Rules Relating to Installation and Location of Natural Gas Alarms

Online comments: 7

• Robert Torbin, PE

  I am submitting comments in conjunction with Eric Crosson of Sparrow Detect, Inc. Mr. Crosson has requested time to make public comments as well.

  Comment attachment
  NYC-RMD-Ordinace-2023.docx

  Comment added November 16, 2023 2:06pm

• Bruce J. Stedman

  I am a lifelong environmentalist, and I write in support of the proposed gas monitoring rule for the city of New York. If passed, the rule would demonstrate to other city and state governments how they can also address this part of the climate crisis. Please review the linked 2022 Standford University study, which shows that methane leaking from stoves inside US homes has the same climate impact as about 500,000 gasoline powered cars. Furthermore, stove leakage exposes people to respiratory disease-triggering pollutants.
  https://news.stanford.edu/2022/01/27/rethinking-cooking-gas/#:~:text=Stanford%20researchers%20estimate%20that%20methane,to%20respiratory%20disease%2Dtriggering%20pollutants.

  These natural gas leaks would be caught by the proposed leak detectors. However, if leak detectors are not monitored, then their batteries will die, and a well-intentioned law will leave nothing but plastic detectors on walls after a year. Natural gas leaks are a silent threat, and the threat of explosion is real. If the city implements this rule, the city should also consider monitored detectors that will alert the residents if the detector becomes disabled or the battery runs out. With changing technology, I am aware that relatively low cost monitored systems exist. Monitoring will safeguard the inhabitants, the planet, and the firefighters who could enter a dangerous, explosive environment.

  The gas detector rule is one of the essential steps that all municipalities should take, but I hope that the city also requires that the gas detectors be monitored.
  Sincerely,
  Bruce J. Stedman

  Comment added November 19, 2023 4:43pm

• Marc Huestis

  As a former senior executive with responsibility for Con Edison’s Gas Operations, I write in support and applaud the NYC Department of Buildings for moving forward with rules to implement LL 157, which was passed in 2016 in the wake of fatal natural gas explosions in the East Harlem and East Village neighborhoods in 2014 and 2015. This initiative will no doubt prevent events and save lives, just like smoke and carbon dioxide detectors have been doing for decades.

  I also commend the Department for integrating the applicable industry standards, UL 1484 and NFPA 715 into this rulemaking. Both are consensus-based standards that reflect the aggregate knowledge and experience of the industry and therefore are not overly influenced by any specific manufacturer that may claim advantages of a specific technology that has yet to be proven in the field at scale. The successful Con Edison mass deployment of more than 200,000 natural gas detectors to date has demonstrated the public safety value of the additional layer of protection provided by natural gas alarms, while generating virtually no false alarms, utilizing UL 1484/UL 2075 compliant technology that can comply with NFPA 715-23.

  I have two specific comments on the proposed rules. One technical comment concerning a conflict in how the applicable industry device manufacturing and installation standards are referenced. The second is allowing for an exception from device installation guidance in NFPA 715-23 and the proposed rule itself, to accommodate physical room size space limitations. The specifics and justification for my comments are provided in the attached document.

  Marc Huestis

  Comment attachment
  LL-157-Final-Comments-on-Proposed-DOB-Rules-11-19-2023.pdf

  Comment added November 19, 2023 10:07pm

• John Rusk

  Hello, my name is John Rusk from the Bronx, and I am the founder of ProSentry, a building monitoring company, and I have taught at Columbia University for the last 15 years. I would like to applaud the DOB for an excellently written rule to implement Local Law 157.

  I would ask the DOB to consider one issue. Currently, the rule allows the gas detectors to be both monitored and unmonitored. I would like you to consider that all natural gas detectors be part of a monitored system.
  Natural gas leaks are invisible and cause serious health problems as well as the potential for loss of life and property. Unfortunately, batteries run out. Nationwide, 37% of fire related deaths are due to dead batteries. But hard-wiring detectors aren’t the answer either. 6% of fire related deaths are the result of hard-wired smoke detectors not alerting because the breaker is tripped. Monitored systems check in numerous times a day to confirm operation and report to the building owner and first responder precisely where the leak is, speeding action. As a result, many states including New York now recognize monitored smoke detectors are equivalent, if not better than hard wired devices.

