The following comments have been submitted:
Comment #1Page Number: 16Paragraph / Figure / Table / Note: 4.4.2. Duct Leakage to Outside TestComment Intent: ObjectionComment Type: TechnicalComment: Duct leakage TO OUTSIDE test results are meaningless on homes where all ducts are inside conditioned space and left exposed. (For example, Ducts are all inside an unfinished basement with insulated walls.) In this specific circumstance, the leakier the ducts are, the better the test result will be. (try it yourself on your next test of this type of home. rip open some of your tape to simulate a leakier duct system, the leakage to outside number will show and improvement.) Therefore I suggest language be added to discourage reliance on leakage to outside testing numbers on homes of this type. Proposed Change: Duct leakage to outside test This test is only suitable for ducts that are isolated in some way from the typical pressure boundary of the home. If the majority of the ductwork is inside conditioned space and remain visible to they eye. This test is not reliable. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Duct leakage TO OUTSIDE test results are meaningless on homes where all ducts are inside conditioned space and left exposed. (For example, Ducts are all inside an unfinished basement with insulated walls.)
In this specific circumstance, the leakier the ducts are, the better the test result will be. (try it yourself on your next test of this type of home. rip open some of your tape to simulate a leakier duct system, the leakage to outside number will show and improvement.)
Therefore I suggest language be added to discourage reliance on leakage to outside testing numbers on homes of this type.
Duct leakage to outside test
This test is only suitable for ducts that are isolated in some way from the typical pressure boundary of the home. If the majority of the ductwork is inside conditioned space and remain visible to they eye. This test is not reliable.
Reject
The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Comment #2Page Number: 1Paragraph / Figure / Table / Note: 3.1Comment Intent: ObjectionComment Type: TechnicalComment: 1. section 3.1 under Equipment where the "equipment shall be tested annualy for calibration" in the case of equipment that has a longer period of calibration this statement is incorrect. Proposed Change: 3.1. Equipment The equipment listed in this section shall be tested annually per manufacturers specification for calibration using the manufacturer’s recommended calibration procedure. Response: Accpect in Principle Alternate new language: 3.1. Equipment The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration procedure. The equipment listed in this section shall have their calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.
1. section 3.1 under Equipment where the "equipment shall be tested annualy for calibration" in the case of equipment that has a longer period of calibration this statement is incorrect.
3.1. Equipment The equipment listed in this section shall be tested annually per manufacturers specification for calibration using the manufacturer’s recommended calibration procedure.
Accpect in Principle
Alternate new language:
3.1. Equipment The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration procedure. The equipment listed in this section shall have their calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.
Comment #3Page Number: 2-3Paragraph / Figure / Table / Note: 3.2.1 and 3.2.5Comment Intent: ObjectionComment Type: TechnicalComment: Sections 3.2.1 and 3.2.5 leave it somewhat vague what to do with unconditoined basements. Depending what is intended, I suggest two changes below: Proposed Change: If the intention is for unconditioned basements to be closed to ambient AND the house above, section 3.2.1 should say "Doors and windows located in conditioned and unconditioned spaces shall be closed and latched". OR If the intention is for an unconditoined basement to be opened to the outdoors and thus not included in the airtightness of the house, section 3.2.5 should read: " All doors between basements and Conditioned SpaceVolume shall be opened unless thehouse floor above the basement is air sealed and insulated, in which case the door between the basement and Conditioned Space Volume shall be closed and a door or window between the basment and outdoors shall be opened. The position of the basement doors shall be recorded. If the door to the basement is closed, the basement shall beexcluded from Infiltration Volume and Conditioned Floor Area. Response: Reject The intent is that all basement doors and windows to outside be closed and doors to inside be opened. As stated in the text.
Sections 3.2.1 and 3.2.5 leave it somewhat vague what to do with unconditoined basements. Depending what is intended, I suggest two changes below:
If the intention is for unconditioned basements to be closed to ambient AND the house above, section 3.2.1 should say "Doors and windows located in conditioned and unconditioned spaces shall be closed and latched".
OR
If the intention is for an unconditoined basement to be opened to the outdoors and thus not included in the airtightness of the house, section 3.2.5 should read: "
All doors between basements and Conditioned SpaceVolume shall be opened unless thehouse floor above the basement is air sealed and insulated, in which case the door between the basement and Conditioned Space Volume shall be closed and a door or window between the basment and outdoors shall be opened. The position of the basement doors shall be recorded. If the door to the basement is closed, the basement shall beexcluded from Infiltration Volume and Conditioned Floor Area.
The intent is that all basement doors and windows to outside be closed and doors to inside be opened. As stated in the text.
Comment #4Page Number: 2Paragraph / Figure / Table / Note: 3.1Comment Intent: ObjectionComment Type: TechnicalComment: Existing: The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration procedure. Proposed: The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration periods and procedures. Manufacturers may specifiy periods less than annually or greater than annually for specific pieces of equipment. Those with periods less than annually should be followed. If a manufacturer has specificed a period longer than annually, it should also be allowed. If a manufacturer specifies field calibration procedures to be used for periodic checks those should also be followed. Response: Accept in Principle The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration procedure. The equipment listed in this section shall have their calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.
