The following comments have been submitted:
Comment #1Page Number: 21Paragraph / Figure / Table / Note: Table 4.2.2(1) section MComment Intent: ObjectionComment Type: GeneralComment: In our experience from QA of many rating companies across the country, there has been much confusion on duct testing exemptions. Even more confusing is that RESNET 380 does not mention an exemption from duct testing, however the RESNET Board Interpretations still exist on RESNET’s website and it is unclear as to whether they are in effect: http://www.resnet.us/standards/duct_test.pdf Many markets that we work in (either for our own ratings or for external/independent raters) we see unfinished basements, conditioned crawlspaces, and sealed attics. In these cases where ducts qualify for exemption, raters have worked with their builder clients to bring ductwork into conditioned space with one of the benefits being no need to do leakage to outside testing. This change would be of significant impact to those builders and raters. If this is an unintended mistake where the exemption was left out of ANSI 380, then we suggest that a proposal be made to change ANSI 380 to include duct testing exemptions. If the intent is for ANSI 380 to remove duct testing exemptions, then EnergyLogic would like for the Standard Development Committee who is overseeing these revisions to take industry application of the new standards into consideration. EnergyLogic provides QA services across the country for hundreds of raters and we find proper application of duct testing exemptions to be an area of much confusion and inconsistency. We encourage some level of official interpretation to be referenced so that we can consistently apply the standards in our QA activities. Proposed Change: (m) Tested duct leakage shall be determined and documented by an Approved Tester using the protocols equivalent to those specified in Duct leakage shall be tested by an Approved Tester in accordance with requirements of Standard ANSI/RESNET/ICC 380-2016 or equivalent, including RESNET Board Interpretations to Section 803 of the Mortgage Industry National Home Energy Rating Systems Standards by an Approved Tester.
In our experience from QA of many rating companies across the country, there has been much confusion on duct testing exemptions. Even more confusing is that RESNET 380 does not mention an exemption from duct testing, however the RESNET Board Interpretations still exist on RESNET’s website and it is unclear as to whether they are in effect:
http://www.resnet.us/standards/duct_test.pdf
Many markets that we work in (either for our own ratings or for external/independent raters) we see unfinished basements, conditioned crawlspaces, and sealed attics. In these cases where ducts qualify for exemption, raters have worked with their builder clients to bring ductwork into conditioned space with one of the benefits being no need to do leakage to outside testing. This change would be of significant impact to those builders and raters.
If this is an unintended mistake where the exemption was left out of ANSI 380, then we suggest that a proposal be made to change ANSI 380 to include duct testing exemptions. If the intent is for ANSI 380 to remove duct testing exemptions, then EnergyLogic would like for the Standard Development Committee who is overseeing these revisions to take industry application of the new standards into consideration.
EnergyLogic provides QA services across the country for hundreds of raters and we find proper application of duct testing exemptions to be an area of much confusion and inconsistency. We encourage some level of official interpretation to be referenced so that we can consistently apply the standards in our QA activities.
(m) Tested duct leakage shall be determined and documented by an Approved Tester
using the protocols equivalent to those specified in Duct leakage shall be tested by an Approved Tester in
accordance with requirements of Standard ANSI/RESNET/ICC 380-2016 or equivalent, including RESNET Board Interpretations
to Section 803 of the Mortgage Industry National Home Energy Rating Systems
Standards by an Approved Tester.