MPSC VAP Collaborative Meeting discusses data transfer
Last month MPSC held a collaborative meeting in Lansing to discuss the possibility of a website providing information as to how to retrieve information regarding the new Value Added Program (VAP).
The website's goal is simply information. "If you are a utility and the law says you must provide information to all of your competitors, you may not know who they are; this website will be designed to level the playing field in making an informed request by providing all of the needed information," said Director Bill Stosik.
Why MPSC is envisioning each utility having a website of its own in which a user can make a request - basically a way to have easy access to all pertinent information - although no conclusion was made as to the implementation of the site and whether it should be hosted by each utility.
Other topics regarded the level of security needed and the timelines for such an implementation. Essentially, the issue will be how the data is transferred from one entity to another entity and if the recipient has an acceptable level of Information Technology security in place to satisfy the security policy of the sender (utility).
The meeting adjourned stating that it will try to get a report within a couple of weeks though MPSC was not sure what will happen after the report is submitted or how long before a response will be made regarding the access to the VAP information.
Midstream HVAC rebate programs are still far from ready
The recent Energy Waste Reduction collaborative meeting in Lansing was met with a rather large turnout. Presentations were given on existing midstream HVAC rebate programs and proposed programs by representatives of utilities and implementation contractors.
With a midstream program, a customer purchases equipment for example, and a contractor distributor give the discount to the contractor who passes the discount to homeowner and the distributor is reimbursed by utility. The problem with the distributor rebate is that it places an undue burden on the distributor and will take away from the integrity of the rebate program as opposed to contractor doing as it has been done for 10 years. With a midstream program, there is not much of a way to guarantee that the customer will get his/her rebate unlike the current system where the customer gets a check after submitting his/her rebate.
Basically, instead of the contractor processing a rebate, the distributor processes the rebate which can take away form the integrity of the program without ensuring that homeowner gets the rebate.
MIACCA and others were on hand to communicate the specific concerns of contractors and distributors of having the wholesaler process the rebate; which generated good questions and significant discussion.
Throughout the formal presentations, multiple concerns about midstream HVAC programs were acknowledged including the potential for over-sizing and poor equipment installation, the rebate not getting to the home owner, delayed reimbursement to the distributor and shifting admin burden to the distributor among other topics.
It seem that utilities, implementation contractors, and others were all on the same page that midstream HVAC programs are far from ready to roll out at a large scale. To be clear, the utilities are still interested in trying to find a way to make these work. But the door is open for much more discussion with all partners first.
MIACCA will continue to actively follow these sessions and report back as more information is made available.
HB 5376 Update Documents
MIACCA Submits proposed 2018 Michigan Mechanical Code rules
301.2 Energy utilization. Heating, ventilating and air-conditioning systems of all structures shall be designed and installed for efficient utilization of energy in accordance with the International Energy Conservation Code.
Exception: Any code provision or part of the system that does not meet the definition of “cost-effective” per MCL 125.1502a(p) and MCL 125.1504(3)(f) - (g) as determined by the mechanical inspector.
603.9 Joints, seams and connections. Longitudinal and transverse joints, seams and connections in metallic and nonmetallic ducts shall be constructed as specified in SMACNA HVAC Duct Construction Standards—Metal and Flexible and NAIMA Fibrous Glass Duct Construction Standards. Joints, longitudinal and transverse seams and connections in ductwork shall be securely fastened and with welds, gaskets, mastics (adhesives), mastic-plus-embedded-fabric systems, liquid sealants or tapes.
Tapes and mastics used to seal fibrous glass ductwork shall be listed and labeled in accordance with UL 181A and shall be marked “181 A-P” for pressure-sensitive tape, “181 A-M” for mastic or “181 A-H” for heat-sensitive tape. Tapes and mastics used to seal metallic and flexible air ducts and flexible air connectors shall comply with UL 181B and shall be marked “181 B-FX” for pressure-sensitive tape or “181 B-M” for mastic. Duct connections to flanges of air distribution system equipment shall be sealed and mechanically fastened. Mechanical fasteners for use with flexible nonmetallic air ducts shall comply with UL 181B and shall be marked “181 B-C.” Closure systems used to seal all ductwork shall be installed in accordance with the manufacturer's instructions.
Reason for 301.2: Because the Bureau of Construction Codes is not promulgating the Energy Code at the same time and the Mechanical Code, which is broadly referencing the Energy Code, the suggested exemption language is needed for clarification that even referenced code provisions, that are enforceable, must still be "cost effective" as statutorily required. Additionally it must be made clear that mechanical inspectors that work in jurisdictions that have elected pursuant to MCL 125.1508b to administer and enforce the Stille-DeRossett-Hale Single State Construction Code Act, 1972 PA 230 and state code have the authority and responsibility to determine what is "cost effective". This exemption is consistent with the Bureau of Construction Codes published 2015 Michigan Residential Code Errors and Conflict document.
- Exception: For ducts having a static pressure classification of less than 2 inches of water column (500 Pa), additional closure systems shall not be required for continuously welded joints and seams and locking-type joints and seams. This exception shall not apply to snaplock and button-lock type joints and seams located outside of conditioned spaces.
- Exception: For ducts having a static pressure classification of less than 2 inches of water column (500 Pa) and located inside of the condition space, additional sealing shall not be required. REASONS
Reason for 603.9: The 2018 International Mechanical Code has already established that for ducts having a static pressure classification of less than 2 inches of water column that are located in the conditioned space does not need additional closure systems on continuously welded joints and seams and lockingtype joints and seams. However requiring ducts with other types of joints and seams to be sealed that are constructed in accordance with the mechanical code and located in a conditioned space will not see enough of an energy savings to meet the definition of "cost effective" and therefore not statutorily allowed. This exemption is consistent with the Bureau of Construction Codes published 2015 Michigan Residential Code Errors and Conflict document. Additionally to further support this exemption see attached mechanical resolution dated September 7, 2018 that was prepared by a mechanical engineer.
Revised Code of Conduct Proposed
In the matter, on the Commission’s own motion, to promulgate rules
MIACCA's Legislative Committee is currently at work for membership on these important issues::
State of Michigan LARA updates:
The Bureau of Construction Code has updated the Rule Promulgation Process. To review the "Old vs New" process, Click Here
MIACCA Submits public comment on Code of Conduct rules change
An updated version of Code of Conduct rules was approved for all utilities and alternative electric suppliers (AESs) after comments from a public hearing were incorporated (Case No. U-18361). The new rules are intended to prevent cross-subsidization, preferential treatment, and information sharing between a utility’s regulated and unregulated services and programs. They also allow utilities to offer “value-added programs and services” to customers. The rules will be submitted to the Legislative Service Bureau and the Office of Regulatory Reinvention for their formal approvals.
MIACCA asks Michigan Court of Appeals to apply the Michigan Residential Code (MRC) uniformly throughout the State.
On May 31, 2018, attorneys James Bruinsma and Kathleen Bruinsma of McShane & Bowie P.L.C., filed a great brief on behalf of MIACCA pointing out that the Single State Construction Code Act (SSCCA) requires that the MRC must be applied uniformly throughout the state and that local inspectors are not authorized to add or go beyond the code. MIACCA’s brief also pointed out that SSCCA requires that both the local construction board of appeals and the Construction Code Commission must timely hear all appeals within 30 days, and that the Bureau of Construction Codes cannot delay an appeal with administrative procedures.