Existing:
The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration procedure.
Proposed:
The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration periods and procedures.
Manufacturers may specifiy periods less than annually or greater than annually for specific pieces of equipment. Those with periods less than annually should be followed.
If a manufacturer has specificed a period longer than annually, it should also be allowed. If a manufacturer specifies field calibration procedures to be used for periodic checks those should also be followed.
Accept in Principle
The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration procedure. The equipment listed in this section shall have their calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.
Comment #5Page Number: 19Paragraph / Figure / Table / Note: 5.0Comment Intent: Not an ObjectionComment Type: GeneralComment: No where in the standard is it specified 'who' will follow these procedures. It is implied that the Rater will conduct all tests following these procedures. Some vendors of European Heat Recovery Ventilators have them installed and testing by an employee of the manufacturer. Some may just test the system and verify correct operation after installation by others. Other equipment manufacturers, not limited to recovery ventilation, may offer this service in the future. The lack of a specified person to conduct these tests makes this murky and open to all types of interpretation. I would recommend adding a sub section 2.2: 2.2 Persons conducting these procedures: 2.2.1 The HERS Rater 2.2.2 The manufacturer when the installation and verifcation is performed subject to the sales contractor for that equipment. The HERS Rater shall be present during such verification procedures, conducted by manufacturers representative(s). The written verification report from the manufacturers representative shall be dated and signed by the person(s) conducting the verification test(s). This report shall become part of the Ratings File and subject to all quality assurance activities. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
No where in the standard is it specified 'who' will follow these procedures.
It is implied that the Rater will conduct all tests following these procedures.
Some vendors of European Heat Recovery Ventilators have them installed and testing by an employee of the manufacturer. Some may just test the system and verify correct operation after installation by others.
Other equipment manufacturers, not limited to recovery ventilation, may offer this service in the future.
The lack of a specified person to conduct these tests makes this murky and open to all types of interpretation.
I would recommend adding a sub section 2.2:
2.2 Persons conducting these procedures:
2.2.1 The HERS Rater
2.2.2 The manufacturer when the installation and verifcation is performed subject to the sales contractor for that equipment. The HERS Rater shall be present during such verification procedures, conducted by manufacturers representative(s). The written verification report from the manufacturers representative shall be dated and signed by the person(s) conducting the verification test(s). This report shall become part of the Ratings File and subject to all quality assurance activities.
Comment #6Page Number: MutipleParagraph / Figure / Table / Note: CalibrationComment Intent: ObjectionComment Type: EditorialComment: The language used in section 3.1 Equipment, should be used in all sectons dealing with calibration.The addition of at least is not needed. "The equipment listed in this section shall be tested annually for calibration using the manufacturer’s calibration procedure" vs. "The equipment below shall be tested at least annually for calibration using the manufacturer’s calibration procedure" Proposed Change: "The equipment listed in this section shall be tested annually for calibration using the manufacturer’s calibration procedure" Response: Accept in Principle The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration procedure. The equipment listed in this section shall have their calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.
The language used in section 3.1 Equipment, should be used in all sectons dealing with calibration.The addition of at least is not needed.
"The equipment listed in this section shall be tested annually for calibration using the manufacturer’s calibration procedure"
vs.
"The equipment below shall be tested at least annually for calibration using the manufacturer’s calibration procedure"
Comment #7Page Number: 21Paragraph / Figure / Table / Note: 5.2.2. Bag Inflation DeviceComment Intent: ObjectionComment Type: TechnicalComment: This section should be removed. It is the equivilant of using a butane lighter to determine Low E coatings on windows. The repeatibility of the test from one tester to another is questionable. I have searched repeatedly and have been unable to find anything other than an article in Home Energy Magazine on the procedure. http://www.homeenergy.org/show/article/id/59 It states: "Field testing of bags on 30 registers in three houses resulted in biases of –5% and RMS differences of 11% (see “Assessing the Precision of Bags and Baskets”)." "Because the bag filling tests require the user to interpret when the bag filling starts and stops,we wanted to look at variability from user to user. Five people (three researchers, a homeowner, and the homeowner’s son—none of whom had any previous experience with this measurement technique) measured the same grille three times. Each person was given simple instructions on how to perform the test and observed an experienced researcher perform the test. Each person then performed the test three times, and each individual’s measurements were then averaged.The five averaged flows fell in a narrow range between 61 and 64 CFM.Compared to the reference flow measurement, there was an RMS error of only 4%." Note, they used the same set up bewteen testers. There are to many variables between one tester using a different bag type, frame type, and ability to "Interpret when the bag filling starts and stops" to be able to include this as a repeatble method, if the event of litigation. A posting on the RESNET website states: "If the bag sides flap a lot and measuring the same register twice gives results that differ by more than 20%, then try a bag with thicker material." http://www.resnet.us/blog/wp-content/uploads/formidable/Ventilation-presentation_BER_2014.pdf How can you include a method without calibration accuarcy. The other methods require instrumant calibration accuracy of +/- 5% or +/- 1%. I can see the attorneys having a field day with trash bags in front of a jury. Proposed Change: Remove section. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
This section should be removed. It is the equivilant of using a butane lighter to determine Low E coatings on windows. The repeatibility of the test from one tester to another is questionable. I have searched repeatedly and have been unable to find anything other than an article in Home Energy Magazine on the procedure.