  Monitored gas detectors are also consistent with likely state legislation: Senator Leroy Comrie of Queens proposed Bill 3705 in 2021 to require monitored gas detectors in all New York State residences both for safety of tenants and first responders, but also so that reports of gas leaks could be made available to the State for review.

  While a monitored system is more expensive to install than simple battery powered devices, a monitored system can be much more cost effective in the long run. When the FDNY responds to a report of a gas leak without the exact apartment, they must slowly travel through the halls with gas detection equipment and if they are unable to identify the source quickly enough, they turn off the building’s gas to safeguard property and lives. The building then runs the risk of a months-long gas shutoff and often hundreds of thousands of dollars of re-piping expense. Monitored systems give the exact location of the leak within a minute to the building’s staff and first responders. They can then go directly to the apartment, turn off the gas valve at the stove, open the window and resolve the situation safely. Monitored systems also allow battery powered, wireless systems that don’t require hard wiring and are relatively low cost for existing buildings as well as new.

  By requiring monitored systems, the city will create the low-cost infrastructure to connect other 10-year battery powered devices to the same system, paving the way for leak detectors that will reduce mold, sense temperature, catch mice, etc. I have separately supplied my whitepaper on this topic: “The Benefits of Using Monitoring for Natural Gas Leak Detectors.”

  If the DOB decides not to require monitored systems, we believe that the rule should at least be modified to follow the New York State Division of Consumer Protection requirements for home smoke detectors that require a 10-year battery or hardwired systems rather than a 1-year battery.

  Monitored gas sensors will save the lives of residents and first responders, mitigate the risk of gas shutdowns, and will likely comply with future New York State gas detection legislation. Thank you.

  Comment attachment
  The-Benefits-of-Monitoring-Natural-Gas-Leaks-01-03-23.pdf

  Comment added November 20, 2023 8:10am

• Conrad McMillan

  I am a landlord in New York, writing in support of the proposed gas leak detection rule. I believe this rule should require all gas monitors to be part of a monitored system with a central station so that I know if the gas detector has been disable or the battery is dead. I am concerned that my tenants may disable the detector or that he battery will run out, risking lives as well as property.

  I am glad to see this technology is finally available and am planning to put in other sensors for water leak detection and mouse traps. Gas leak sensors are an easy add on to this critical service.

  Comment added November 20, 2023 9:25am

• Robert Wilson, Vice President, Special Projects, Northeast Gas Association

  Please see the attached comments of the Northeast Gas Association in the abovementioned matter.

  Thank you.

  Comment attachment
  NYCDOB-Section-908-02-Standards-for-Installation-and-Location-of-Natural-Gas-Alarms-NGA-Comments-Final-11.20.23.pdf

  Comment added November 20, 2023 10:51am

• Ben Saltzman

  Good afternoon. My name is Ben Saltzman, and I am a resident of the Upper West Side in Manhattan.

  As someone who has devoted my life to technology, but with a family and a strong interest in the future, I applaud New York’s City Council Members and the Department of Buildings in their implementation of Local Law 157. I believe it will positively help New Yorker’s as we live in aging infrastructure which we must care for and extend its life while safeguarding our communities. I believe that leaking gas appliances are a threat to New York’s citizens which is often overlooked until health issues or an explosion brings the issue to life. I also see New York as part of a greater ecological environment and while we know that some will cook with gas for the foreseeable future, we wish to limit the climate change affects of natural gas. When burned, natural gas turns into C02 and other harmful indoor pollutants, leaking gas however is not only harmful to those directly exposed, but a much more potent contributor to climate change. See MIT Climate Portal: https://climate.mit.edu/ask-mit/how-much-does-natural-gas-contribute-climate-change-through-co2-emissions-when-fuel-burned#:~:text=And%20those%20leaks%2C%20too%2C%20need,of%20total%20natural%20gas%20production.

  I would ask you to consider revising the bill to require that these detectors are part of a monitored system. This would make sure 1) that the devices are functioning and don’t fall into disrepair 2) that if there is a leak, the proper responders can be notified immediately, whether the building or the fire department with the exact location of the leak so that action can be taken before there is an explosion. 3) I know that Senator Comrie proposed a bill requiring monitored gas detectors (2021-2022 S3705). It would seem silly if the city allowed the installation of non-monitored detectors, and then we had to turn around and install monitored detectors.

  Thank you again to everyone involved in this bill and rulemaking. It’s a great step forward for the city as it implements technology to improve our lives.

  Comment added November 20, 2023 3:25pm