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    American Gas Association Issues Public Comment to HUD


    September 23, 2022 - Targeted News Service

     

      TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, editor@targetednews.com, Springfield, Virginia; 703/304-1897; https://targetednews.com

      WASHINGTON, Sept. 22 -- The American Gas Association has issued a public comment to the U.S. Department of Housing and Urban Development. The comment was written and posted on Sept. 19, 2022.

      The comment, on Docket No. HUD-2010-0060-0016, was sent to Teresa B. Payne, administrator of the Office of Manufactured Housing Programs at the Office of Housing.

      Here are excerpts:

      * * *

      The American Gas Association ("AGA"), appreciates the opportunity to provide comments in response to the Department of Housing and Urban Development's ("HUD") Notification of Proposed Rulemaking ("NOPR")/1 for proposed changes to the Manufactured Home Construction and Safety Standards.

      AGA, founded in 1918, represents more than 200 local energy companies that deliver clean natural gas throughout the United States. There are more than 77 million residential, commercial, and industrial natural gas customers in the U.S., of which 95 percent -- more than 73 million customers -- receive their gas from AGA members. AGA is an advocate for natural gas utility companies and their customers and provides a broad range of programs and services for member natural gas pipelines, marketers, gatherers, international natural gas companies, and industry associates. Today, natural gas meets more than one-third of the United States' energy needs.

      A. Update of Referenced Industry Safety Standards

      1 Manufactured Home Construction and Safety Standards, 87 Fed Reg. 43114 (July 19, 2022).

      * * *

      The NOPR would propose updating existing reference standards for appliances and components used in the construction of manufactured homes that, although more current than existing referenced standards, do not reflect the most current edition of these standards. Mandating the use of appliances and components that meet outdated standards puts a burden on the manufacturers to maintain outdated equipment, and does not allow manufactured homes owners the opportunity to have the most current products installed. AGA recommends that HUD consider a review of the standards and update the references to most current edition of the standards. Specifically, AGA recommends the following standards and codes for gas-fired appliances and accessories, including controls and tubing, be considered (as shown below using strike-out an underline to denote the recommended changes to the newest edition of the referenced codes and standards):

      * * *

      Table: J. Revisions to Standards Incorporated by Reference (Reference Standards)

      * * *

      [Text omitted due o strike through words]

      Additionally, AGA recommends that CSA Group, the accredited standards development organization for most of the above listed standards, should be included in the resources.

      In addition to reviewing these standards on-line, copies of the standards may be obtained from the organization that developed the standard as follows:

      ADD

      CSA Group

      8501 East Pleasant Valley Road

      Independence, OH 44131

      Website: csagroup.org

      Sec. 3280.4 Incorporation by reference.

      ADD

      CSA Group

      8501 East Pleasant Valley Road

      Independence, OH 44131

      Website: csagroup.org

      B. Heating, Cooling and Fuel Burning Systems a. Paragraph 3280.709(a)

      HUD proposes to revise Sec. 3280.709(a) to remove the language that requires manufacturers to leave appliance manufacturer instructions attached to appliances. AGA appreciates the concern that users of the code may interpret this paragraph to require duplicate set of instructions, the CSA/ANSI standards currently require that these instructions be attached as part of the appliance's certification. Removal of this requirement will cause a conflict with the safety standards and fuel gas installation code requirements.

      b. Paragraph 3280.709(g)

      HUD proposes to revise Sec. 3280.709(g) to allow any fireplace or wood stove, provided they are listed or certified for their intended purpose, to be installed regardless of the testing and certification requirements specified by the Standard for Vented Gas Fireplace Heaters, CSA/ANSI Z21.88-2019 * CSA 2.33-2019. The standard has specific requirements for appliances intended for installation in manufactured and mobile homes, including provisions for converting from natural gas to propane, means to fasten burners to prevent movement during transport, venting, and marking and labeling requirements. Using an appliance not tested and certified for mobile/manufactured homes could be in violation of the listing and certification of the product.

      c. Paragraph 3280.707 Heat Producing Appliances

      Paragraph 3280.707(d)(2) specifies the method of test to determine energy efficiency compliance for gas-fired water heaters as specified in ANSI Standard Z21.10.1. However, these requirements were removed from the ANSI Z21.10.1 standard more than a decade ago. The Manufactured Home Construction and Safety Standards should reference the applicable 10 CFR requirements established by the Department of Energy.

      C. Conclusion

      AGA thanks HUD for the review and consideration of these comments and the requests contained herein. If you have any questions regarding this submission, please do not hesitate to contact the undersigned.

      Respectfully submitted,

      Matthew J. Agen

      Assistant General Counsel

      American Gas Association

      400 N. Capitol Street, NW

      Washington, DC 20001

      magen@aga.org

      * * *

      Original text here: https://downloads.regulations.gov/HUD-2010-0060-0048/attachment_1.pdf

      TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, editor@targetednews.com, Springfield, Virginia; 703/304-1897; https://targetednews.com

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