http://www.homeenergy.org/show/article/id/59 It states: "Field testing of bags on 30 registers in three houses resulted in biases of –5% and RMS differences of 11% (see “Assessing the Precision of Bags and Baskets”)."
"Because the bag filling tests require the user to interpret when the bag filling starts and stops,we wanted to look at variability from user to user. Five people (three researchers, a homeowner, and the homeowner’s son—none of whom had any previous experience with this measurement technique) measured the same grille three times. Each person was given simple instructions on how to perform the test and observed an experienced researcher perform the test. Each person then performed the test three times, and each individual’s measurements were then averaged.The five averaged flows fell in a narrow range between 61 and 64 CFM.Compared to the reference flow measurement, there was an RMS error of only 4%."
Note, they used the same set up bewteen testers. There are to many variables between one tester using a different bag type, frame type, and ability to "Interpret when the bag filling starts and stops" to be able to include this as a repeatble method, if the event of litigation.
A posting on the RESNET website states: "If the bag sides flap a lot and measuring the same register twice gives results that differ by more than 20%, then try a bag with thicker material."
http://www.resnet.us/blog/wp-content/uploads/formidable/Ventilation-presentation_BER_2014.pdf
How can you include a method without calibration accuarcy. The other methods require instrumant calibration accuracy of +/- 5% or +/- 1%. I can see the attorneys having a field day with trash bags in front of a jury.
Remove section.
Comment #8Page Number: 11Paragraph / Figure / Table / Note: 3.5Comment Intent: ObjectionComment Type: TechnicalComment: The standard states that only multi-point test results can be used for Home Energy Ratings or assessing compliance unless the result is multiplied by 1.1. However, there are two additional testing methods that provide results that are as accurate or more accurate than a multi-point test: 1. Repeated single-point test: The repeated single point test is at least as accurate as a multi-point test. In fact, due to the fact that the baseline is taken multiple times, the results are more accurate than a multi-point test that relies on a single baseline. You should indicate the number of repeated single-point tests that can be used to eliminate the 1.1 factor. This should be in the range of 3-5. 2. Longer term average tests: In this method, the baseline is taken over a long period of time, such as 3 minutes, and the test result is also taken over a long period time such as 3 minutes. This method is often used for testing large buildings. The long average periods for baseline and at test pressure result in a far more accurate result than a standard single point test and also more accuracy than a standard multi-point test due to the long-term averages. The methods above provide equal or greater accuracy than the multi-point test and allow equipment that is currently standard in the industry to be used. By making multi-point testing the only way to avoid the 1.1 multiplier to test results, significant upgrades to testing equipment will be required without producing greater accuracy. For example, the standard blower door with gauge set-up (for example, Energy Conservatory BD3 with DG700) for single-family homes does not perform multi-point testing. Also, the stanard set-up for multifamily building (for example, Energy Conservatory BD3, DG700, and the TecLog software) does not perform multi-point testing. I propose that repeated single-point tests and long-term average tests be allowed for compliance testing and HERS testing without a 1.1 multiplier. Proposed Change: 3.5.1. If the results of the building enclosure airleakage test are to be used forconducting a home energy rating or assessing complian ce with a buildingenclosure leakage limit (e.g., defined by code or by an energy efficiency program), then thecorrected airflow determined using a one point test shall be... Unless the one point test is repeated at least 3 times and the result averaged or the one point test baseline pressure is average at least 2 minutes and the test result is averaged at least 2 minutes. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
The standard states that only multi-point test results can be used for Home Energy Ratings or assessing compliance unless the result is multiplied by 1.1. However, there are two additional testing methods that provide results that are as accurate or more accurate than a multi-point test:
1. Repeated single-point test: The repeated single point test is at least as accurate as a multi-point test. In fact, due to the fact that the baseline is taken multiple times, the results are more accurate than a multi-point test that relies on a single baseline. You should indicate the number of repeated single-point tests that can be used to eliminate the 1.1 factor. This should be in the range of 3-5.
2. Longer term average tests: In this method, the baseline is taken over a long period of time, such as 3 minutes, and the test result is also taken over a long period time such as 3 minutes. This method is often used for testing large buildings. The long average periods for baseline and at test pressure result in a far more accurate result than a standard single point test and also more accuracy than a standard multi-point test due to the long-term averages.
