Comment #1Amendment: Proposed Standard Amendment on Adoption of ANSI/RESNET/ICC 380-2016Page Number: 19Paragraph / Figure / Table / Note: 207.2.2Comment Intent: Not an ObjectionComment Type: EditorialComment: The proposal is removing a sub-section but neglected to re-number the following sub-section. This is purely an editorial change to ensure the final product is correctly numbered and avoid confusion. Proposed Change: 207.2.2 Determining Conditioned Space Volume 207.2.2.1 Use pressure differential diagnostics to identify intermediate buffer zones including (but not limited to) attics, garages, or crawlspaces. 207.2.2.21 Determine the Conditioned Space Volume of a dwelling unit as defined in Appendix B. Response: Accept Accept as editorial.
The proposal is removing a sub-section but neglected to re-number the following sub-section. This is purely an editorial change to ensure the final product is correctly numbered and avoid confusion.
207.2.2 Determining Conditioned Space Volume
207.2.2.1 Use pressure differential diagnostics to identify intermediate buffer zones including (but not limited to) attics, garages, or crawlspaces.
207.2.2.21 Determine the Conditioned Space Volume of a dwelling unit as defined in Appendix B.
Accept
Accept as editorial.
Comment #2Amendment: Proposed Standard Amendment on Adoption of ANSI/RESNET/ICC 380-2016Page Number: 1Comment Intent: ObjectionComment Type: EditorialComment: Everytime I hear about another way to measure residential home performance it upsets me. It is already so confusing to the general public. We (in the industry) need to agree on one measuring tool that can be standardized across the country. Having a different system for each organization isn't working. I realize this is a territorial thing, but can't we all decide to put that behind us and agree to work together and standardize. It is extremely difficult to keep up with BPI, Resnet, HERS, HES, etc. etc. Proposed Change: I recommend that the HERS rating become the National Standard for measuring residential home performance. Response: Reject This is not a specific comment on Standards 301/380, but on the nature of the home performance industry. The issue raised by the commenter is beyond the scope of the standards revisions under public review.
Everytime I hear about another way to measure residential home performance it upsets me. It is already so confusing to the general public. We (in the industry) need to agree on one measuring tool that can be standardized across the country. Having a different system for each organization isn't working. I realize this is a territorial thing, but can't we all decide to put that behind us and agree to work together and standardize. It is extremely difficult to keep up with BPI, Resnet, HERS, HES, etc. etc.
I recommend that the HERS rating become the National Standard for measuring residential home performance.
Reject
This is not a specific comment on Standards 301/380, but on the nature of the home performance industry. The issue raised by the commenter is beyond the scope of the standards revisions under public review.
Comment #3Amendment: Proposed Standard Amendment on Adoption of ANSI/RESNET/ICC 380-2016Page Number: 117Paragraph / Figure / Table / Note: Definition of Conditioned Floor AreaComment Intent: ObjectionComment Type: TechnicalComment: The definition given of Conditioned Floor Area excludes the floor area of floor cavities. There is no definition of "Floor Cavity" which could reasonably be assumed to mean the floor cavity which is part of the thermal envelope. This means we would be excluding the floor area of rooms over garages, cantilevered floors, floors over unconditioned basements and crawl spaces, etc. which does not make any sense. This also appears to conflict with Appendix A: A-1.4.1.1 which states, "Do include the "footprint" of other protrusions like a cantilever when it includes finished floor area." If this is not what is meant by "Floor Cavity" and what should be excluded, this part of the section needs to be clarified. Proposed Change: Conditioned Floor Area (CFA) The floor area of the Conditioned Space Volume within a building, minus the floor area of attics, floor cavities, crawlspaces, and basements below air sealed and insulated floors. The following specific spaces are addressed to ensure consistent application of this definition: • The floor area of a wall cavity that is Conditioned Space Volume shall be included. • The floor area of a basement shall only be included if the party conducting evaluations has either: o Obtained an ACCA Manual J, S, and either B or D report and verified that both the heating and cooling equipment and distribution system are designed to offset the entire design load of the volume, or, o Verified through visual inspection that both the heating and cooling equipment and distribution system serve the volume and, in the judgment of the party conducting evaluations, are capable of maintaining the heating and cooling temperatures specified by the Thermostat section in Table 4.2.2(1) of ANSI/RESNET/ICC 301-2104. • The floor area of a garage shall be excluded, even when it is conditioned. • The floor area of a thermally isolated sunroom shall be excluded. • The floor area of an attic shall be excluded, even when it is Conditioned Space Volume. • The floor area of a floor cavity shall be excluded, even ifwhen it is Conditioned Space Volume. • The floor area of a crawlspace shall be excluded, even when it is Conditioned Space Volume. Response: Reject For the purposes of this standard, floor cavities are the interstitial spaces in floor assemblies. In other words, floor cavities comprise the space containing the floor structure. Floor cavity areas are not included in CFA because they have already been counted in Conditioned Space Volume, which serves as the basis for determination of Conditioned Space Area. Thus, it would not make sense for floor cavity area to be included in CFA as this would effectively double this floor area.
