fall, groups representing the gas industry—American Public Gas Association (APGA), Spire, Inc., the Natural Gas Supply Association (NGSA), the American Gas Association (AGA), and the National Propane Gas Association (NPGA)—petitioned DOE to change how it interprets the definition of “performance characteristics” as it relates to gas furnaces and commercial water heaters. While this gets wonky pretty quickly, the issue boils down to the use of condensing or non-condensing technology.

Condensing vs. Non-Condensing

Furnaces or water heaters using condensing technology capture additional heat from the flue gases that would otherwise be lost up the chimney, and return usable heat. This results in a more efficient furnace or water heater with significant energy savings for consumers. In fact, without the use of condensing technology, there is little room for energy efficiency improvements over existing models of gas equipment.

The energy-saving benefits of condensing technology are immense. A recent report from the Appliance Standards Awareness Project found that condensing technology can reduce residential gas water heater energy consumption by about 25 percent. DOE estimated in a September 2016 furnace supplemental proposed rule that consumers would save about $700 on average by purchasing a furnace that complies with the proposed standard, after accounting for all costs (including any relevant venting and plumbing costs related to installation).

DOE Changes its Tune

Condensing equipment requires different venting compared to non-condensing equipment, and also requires a plumbing connection to dispose of the condensate produced. The gas industry groups argued that the presence of this different venting and a plumbing connection are “features” or “performance characteristics” that require these products to be put in a separate product class, with separate standards for condensing and non-condensing products. That’s a problem, because it means that inefficient furnaces and water heaters that waste energy by not utilizing up-to-date technology will still be available on the market—which defeats the purpose of a higher energy-saving standard that benefits all consumers.

We do not agree with the gas industry groups’ interpretation of what constitutes a “performance characteristic,” as we laid out in comments submitted to DOE on the petition back in March, In fact, we find what the gas industry groups requested to be contrary to the law.

What’s more: DOE itself previously disagreed with this interpretation! The gas industry groups have been looking for a way out of updating the standard for years, and each time, DOE has given a consistent, rational explanation for its decision to not treat condensing products as a unique product feature. Most recently, DOE cautioned in the March 2015 residential furnace notice of proposed rulemaking (NOPR), and reconfirmed in its September 2016 supplemental NOPR, “Tying the concept of ’feature‘ to a specific technology would effectively lock-in the current existing technology as the ceiling for product efficiency and eliminate DOE’s ability to address technological advances that could yield significant consumer benefits in the form of lower energy costs while providing the same functionality for the consumer.” Yet this is exactly what the gas industry groups asked DOE to do in the petition at hand, without providing a compelling reason for why DOE should reverse its long-held, consistent determination of product classes.

Unfortunately, DOE has done a 180-degree turn to change its position, now agreeing with the gas industries—to the detriment of consumer energy savings. DOE claims that they’re looking out for the consumer, citing concerns about how exterior venting could impact the aesthetics of a home, and that requiring better technology would result in financial hardship to low-income consumers. Yet, groups like the National Consumer Law Center and the Consumer Federation of America—whose job day in and day out is to represent interests of low-income consumers—are strongly opposed to DOE’s approach. They note that consumers—especially low-income consumers—will suffer “substantial financial harm,” losing out on billions of dollars in energy savings under the proposal at hand.

There are more steps DOE needs to take before this is a done deal, and we’ll be fighting at every step of the way. Changing the rules to stymie progress is not in the best interest of consumers, especially low-income consumers who spend a disproportionate amount of their income on energy bills. This proposal rests on shaky legal ground, and even worse, it wastes fossil fuels. And when fossil fuels are responsible for so much of the climate crisis, a proposal to increase waste is simply unconscionable.

Laura Urbanek is Senior Energy Policy Advocate, Climate & Clean Energy Program, NRDC.

Recently, the International Code Council held their Code Action Hearings in Albuquerque, NM. Included on the agenda were what appeared to be innocuous proposals to update the standards that are included in the codes. Typically the standards updates are relatively benign, and incorporate new language to accommodate new technologies. Seldom does a standard update change the level of safety for a particular product, such as is happening with the product listing standard for equipment using flammable refrigerants. In the ICC system, standard updates are considered by the Administrative committee and if they meet the ICC criteria, they are rubber stamped into the next edition.