The methods above provide equal or greater accuracy than the multi-point test and allow equipment that is currently standard in the industry to be used. By making multi-point testing the only way to avoid the 1.1 multiplier to test results, significant upgrades to testing equipment will be required without producing greater accuracy. For example, the standard blower door with gauge set-up (for example, Energy Conservatory BD3 with DG700) for single-family homes does not perform multi-point testing. Also, the stanard set-up for multifamily building (for example, Energy Conservatory BD3, DG700, and the TecLog software) does not perform multi-point testing.
I propose that repeated single-point tests and long-term average tests be allowed for compliance testing and HERS testing without a 1.1 multiplier.
Comment #9Page Number: 26Paragraph / Figure / Table / Note: Definition of Infiltration VolumeComment Intent: ObjectionComment Type: TechnicalComment: If the access hatches for sealed attics are supposed to be opened for blower door tests, then the sealed attic space SHOULD be part of the Infiltration Volume! Excluding Vented attics would make more sense. Also, I've included language to address some sealed attic scenarios where there may be no access doors or hatches within the dwelling, e.g. access is via the attached garage or from the exterior via the gable end. Proposed Change: Infiltration Volume – The sum of the Conditioned Space Volume and Unconditioned Space Volume in the dwelling unit, minus the volume of: Floor cavities that have Unconditioned Space Volume both above and below, Unconditioned wall cavities, Attics that are vented, or attics that are air sealed and insulated at the roof deck and which have no access doors and hatches to open within the dwelling during enclosure air leakage testing (Section 3.2.4). Vented crawlspaces, Garages, Basements, if the door between the basement and Conditioned Space Volume is closed during enclosure air leakage testing (Section 3.2.5), and, Thermally isolated sunrooms. Response: Accept in Principle No attic spaces should be part of the infiltration volume - the text has been changed to reflect this. Infiltration volume is used to convert from measured CFM50 or ELA to ACH and is not used directly in the energy calculations for a RESNET rating, but is used to confirm compliance with other codes and standards. In order not to bias ACH50 values in favor of large attic volumes the attic volume is not included in infiltration volume. For testing, if the attic is sealed, then any access between the house and attic should be open.
No attic spaces should be part of the infiltration volume - the text has been changed to reflect this. Infiltration volume is used to convert from measured CFM50 or ELA to ACH and is not used directly in the energy calculations for a RESNET rating, but is used to confirm compliance with other codes and standards. In order not to bias ACH50 values in favor of large attic volumes the attic volume is not included in infiltration volume. For testing, if the attic is sealed, then any access between the house and attic should be open.
Comment #10Page Number: 25Paragraph / Figure / Table / Note: Definition of Conditioned Floor AreaComment Intent: ObjectionComment Type: TechnicalComment: This should reference ANSI-Z765, or at least the definition in ANSI-RESNET 301. If the basement is finished, it clearly is intended to be conditioned living space even in the absence of Man J, S, & D analyses. Perhaps limit this exclusion to be "the floor area of an unfinished basement..." If the attic is finished, it clearly is intended to be conditioned living space, and the floor area should be included. The exclusion should be directed at all unfinished attics. 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, and crawlspaces, and basements below air sealed and insulated floors. For more detail, see definition in ANSI-RESNET 301-2014. 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 it is finished space, or the Rater has obtained a Manual J, S, and 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. The floor area of a garage shall be excluded, even if it is conditioned. The floor area of a thermally isolated sunroom shall be excluded. The floor area of an unfinished attic shall be excluded, even if it is Conditioned Space Volume. The floor area of a floor cavity shall be excluded, even if it is Conditioned Space Volume. The floor area of a crawlspace shall be excluded, even if it is Conditioned Space Volume. Response: Accept in Principle One goal of the committee in drafting standard 380 was to develop more objective, rather than subjective, definitions to ensure consistent application of the standard. With that said, the committee understands that obtaining a manual j, s, and d report is not standard practice today for raters and that it may be appropriate to add an alternative compliance option for basements that is based upon finishes. To address the comment, the definition for conditioned floor area and conditioned space volume will be modified by adding the following option for basements: "verified through visual inspection that the basement is an enclosed area that is suitable for year-round use, employing wall, floor, and ceiling finishes that are similar to the rest of the house."
This should reference ANSI-Z765, or at least the definition in ANSI-RESNET 301.
Conditioned Floor Area (CFA) –The floor area of the Conditioned Space Volume within a building, minus the floor area of attics, floor cavities, and crawlspaces, and basements below air sealed and insulated floors. For more detail, see definition in ANSI-RESNET 301-2014. The following specific spaces are addressed to ensure consistent application of this definition:
One goal of the committee in drafting standard 380 was to develop more objective, rather than subjective, definitions to ensure consistent application of the standard. With that said, the committee understands that obtaining a manual j, s, and d report is not standard practice today for raters and that it may be appropriate to add an alternative compliance option for basements that is based upon finishes. To address the comment, the definition for conditioned floor area and conditioned space volume will be modified by adding the following option for basements: "verified through visual inspection that the basement is an enclosed area that is suitable for year-round use, employing wall, floor, and ceiling finishes that are similar to the rest of the house."