The definition given of Conditioned Floor Area excludes the floor area of floor cavities. There is no definition of "Floor Cavity" which could reasonably be assumed to mean the floor cavity which is part of the thermal envelope. This means we would be excluding the floor area of rooms over garages, cantilevered floors, floors over unconditioned basements and crawl spaces, etc. which does not make any sense.
This also appears to conflict with Appendix A: A-1.4.1.1 which states, "Do include the "footprint" of other protrusions like a cantilever when it includes finished floor area."
If this is not what is meant by "Floor Cavity" and what should be excluded, this part of the section needs to be clarified.
Conditioned Floor Area (CFA)
The floor area of the Conditioned Space Volume within a building, minus the floor area of attics, floor cavities, crawlspaces, and basements below air sealed and insulated floors. The following specific spaces are addressed to ensure consistent application of this definition:
• The floor area of a wall cavity that is Conditioned Space Volume shall be included. • The floor area of a basement shall only be included if the party conducting evaluations has either: o Obtained an ACCA Manual J, S, and either B or D report and verified that both the heating and cooling equipment and distribution system are designed to offset the entire design load of the volume, or, o Verified through visual inspection that both the heating and cooling equipment and distribution system serve the volume and, in the judgment of the party conducting evaluations, are capable of maintaining the heating and cooling temperatures specified by the Thermostat section in Table 4.2.2(1) of ANSI/RESNET/ICC 301-2104. • The floor area of a garage shall be excluded, even when it is conditioned. • The floor area of a thermally isolated sunroom shall be excluded. • The floor area of an attic shall be excluded, even when it is Conditioned Space Volume. • The floor area of a floor cavity shall be excluded, even ifwhen it is Conditioned Space Volume. • The floor area of a crawlspace shall be excluded, even when it is Conditioned Space Volume.
For the purposes of this standard, floor cavities are the interstitial spaces in floor assemblies. In other words, floor cavities comprise the space containing the floor structure. Floor cavity areas are not included in CFA because they have already been counted in Conditioned Space Volume, which serves as the basis for determination of Conditioned Space Area. Thus, it would not make sense for floor cavity area to be included in CFA as this would effectively double this floor area.
Comment #4Amendment: Proposed Standard Amendment on Adoption of ANSI/RESNET/ICC 380-2016Page Number: 117Paragraph / Figure / Table / Note: Definition of Conditioned Floor AreaComment Intent: ObjectionComment Type: TechnicalComment: The procedure in Appendix A for measuring conditioned floor area, A-1.4.1.1 includes, "Use exterior measurements; those measurements should start at the exterior finished surface of the outside wall." The new definition of Conditioned Floor Area includes, "The floor area of the Conditioned Space Volume within a building" and "The floor area of a wall cavity that is Conditioned Space Volume shall be included." However, the new definition of Conditioned Space Volume excludes wall cavities that are part of the thermal envelope. This means that the new definition of CFA conflicts with Appendix A and that interior measurements should be used instead of exterior measurements. From a field work point of view, it is much less time-consuming to use exterior measurements as we have in the past. However, argument could be made that systems are not intended to condition the envelope walls and many codes now exclude these walls as approved places to run duct work, so the change to conditioned volume may be needed. This does not need to impact the CFA however. The bottom line is that the standards need to be made consistent; so either Appendix A needs to change or the new definition of Conditioned Floor Area needs to change. Proposed Change: Conditioned Floor Area (CFA) The floor area of the Conditioned Space Volume within a building, minus the floor area of attics, floor cavities, crawlspaces, and basements below air sealed and insulated floors and plus the floor area of wall cavities between Conditioned Space Volume and Unconditioned Space Volume. The following specific spaces are addressed to ensure consistent application of this definition: • The floor area of a wall cavity that is Conditioned Space Volume shall be included. The floor area of a wall cavity that is between Conditioned Space Volume and Unconditioned Space Volume shall be included. Response: Reject The basis for the comment is incorrect – the definition of Conditioned Space Volume does not exclude wall cavities that are part of the thermal envelope. From the definition of Conditioned Space Volume: If the volume of one or both of the spaces horizontally adjacent to a wall cavity meets this definition, then the volume of the wall cavity shall also be included. Otherwise, the volume of the wall cavity shall be excluded. The basic definition of Conditioned Space Volume is: “The volume within a building serviced by a space heating or cooling system designed to maintain space conditions at 78 °F (26 °C) for cooling and 68 °F (20 °C) for heating.”. Therefore an exterior wall that has conditioned space on one side is included in Conditioned Space Volume. The basic definition for Conditioned Floor Area is the floor area of the Conditioned Space Volume. Because these exterior wall cavities are included in the Conditioned Space Volume, their floor area is also included in the Conditioned Floor Area. Note that RESNET Standard 380 is currently being revised to help clarify these definitions.
