On April 22, APGA submitted comments in response to the first public review draft of the Standard for the Design of High Performance Green Buildings Except Low-Rise Residential Buildings. This document is being revised in coordination with several Standards Developing Organizations (SDO), including American National Standards Institute (ANSI), American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), International Code Council (ICC), U.S. Green Building Council (USGBC), and Illuminating Engineering Society (IES). APGA worked closely with Neil Leslie, at the Gas Technology Institute (GTI), in drafting this input.
If certain stakeholders working the revision are successful in getting their language in the new version, the direct use of natural gas for buildings will be significantly impacted. For this reason, the APGA comments on the first public review draft identify the need to use source energy conversion factors consistent with those used by other stakeholders and governments. As well, even though APGA notes that marginal calculation methods are preferred, the feedback submitted states that national average conversion factor methods be used, which is the methodology used by the Environmental Protection Agency (EPA). At a minimum, the Standard 189.1 revision committee should provide rationale for deviation from what is being used in efficiency standards by other entities. More technical details were provided by other commenters, such as GTI, but the general concerns raised allow for APGA positions to be heard and a response from the revision committee.
APGA’s comments are available on the APGA website. For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-544-1334 or by email at
ssaulters@apga.org.