Proposed MINHERS Addendum 53f, Modifications and Clarifications for Implementation of ANSI/RESNET/ICC 301-2019, Draft PDS-01

Comment #1

Amendment: Proposed MINHERS Addendum 53f, Modifications and Clarifications for Implementation of ANSI/RESNET/ICC 301-2019, Draft PDS-01
Page Number: None Listed
Paragraph / Figure / Table / Note: Table 4.2.2.5.2.11(1) Normative Note
Comment Intent: Not an Objection
Comment Type: General

Comment:

Recommend the following change to the normative note to provide clarity.

 

 

Proposed Change:

Change from:

[1] (Normative Note) A shower with multiple showerheads that operate simultaneously meets the low-flow criteria if the sum of the flow rates of all showerheads is less than or equal to 2.0 gpm.

Change to:

[1] (Normative Note) A shower with multiple showerheads that are controlled using an single mechanism and cannot be operated independently meets the low-flow criteria if the sum of the flow rates of all showerheads is less than or equal to 2.0 gpm.


Comment #2

Amendment: Proposed MINHERS Addendum 53f, Modifications and Clarifications for Implementation of ANSI/RESNET/ICC 301-2019, Draft PDS-01
Page Number: 8-9
Paragraph / Figure / Table / Note: Table 4.2.2(1), note "m"
Comment Intent: Objection
Comment Type: Technical

Comment:

In note (m) to Table 4.2.2(1), I disagree to the 2nd sentence that is being added.
"Where Dwelling Unit Mechanical Ventilation System controls have a standard On/Off switch to enable continuous ventilation, the controls shall only be treated as a Dwelling Unit Mechanical Ventilation System if the system is labeled clearly to identify the purpose of the switch and that the switch be set to “On” to enable Dwelling Unit Mechanical Ventilation"


I disagree that 'labeling' of an On/Off switch should play a role in whether a ventilation fan meets the definition of a 'dwelling unit mechanical ventilation system', as defined in Section 3 of ANSI 301-2019, as amended in Addendum B.  That definition clearly states that a "Dwelling Unit Mechanical Ventilation System" is a "Ventilation system, operating continuously or through a programmed intermittent schedule, consisting of powered Ventilation equipment related mechanical components, and automated control devices that provides Dwelling Unit Ventilation at a known or measured airflow rate."

The key word is "automated".  I would instead support a Normative Note added to the definition of DUMVS, that states clearly that labeling is not sufficient since the requirement is ‘automated’ control, not labeled manual control.

Proposed Change:

Revise ANSI/RESNET/ICC 301-2019 Definitions as Follows:

Bathroom – A room with at least one sink and at least one toilet.

Cooling Load – The quantity of sensible heat that must be removed from the building to keep the space temperature at a specified thermostat setting. The cooling load is independent of the distribution system(s) used to remove heat from the spaces.

Dwelling Unit Mechanical Ventilation System – A Ventilation system, operating continuously or through a programmed intermittent schedule, consisting of powered Ventilation equipment, related mechanical components, and automated# control devices that provides Dwelling Unit Ventilation at a known or measured airflow rate.

## (Normative Note) A switch or thermostat setting, which enables the occupant to turn a system on and off, is not considered automated, continuous, nor programmed. The presence of a ventilation override control is permitted, if the override control is labeled with text or an icon that clearly indicate its function is to turn off the ventilation system.

Revise ANSI/RESNET/ICC 301-2019 Table 4.2.2(1) Note m. as follows:

m. Where Dwelling-Unit Mechanical Ventilation Systems are specified but lack controls to either provide continuous or programmed operation, the system does not qualify as a Dwelling-Unit Mechanical Ventilation System and the Rated Home shall be treated as a Dwelling Unit without a Dwelling-Unit Mechanical Ventilation System. Where Dwelling-Unit Mechanical Ventilation System controls have a standard On/Off switch to enable continuous ventilation, the controls shall only be treated as a Dwelling-Unit Mechanical Ventilation System if the system is labeled clearly to identify the purpose of the switch and that the switch be set to “On” to enable Dwelling-Unit Mechanical Ventilation.


Comment #3

Amendment: Proposed MINHERS Addendum 53f, Modifications and Clarifications for Implementation of ANSI/RESNET/ICC 301-2019, Draft PDS-01
Page Number: 17
Paragraph / Figure / Table / Note: A-1.2
Comment Intent: Objection
Comment Type: Technical

Comment:

While the language being added to the Exception in Appendix A, A-1.2 of ANSI 301-2019, is intended as a clarification in response to an Interpretation Request, it is not adding the clarity it intends. The Committee should fine-tune the sentence to make it easier to understand.

Proposed Change:

Exception: The floor framing cavity insulation shall be permitted to be in contact with the topside of sheathing or continuous insulation installed on the bottom side of floor framing where combined with insulation that meets or exceeds the minimum wood frame wall R-Value in Table 402.1.2 of the International Energy Conservation Code (IECC) and that extends from the bottom to the top of all perimeter floor framing members.  Where the floor perimeter meets an exterior envelope wall, pPerimeter floor insulation is not required to extend vertically from the bottom to the top of framing members that separate the Unconditioned Space Volume of the floor cavity from the Conditioned Space Volume


Comment #4

Amendment: Proposed MINHERS Addendum 53f, Modifications and Clarifications for Implementation of ANSI/RESNET/ICC 301-2019, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: MINHERS 301.2 Scope
Comment Intent: Objection
Comment Type: Technical

Comment:

It is understood that Exception 3 was added to allow rating of units in MF over 3 stories to upload official HERS ratings using current software that implements ANSI 301-2014, given that accredited software that implement ANSI 301-2019 are not available (even at the time of this public comment on 2/28/2021). While the scope of ANSI 301-2014 does not officially include these MFHR units, the ANSI 301-2019 standard that includes them has been available for use since October 2019. Given that multifamily projects that might be ready to upload ratings in 2021 cannot easily accommodate changes in the ERI that may occur when switching software at this late stage, RESNET should consider extending the date from April 1, 2021 to January 1, 2022.  

Proposed Change:

Exception 3: These Standards also apply to Dwelling Units and Sleeping Units in multifamily buildings of any height with a “Date Rated” as reported to the Registry before April 1, 2021January 1, 2022, if they are compliant with RESNET’s Guidelines for Multifamily Energy Ratings.


Return to Proposed MINHERS Addendum 53f, Modifications and Clarifications for Implementation of ANSI/RESNET/ICC 301-2019, Draft PDS-01