The procedure in Appendix A for measuring conditioned floor area, A-1.4.1.1 includes, "Use exterior measurements; those measurements should start at the exterior finished surface of the outside wall." The new definition of Conditioned Floor Area includes, "The floor area of the Conditioned Space Volume within a building" and "The floor area of a wall cavity that is Conditioned Space Volume shall be included." However, the new definition of Conditioned Space Volume excludes wall cavities that are part of the thermal envelope. This means that the new definition of CFA conflicts with Appendix A and that interior measurements should be used instead of exterior measurements.
From a field work point of view, it is much less time-consuming to use exterior measurements as we have in the past. However, argument could be made that systems are not intended to condition the envelope walls and many codes now exclude these walls as approved places to run duct work, so the change to conditioned volume may be needed. This does not need to impact the CFA however. The bottom line is that the standards need to be made consistent; so either Appendix A needs to change or the new definition of Conditioned Floor Area needs to change.
The floor area of the Conditioned Space Volume within a building, minus the floor area of attics, floor cavities, crawlspaces, and basements below air sealed and insulated floors and plus the floor area of wall cavities between Conditioned Space Volume and Unconditioned Space Volume. The following specific spaces are addressed to ensure consistent application of this definition: • The floor area of a wall cavity that is Conditioned Space Volume shall be included.
The floor area of a wall cavity that is between Conditioned Space Volume and Unconditioned Space Volume shall be included.
The basis for the comment is incorrect – the definition of Conditioned Space Volume does not exclude wall cavities that are part of the thermal envelope.
From the definition of Conditioned Space Volume:
The basic definition of Conditioned Space Volume is: “The volume within a building serviced by a space heating or cooling system designed to maintain space conditions at 78 °F (26 °C) for cooling and 68 °F (20 °C) for heating.”. Therefore an exterior wall that has conditioned space on one side is included in Conditioned Space Volume. The basic definition for Conditioned Floor Area is the floor area of the Conditioned Space Volume. Because these exterior wall cavities are included in the Conditioned Space Volume, their floor area is also included in the Conditioned Floor Area.
Note that RESNET Standard 380 is currently being revised to help clarify these definitions.
Comment #5Amendment: Proposed Standard Amendment on Adoption of ANSI/RESNET/ICC 380-2016Page Number: 117Paragraph / Figure / Table / Note: Definition of Conditioned Floor AreaComment Intent: ObjectionComment Type: TechnicalComment: In my previous comment I neglected to include ambient air in my proposed definition so left out part of the building envelope. I use the term "outside" to be consistent with the definition of "Building Envelope" in the standard. This is a modification to Comment #4. Proposed Change: Conditioned Floor Area (CFA) The floor area of the Conditioned Space Volume within a building, minus the floor area of attics, floor cavities, crawlspaces, and basements below air sealed and insulated floors and plus the floor area of wall cavities between Conditioned Space Volume and Unconditioned Space Volume or outside. The following specific spaces are addressed to ensure consistent application of this definition: • The floor area of a wall cavity that is Conditioned Space Volume shall be included. The floor area of a wall cavity that is between Conditioned Space Volume and Unconditioned Space Volume or outside shall be included. Response: Reject Comment #5 is a continuation/update to comment #4 and shares the same issue: the comment is incorrect on the issue of wall cavities between conditioned and unconditioned space. They are included in CSV and CFA. Note that RESNET Standard 380 is currently being revised to help clarify these definitions.