Comment #11Page Number: 25Paragraph / Figure / Table / Note: Definition of Conditioned Space VolumeComment Intent: ObjectionComment Type: TechnicalComment: The temperature definition for being Conditioned Space is overly specific. The heating and cooling temperatures should be given example ranges, not specific temperatures. Perhaps a blending of HERS and IECC setpoint defaults would be more appropriate. Also, the volume of a finished attic should be included in the Conditioned Space Volume. Finally, a grammatical edit: "... an attic this that is air sealed..." Proposed Change: Conditioned Space Volume -The volume within abuilding serviced by a space heating or cooling system designed to maintain space conditions at around 75-78 °F (24-26 °C) for cooling and 68-70 °F (20-21 °C) for heating. The following specific spaces are addressed to ensure consistent application of this definition: If the volume both above and below a floor cavity meets this definition, then the volume of the floor cavity shall also be included. Otherwise the volume of the floor cavity shall be excluded. 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 volume of an attic that is not air sealed and insulated at the roof deck shall be excluded. The volume of a vented crawlspace shall be excluded. The volume of a garage shall be excluded, even if it is conditioned. The volume of a thermally isolated sunroom shall be excluded. The volume of a finished attic shall be included. The volume of an attic thatthis is air sealed and insulated at the roof deck, an unvented crawlspace, or a basement shall only be included if the Rater has obtained a Manual J, S, and 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. Response: Reject The definition is OK as is. The definition is talking about design temperatures, and is consistent with RESNET 301, rather than if a system actually maintains temperatures at one fixed degree Fahrenheit number.
The temperature definition for being Conditioned Space is overly specific. The heating and cooling temperatures should be given example ranges, not specific temperatures. Perhaps a blending of HERS and IECC setpoint defaults would be more appropriate.
Also, the volume of a finished attic should be included in the Conditioned Space Volume.
Finally, a grammatical edit: "... an attic this that is air sealed..."
Conditioned Space Volume -The volume within abuilding serviced by a space heating or cooling system designed to maintain space conditions at around 75-78 °F (24-26 °C) for cooling and 68-70 °F (20-21 °C) for heating. The following specific spaces are addressed to ensure consistent application of this definition:
The definition is OK as is. The definition is talking about design temperatures, and is consistent with RESNET 301, rather than if a system actually maintains temperatures at one fixed degree Fahrenheit number.
Comment #12Page Number: 26Paragraph / Figure / Table / Note: Definition of Unconditioned Space VolumeComment Intent: ObjectionComment Type: TechnicalComment: These clarifications relate to edits I've proposed in preceding comments. The last bullet should specify unfinished attics and unfinished basements. -------------------------------------------- Please note, I should have added an edit to Conditioned Space Volume that The volume of a finished basement shall be included. Proposed Change: Unconditioned Space Volume -The volume within a building that is not Conditioned Space Volume but which may contain heat sources or sinks that influence the temperature of the area or room. The following specific spaces are addressed to ensure consistent application of this definition: The volume of a floor cavity shall be included, unless the volume both above and below the floor cavity meets the definition of Conditioned Space Volume. The volume of a wall cavity shall be included, unless the wall cavity meets the definition of Conditioned Space Volume. The volume of a vented attic shall be included. The volume of a vented crawlspace shall be included. The volume of a garage shall be included, even if it is conditioned. The volume of a thermally isolated sunroom shall be included. The volume of an unfinished attic sealed and insulated at the roof deck, an unvented crawlspace, or an unfinished basement shall be included unless it meets the definition of Conditioned Space Volume. Response: Reject Because it is difficult to define furnished vs. unfinished space, the standard will use definitions referring to location of air seal and insulation.
These clarifications relate to edits I've proposed in preceding comments.
The last bullet should specify unfinished attics and unfinished basements.
--------------------------------------------
Please note, I should have added an edit to Conditioned Space Volume that
Unconditioned Space Volume -The volume within a building that is not Conditioned Space Volume but which may contain heat sources or sinks that influence the temperature of the area or room. The following specific spaces are addressed to ensure consistent application of this definition:
Because it is difficult to define furnished vs. unfinished space, the standard will use definitions referring to location of air seal and insulation.
Comment #13Page Number: 24Paragraph / Figure / Table / Note: DefinitionsComment Intent: Not an ObjectionComment Type: GeneralComment: The usage of Pressure Station is unfamiliar to me. Based on long experience, I can guess what it means, but it should be explicitly defined. Proposed Change: Pressure Station -- A pressure point during a multipoint Airtightness test at which the fan flow rate is measured. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
The usage of Pressure Station is unfamiliar to me. Based on long experience, I can guess what it means, but it should be explicitly defined.
Pressure Station -- A pressure point during a multipoint Airtightness test at which the fan flow rate is measured.