Unfortunately, this committee is not one to debate or consider the technical aspects within the standards updates being proposed—they simply consider whether the standards meet the ICC criteria, which doesn’t require that the standard be complete before being considered. In this particular case, the UL standard for equipment containing flammable refrigerants was not complete and the exact publish date was still under discussion.

The 2018 and 2021 editions of IMC, IFC and UMC have all rejected the addition of A2L flammable refrigerants in direct HVAC systems until all safety concerns are addressed and the research is complete.

The flammable refrigerants issue has become a very big subject of debate in the codes covering HVAC, refrigeration and fire safety nationwide. In fact, many proposals to add these flammable refrigerants in direct systems, were proposed to the International Mechanical Code committee, the International Fire Code committee, and IAPMO’s Uniform Mechanical Code committee. All were rejected based on multiple aspects including, safety concerns, and incomplete research. The main concern was that the cart was being placed before the horse even before the cart had it’s wheels attached.

There was not a single safety provision related to A2L (flammable) refrigerants for direct air conditioning systems proposed for the International Residential Code (IRC). There was also not a single discussion before the IRC committee even though this committee was chosen for their technical expertise in this area. After the 2021 Code Action Hearings, all of the model codes, nationwide, were in unison in their rejection of proposals to allow these flammable refrigerants for direct HVACR systems in all occupancies, including residential and commercial.

However, there was one loophole still available for those relentlessly pursuing these new flammable refrigerants in all occupancies. They proposed the unfinished standard be included in the IRC to the Administrative Committee.

Proponents desperately trying to go around the technical committees knew that the administrative committee would likely consider only the procedural issues, and not entertain technical debate—the committee is called the “administrative committee” for a reason. Unfortunately, the proponents were correct—instead of rejecting the proposal and putting the responsibility on the proponents to present their case to the appropriate technical committee, they recommended approval and the buck was passed to the membership to determine whether flammable refrigerants should be permitted in the code without any installation requirements.

If this proposal is finalized at the Public Comment Hearing meetings in Las Vegas, there will be absolutely zero provisions in the code to safely install flammable refrigerants in direct HVAC systems in homes. It is important to note that the standard is a product safety standard, not an installation standard. An installation standard is currently under development by ASHRAE, but remains unfinished.

If the standard is confirmed at the Public Comment Hearings, there will be absolutely zero provisions in the IRC to safely install and inspect flammable refrigerants in direct HVAC systems for homes.

The Air Conditioning Contractors of America, multiple fire service organizations and interests and several of the largest manufacturers of refrigerants and equipment all oppose this standard at this time and the use of these refrigerants in direct residential applications.

This must be corrected at the Public Comment Hearings, and most importantly, during the Online Government Vote afterwards. The technical and safety debate must take its proper path and play-out as all other critical lifesafety provisions throughout the history of ICC’s code development process have done. If this action is condoned, what will stop others from timing their standards the same way as they have done here – circumventing all technical and safety debate of the industry and the membership of ICC? This sets a very bad precedent, raises safety concerns and conflicts with the votes of the IMC, UMC and IFC committees..

To the ICC Membership:

The committee must be overturned so that flammable refrigerants will NOT be allowed in homes without a single technical or safety provision included to insure public safety. Please vote to overturn the committee and maintain consistency with the IMC, UMC and IFC code development committees.

About the author: Jay Peters has been in the industry for almost 40 years as a licensed journeyman plumber, refrigeration journeyman, sheetmetal installer and multi-state contractor. For more than a decade he worked for the two largest code organizations as Executive Director of plumbing, mechanical and fuel gas at the International Code Council (ICC) and Senior Director of Codes and Education at the International Asssociation of Plumbing and Mechanical Officials (IAPMO). Currently he is the principal advisor at Codes and Standards International. His articles have appeared in Plumbing Engineer, IAPMO Official, Plumbing Africa, PM Engineer, Contractor, Reeves Journal, National Envirnomental Health Association Journal, ICC Building Safety Journal and more. Contact: Jay@BuildingCodesAndStandards.com

Dain Hansen is vice president of Government Relations, The IAPMO Group. He lends his frequent perspective of Capitol Hill, and the plumbing industry.

Here is an edited version of his update from June 14, 2019:

Congressional Update.

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