In my previous comment I neglected to include ambient air in my proposed definition so left out part of the building envelope. I use the term "outside" to be consistent with the definition of "Building Envelope" in the standard. This is a modification to Comment #4.
The floor area of the Conditioned Space Volume within a building, minus the floor area of attics, floor cavities, crawlspaces, and basements below air sealed and insulated floors and plus the floor area of wall cavities between Conditioned Space Volume and Unconditioned Space Volume or outside. The following specific spaces are addressed to ensure consistent application of this definition:
• The floor area of a wall cavity that is Conditioned Space Volume shall be included.
Comment #5 is a continuation/update to comment #4 and shares the same issue: the comment is incorrect on the issue of wall cavities between conditioned and unconditioned space. They are included in CSV and CFA.
Comment #6Amendment: Proposed Standard Amendment on Adoption of ANSI/RESNET/ICC 380-2016Page Number: no page numbers I seeParagraph / Figure / Table / Note: 804 Reference StandardsComment Intent: ObjectionComment Type: TechnicalComment: Many of the referenced standards do not have a year or version number. A referenced standard should alway have a version or year. For example Section 804 Referenced Standards. It references: ASHRAE Standard 62.2 Ventilation and Acceptable Indoor Air Quality in Low-Rise Residential Buildings, published by the American Society of Heating, Refrigerating and Air-conditioning Engineers, Inc., http://www.ashrae.org But the reference does not include a year. Since RESNET is moving away from the latest ASHRAE 62.2-2013 ventilation rate back to the ASHRAE 62.2-2010 rate it is both important to make the reference complete and to get the right ventilation rate. Proposed Change: Add dates or version numbers to all referenced standards. Response: Reject Reason: This section of the MINHERS standard is not being reviewed under this ballot. We will endeavor to add reference years to this section in the future.
Many of the referenced standards do not have a year or version number. A referenced standard should alway have a version or year.
For example Section 804 Referenced Standards. It references:
ASHRAE Standard 62.2 Ventilation and Acceptable Indoor Air Quality in Low-Rise Residential Buildings, published by the American Society of Heating, Refrigerating and Air-conditioning Engineers, Inc., http://www.ashrae.org
But the reference does not include a year. Since RESNET is moving away from the latest ASHRAE 62.2-2013 ventilation rate back to the ASHRAE 62.2-2010 rate it is both important to make the reference complete and to get the right ventilation rate.
Add dates or version numbers to all referenced standards.
Reason: This section of the MINHERS standard is not being reviewed under this ballot. We will endeavor to add reference years to this section in the future.
Comment #7Amendment: Proposed Standard Amendment on Adoption of ANSI/RESNET/ICC 380-2016Page Number: I don't see a page numberParagraph / Figure / Table / Note: 302 DefinitionsComment Intent: ObjectionComment Type: GeneralComment: RESNET either follows iANSI/RESNET/ICC 380-2016 and iANSI/RESNET/ICC 301- 2014, or it does not. If RESNET says its other documents govern instead of these ANSI standards then RESNET should not claim to use the ANSI standards. Proposed Change: 302 Definitions The following terms have specific meanings as used in this Standard. In the event that definitions given here differ from definitions given elsewhere, including those given in ANSI/RESNET/ICC 301- 2014, the definitions given here shall govern. Where definitions given here differ from referenced ANSI standards, the definitions in ANSI standard shall govern. [Note: Alternately the last sentence could list the ANSI standards referenced in this document.] Response: Reject Reason: The standard can refer to other standards without adopting them in their entirety – including definitions. It is perfectly acceptable for MINHERS to have its own definitions for its own purposes.
RESNET either follows iANSI/RESNET/ICC 380-2016 and iANSI/RESNET/ICC 301- 2014, or it does not. If RESNET says its other documents govern instead of these ANSI standards then RESNET should not claim to use the ANSI standards.
302 Definitions The following terms have specific meanings as used in this Standard. In the event that definitions given here differ from definitions given elsewhere, including those given in ANSI/RESNET/ICC 301- 2014, the definitions given here shall govern. Where definitions given here differ from referenced ANSI standards, the definitions in ANSI standard shall govern.
[Note: Alternately the last sentence could list the ANSI standards referenced in this document.]
Reason: The standard can refer to other standards without adopting them in their entirety – including definitions. It is perfectly acceptable for MINHERS to have its own definitions for its own purposes.
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