Comment #14Page Number: 18Paragraph / Figure / Table / Note: Informative NoteComment Intent: ObjectionComment Type: TechnicalComment: This should not be restricted to central exhaust systems. I have encountered central supply systems which deliver ventilation air within the dwelling unit, not via the corridor. Proposed Change: 4 Informative Note: Measuring the ventilation air supplied to corridors of multifamily buildings is beyond the scope of this standard. However, measuring the flow rate of supply or exhaust systems used for whole house ventilation in individual dwelling units is within the scope of this standard. Response: accept It is in an informative note so this change has been made.
This should not be restricted to central exhaust systems. I have encountered central supply systems which deliver ventilation air within the dwelling unit, not via the corridor.
4 Informative Note: Measuring the ventilation air supplied to corridors of multifamily buildings is beyond the scope of this standard. However, measuring the flow rate of supply or exhaust systems used for whole house ventilation in individual dwelling units is within the scope of this standard.
accept
It is in an informative note so this change has been made.
Comment #15Page Number: 17Paragraph / Figure / Table / Note: 4.4.2.10Comment Intent: Not an ObjectionComment Type: EditorialComment: I think the reference to Equation 11 did not get updated when PDS-02 was renumbered. I believe it should be Equation 10. Proposed Change: 4.4.2.10. If an induced enclosure pressure difference of 25 Pa(0.10in. H2O)was not achieved or a different value was used to achieve an induced duct system pressure difference of 0.0 Pa(0.0 in. H2O), then the recorded airflow(CFMmeasured,CMSmeasured)shall be converted to a nominal airflowat 25 Pa(0.10in. H2O)(CFM25,CMS25) using Equation 1011. Alternately, a Manometerthat is equipped to automatically make the conversion to CFM25 or CMS25 is permitted to be used. Response: Accept Editorial
I think the reference to Equation 11 did not get updated when PDS-02 was renumbered. I believe it should be Equation 10.
4.4.2.10. If an induced enclosure pressure difference of 25 Pa(0.10in. H2O)was not achieved or a different value was used to achieve an induced duct system pressure difference of 0.0 Pa(0.0 in. H2O), then the recorded airflow(CFMmeasured,CMSmeasured)shall be converted to a nominal airflowat 25 Pa(0.10in. H2O)(CFM25,CMS25) using Equation 1011. Alternately, a Manometerthat is equipped to automatically make the conversion to CFM25 or CMS25 is permitted to be used.
Accept
Editorial
Comment #16Page Number: 17Paragraph / Figure / Table / Note: 4.4.2.10Comment Intent: Not an ObjectionComment Type: EditorialComment: I think the reference to Equation 11 did not get updated when PDS-02 was renumbered. I believe it should be Equation 10. Proposed Change: 4.4.2.10. If an induced enclosure pressure difference of 25 Pa(0.10in. H2O)was not achieved or a different value was used to achieve an induced duct system pressure difference of 0.0 Pa(0.0 in. H2O), then the recorded airflow(CFMmeasured,CMSmeasured)shall be converted to a nominal airflowat 25 Pa(0.10in. H2O)(CFM25,CMS25) using Equation 1011. Alternately, a Manometerthat is equipped to automatically make the conversion to CFM25 or CMS25 is permitted to be used. Response: Accept Duplicate of comment 15.
Duplicate of comment 15.
Comment #17Page Number: 6Paragraph / Figure / Table / Note: 3.4.1.5Comment Intent: ObjectionComment Type: TechnicalComment: Two issues: (1) In 3.4.1.5 the term "Corrected CFM50" excludes the SI units also sharing this standard. Suggest including "Corrected CMS50" in parentheses after Corrected CFM50. (2) While I applaud referencing appropriate standards, in this case more explanation is needed. Section 9 of ASTM E779-10 adjustments are predicated on a multipoint test which generates the Air Leakage Coefficient C. A single point test does not provide this value. Instead, I recommend referencing Equation 4 of that standard, with advice to substitute flowrate Q in place of C. Proposed Change: 3.4.1.5. The airflow at 50 Pa shall be corrected for altitude and temperature to determine the corrected airflow at 50 Pa using the calculations in Section 9 of ASTM E779-101, resulting in the term Corrected CFM50 (Corrected CMS50). Specifically, use Eq 4 of that standard, substituting flowrate Q in place of C. Response: Accept in principle We will add (corrected CMS50) in parentheses and change wording to be more precise about using Equation 4 and Annex A1 from the ASTM standard.
3.4.1.5. The airflow at 50 Pa shall be corrected for altitude and temperature to determine the corrected airflow at 50 Pa using the calculations in Section 9 of ASTM E779-101, resulting in the term Corrected CFM50 (Corrected CMS50). Specifically, use Eq 4 of that standard, substituting flowrate Q in place of C.
Accept in principle
We will add (corrected CMS50) in parentheses and change wording to be more precise about using Equation 4 and Annex A1 from the ASTM standard.
