Comment #1Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-01Page Number: 1Paragraph / Figure / Table / Note: PurposeComment Intent: ObjectionComment Type: GeneralComment: Although I think this addendum may be warranted, and I applaud RESNET responsiveness to our new COVID era, I am concerned for two reasons. 1. I believe that this could set a precedent that will come back to undermine the rating industry. If default values are good enough now why not in the future? If a builder or municipality has a historic average leakage rate, why test every home? I strongly believe that you get what you inspect not what you expect. I have seen builder consciously and unconsciously slip away from requirements when testing and inspection stops. Our work as a rater is dependent on inspecting every house. Why develop pathways to limit out ability to inspect and test. 2. Although a RESNET HERS ERI could be developed using default what is to prevent the default from being used for homes that are being tested for code compliance. I believe that the allowance of defaults in the HERS world will be gamed and moved over to the code world without the full knowledge or approval of the jurisdiction. Code is looking for an actual blower door number, for example, not a default. Proposed Change: This is difficult as in Colorado we are still allowed on site to test and inspect. Other parts of the country we are not. I would suggest making is cristal clear that the defaults are ONLY alowed for use when generating a HERS Energy Rating Index and nothing else. I do not believe that is the case currently.
Although I think this addendum may be warranted, and I applaud RESNET responsiveness to our new COVID era, I am concerned for two reasons.
1. I believe that this could set a precedent that will come back to undermine the rating industry. If default values are good enough now why not in the future? If a builder or municipality has a historic average leakage rate, why test every home? I strongly believe that you get what you inspect not what you expect. I have seen builder consciously and unconsciously slip away from requirements when testing and inspection stops. Our work as a rater is dependent on inspecting every house. Why develop pathways to limit out ability to inspect and test. 2. Although a RESNET HERS ERI could be developed using default what is to prevent the default from being used for homes that are being tested for code compliance. I believe that the allowance of defaults in the HERS world will be gamed and moved over to the code world without the full knowledge or approval of the jurisdiction. Code is looking for an actual blower door number, for example, not a default.
This is difficult as in Colorado we are still allowed on site to test and inspect. Other parts of the country we are not. I would suggest making is cristal clear that the defaults are ONLY alowed for use when generating a HERS Energy Rating Index and nothing else. I do not believe that is the case currently.
Comment #2Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-01Page Number: 30Paragraph / Figure / Table / Note: Exception 6Comment Intent: Not an ObjectionComment Type: TechnicalComment: The exception is intended to be a temporary public health/safety provision to address the national emergency caused by the COVID-19 pandemic. It is not intended to be a permanent. The exception needs a sunset date. Proposed Change: Exception 6: RESNET Home Energy Ratings shall comply with the provisions of ANSI/RESNET/ICC 301, except for dwelling units with a rating date on or up to 120 days after the effective date of this amendment established by the RESNET Standards Management Board. Due to the COVID pandemic, dwelling units rated during that time are permitted to use default values in lieu of conducting air tightness testing of dwelling unit enclosures and duct systems as well as measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380. Ratings utilizing default test values must be compliant with RESNET’s Temporary Protocols for Alternative Testing During the COVID-19 Pandemic: Default values by Climate Zone below in table 3.1, OR Default values determined by the Rating Provider for a builder by metro-code area based on past 120 days performance (i.e. measured data from the 120 days immediately preceding the effective date of this exception), OROther default values adopted by program sponsors -such as a building department, a utility program, or a program such as ENERGY STAR - as approved by RESNET. Default Values Table 3.1 CZ CFM per 25 ACH 50 1A 0.032 5.11 2A 0.033 4.91 2B 0.037 4.26 3A 0.036 5.08 3B 0.037 3.90 3C 0.033 3.99 4A 0.034 4.54 4B 0.051 5.00 4C 0.028 3.43 5A 0.033 4.01 5B 0.036 3.21 6A 0.033 3.35 6B 0.026 3.46 7B 0.023 2.99 ? Ventilation Airflow Rate Defaults o Installer-measured and documented ventilation airflow rate -OR- o HVI Rated equipment airflow rates ? Homes with a permit date prior to July 1, 2021 are permitted to use the above default infiltration and duct leakage rates in lieu of conducting an airtightness and/or duct leakage test in accordance with Standard ANSI/RESNET/ICC 380.
The exception is intended to be a temporary public health/safety provision to address the national emergency caused by the COVID-19 pandemic. It is not intended to be a permanent. The exception needs a sunset date.
Exception 6: RESNET Home Energy Ratings shall comply with the provisions of ANSI/RESNET/ICC 301, except for dwelling units with a rating date on or up to 120 days after the effective date of this amendment established by the RESNET Standards Management Board. Due to the COVID pandemic, dwelling units rated during that time are permitted to use default values in lieu of conducting air tightness testing of dwelling unit enclosures and duct systems as well as measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380. Ratings utilizing default test values must be compliant with RESNET’s Temporary Protocols for Alternative Testing During the COVID-19 Pandemic:
Default Values Table 3.1
CFM per 25
? Ventilation Airflow Rate Defaults
o Installer-measured and documented ventilation airflow rate -OR- o HVI Rated equipment airflow rates
? Homes with a permit date prior to July 1, 2021 are permitted to use the above default infiltration and duct leakage rates in lieu of conducting an airtightness and/or duct leakage test in accordance with Standard ANSI/RESNET/ICC 380.
Comment #3Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-01Page Number: 1Comment Intent: Not an ObjectionComment Type: GeneralComment: I have found that the allowable defaults are very conservative and when auditing, the actual test have generally outperformed the defaults. With this in mind, I am in favor of extending the COVID default usage. For my business, it has not only added a critical layer of protection to my verifiers but been critical in keeping my business operating. Although there is a section of the public that couldn't care less...The overwhelming majority of our clients are appreciative of the fact that we do not have to enter and intrude on every room of the home. I have found this to be especially prevalent for the retroactive 45L homes. Without these defaults, I believe the overwhelming majority of client (homeowners and builders alike) would have opted out of pursuing these programs. Proposed Change: no change needed
I have found that the allowable defaults are very conservative and when auditing, the actual test have generally outperformed the defaults. With this in mind, I am in favor of extending the COVID default usage. For my business, it has not only added a critical layer of protection to my verifiers but been critical in keeping my business operating. Although there is a section of the public that couldn't care less...The overwhelming majority of our clients are appreciative of the fact that we do not have to enter and intrude on every room of the home. I have found this to be especially prevalent for the retroactive 45L homes. Without these defaults, I believe the overwhelming majority of client (homeowners and builders alike) would have opted out of pursuing these programs.
no change needed
Comment #4Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: Exception 6, 1st paragraphComment Intent: Not an ObjectionComment Type: EditorialComment: It is not clear how long Exception 6 is valid for. Clarify a sunset date, or be specific about the length of time the exception is allowed, with clear indication of when the exception will be re-evaluated to assess its necessity.
It is not clear how long Exception 6 is valid for. Clarify a sunset date, or be specific about the length of time the exception is allowed, with clear indication of when the exception will be re-evaluated to assess its necessity.
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