Comment #18Page Number: 2Paragraph / Figure / Table / Note: 3.2.5. BasementsComment Intent: ObjectionComment Type: TechnicalComment: Needs clarification for finished basements. Some finished basements have insulated & finished ceiling, with the insulation intended for acoustic reasons. Finished basements should remain part of the Conditioned Space Volume, CFA and the Infiltration Volume. Proposed Change: 3.2.5. Basements. All doors between basements and Conditioned Space Volume shall be opened unless the house floor above the basement is air sealed and insulated, in which case the door between the basement and Conditioned Space Volume shall be closed. In all cases, all doors between finished basements and the rest of Conditioned Space Volume shall be opened. The position of the basement doors shall be recorded. If the door to the basement is closed, the basement shall be excluded from Infiltration Volume and Conditioned Floor Area. Response: Reject If there is insulation for acoustic reasons, but no air sealing then the door to the basement would be open. Determining if the basement is conditioned or not does not depend on the finish in the basement but on the location of the air and insulation boundary.
Needs clarification for finished basements.
Some finished basements have insulated & finished ceiling, with the insulation intended for acoustic reasons. Finished basements should remain part of the Conditioned Space Volume, CFA and the Infiltration Volume.
3.2.5. Basements. All doors between basements and Conditioned Space Volume shall be opened unless the house floor above the basement is air sealed and insulated, in which case the door between the basement and Conditioned Space Volume shall be closed. In all cases, all doors between finished basements and the rest of Conditioned Space Volume shall be opened. The position of the basement doors shall be recorded. If the door to the basement is closed, the basement shall be excluded from Infiltration Volume and Conditioned Floor Area.
If there is insulation for acoustic reasons, but no air sealing then the door to the basement would be open. Determining if the basement is conditioned or not does not depend on the finish in the basement but on the location of the air and insulation boundary.
Comment #19Page Number: 2Paragraph / Figure / Table / Note: 3.2.4. Attics.Comment Intent: ObjectionComment Type: TechnicalComment: If the access to a Sealed attic is outside the dwelling, as in an attached garage or at the gable end of the attic, that access should not be opened for the airtightness test. My proposed revision to the definition of Infiltration Volume would help handle this, in conjunction with the revised language below. Proposed Change: 3.2.4. Attics. Attic access doors and hatches shall be closed unless the attic is part of the Infiltration Volumeair sealed and insulated at the roofdeck, in which case the access doors and hatches located within the dwelling's Conditioned Space Volume shall be opened. The position of the attic access doors and hatches shall be recorded. Exterior access doors, dampers, or vents shall be left in their as-found position and their position shall be recorded on the test report. Response: Reject The proposed edits do little to improve clarity, if at all. The doors separating the attic from the house may or may not be separating the attic from Conditioned Space Volume, so the proposed edits could potentially add more confusion. Also, the next sentence in the definition already states that "Exterior access doors, dampers, or vents, shall be left in their as-found position..". This conveys the intent pretty clearly already.
If the access to a Sealed attic is outside the dwelling, as in an attached garage or at the gable end of the attic, that access should not be opened for the airtightness test. My proposed revision to the definition of Infiltration Volume would help handle this, in conjunction with the revised language below.
3.2.4. Attics. Attic access doors and hatches shall be closed unless the attic is part of the Infiltration Volumeair sealed and insulated at the roofdeck, in which case the access doors and hatches located within the dwelling's Conditioned Space Volume shall be opened. The position of the attic access doors and hatches shall be recorded. Exterior access doors, dampers, or vents shall be left in their as-found position and their position shall be recorded on the test report.
The proposed edits do little to improve clarity, if at all. The doors separating the attic from the house may or may not be separating the attic from Conditioned Space Volume, so the proposed edits could potentially add more confusion. Also, the next sentence in the definition already states that "Exterior access doors, dampers, or vents, shall be left in their as-found position..". This conveys the intent pretty clearly already.
Comment #20Page Number: 1Paragraph / Figure / Table / Note: 3. Procedure for Measuring Airtightness of ____ EnclosureComment Intent: Not an ObjectionComment Type: EditorialComment: Given that this standard is including Multifamily housing in its scope, it would be better to reference the Dwelling Enclosure rather than the Building Enclosure in the context of airtightness testing. The adopted RESNET Guidelines for Multifamily Energy Ratings clearly limits ratings to dwelling units rather than whole multifamily buildings. Proposed Change: 3. Procedure for Measuring Airtightness of Building Dwelling Enclosure Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication
Given that this standard is including Multifamily housing in its scope, it would be better to reference the Dwelling Enclosure rather than the Building Enclosure in the context of airtightness testing. The adopted RESNET Guidelines for Multifamily Energy Ratings clearly limits ratings to dwelling units rather than whole multifamily buildings.
3. Procedure for Measuring Airtightness of Building Dwelling Enclosure
The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication
Comment #21Page Number: 1Paragraph / Figure / Table / Note: 3.1. EquipmentComment Intent: ObjectionComment Type: GeneralComment: Not all equipment is recommended for annual calibration per the manufacturer. I suggest following the manufacturer's recommendation. Proposed Change: The equipment listed in this section shall be tested annually (or at the manufacturer's recommended interval) for calibration using the manufacturer’s recommended calibration procedure. Response: Accept in Principle The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration procedure. The equipment listed in this section shall have their calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.
The equipment listed in this section shall be tested annually (or at the manufacturer's recommended interval) for calibration using the manufacturer’s recommended calibration procedure.
Comment #22Page Number: 2Paragraph / Figure / Table / Note: 3.1.5. Blower DoorComment Intent: Not an ObjectionComment Type: TechnicalComment: As noted earlier, given the multifamily context included in the scope, this should reference the dwelling opening, not the building opening. Similar references should be updated throughout the draft standard. Proposed Change: 3.1.5. Blower Door. A device that combines an Air-Moving Fan as defined in Section 3.1.1, an Airflow Meter as defined in Section 3.1.3, and a covering to integrate the Air-Moving Fan into the buildingdwelling opening. Response: Reject Multi-family issues For clarity and uniformity throughout the standard the term "building" is used. The proposed change will be considered in the future when the standard is revised to better address multi-family issues.
As noted earlier, given the multifamily context included in the scope, this should reference the dwelling opening, not the building opening. Similar references should be updated throughout the draft standard.
3.1.5. Blower Door. A device that combines an Air-Moving Fan as defined in Section 3.1.1, an Airflow Meter as defined in Section 3.1.3, and a covering to integrate the Air-Moving Fan into the buildingdwelling opening.
Multi-family issues
For clarity and uniformity throughout the standard the term "building" is used. The proposed change will be considered in the future when the standard is revised to better address multi-family issues.
Comment #23Page Number: 2Paragraph / Figure / Table / Note: 3.2. Procedure to Prepare the Building for TestingComment Intent: ObjectionComment Type: TechnicalComment: As noted previously, by including multifamily in the scope, the standard should reference "Dwelling" rather than "Building" in most if not all instances. Proposed Change: 3.2. Procedure to Prepare the BuildingDwelling for Testing Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
As noted previously, by including multifamily in the scope, the standard should reference "Dwelling" rather than "Building" in most if not all instances.
3.2. Procedure to Prepare the BuildingDwelling for Testing
Comment #24Page Number: 3Paragraph / Figure / Table / Note: 3.2.6.Comment Intent: ObjectionComment Type: TechnicalComment: Given the inclusion of Multifamily in the scope of this draft standard, the relevant details of the Adopted RESNET Guidelines for Multifamily Energy Ratings should be incorporated. Insert 3.2.6 Multifamily Dwellings after 3.2.5 Basements, and renumber subsequent sections as needed. Taken from RESNET MF Working Group guidance for Compartmentalization Test procedure. Proposed Change: 3.2.6. Multifamily Dwellings. Adjacent spaces shall be connected to the outside. The objective is to connect the adjacent spaces to the outside, either through opening windows in the adjacent spaces or connecting the corridor to outside and then connecting the adjacent spaces to the corridor. For the purposes of this test, adjacent spaces shall include the spaces immediately abutting the target dwelling unit in the horizontal plane, but does not need to include spaces abutting the target dwelling unit in the vertical plane. Instead of opening spaces to the outside, the induced pressure difference between the target dwelling unit and the adjacent spaces can be measured during the test to verify that adjacent spaces are close to outside pressure. Doors and/or windows do not need to be opened in adjacent spaces if the induced pressure difference between the target dwelling unit and the adjacent space is equal to or greater than 90% of the induced pressure difference between the target dwelling unit and outside. For example, 45 Pascal between the target dwelling unit and the adjacent space at a target unit induced pressure of 50 Pascal with respect to outside. 3.2.6.1 MF Dwelling Access Panels. Any access panels to interstitial spaces in the target dwelling unit shall be opened during the test. For top floor dwelling units, access panels can be closed where the access panel is part of the exterior enclosure air barrier assembly. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Given the inclusion of Multifamily in the scope of this draft standard, the relevant details of the Adopted RESNET Guidelines for Multifamily Energy Ratings should be incorporated.
Comment #25Page Number: 3Paragraph / Figure / Table / Note: 3.2.9. Fans.Comment Intent: ObjectionComment Type: TechnicalComment: The requirement to turn off fans in adjacent multifamily units is perhaps unnecessary, given requirement to open adjacent dwelling units to exterior pressures (open windows, etc.) as specified in the Adopted RESNET Guidelines for Multifamily Energy Ratings. Or, the standard should also require whole-MF-building systems be turned off that might be affecting pressures of interstitial spaces. This would be counter to the MF Working Group guidance in the following insertion. Insert 3.2.9.1, from MF Guidance: Proposed Change: 3.2.9.1. MF Central Ventilation Fans. A continuously operating central ventilation system serving multiple dwelling units does not need to be turned off as long as taping select dwelling unit registers will not compromise the system and the sealed registers remain sealed during the test. Response: Reject The current language is compatible with the MF requirements mentioned in the comment. However, the commenter raises a good point about addressing multi-family issues that we plan to deal with in future changes to the standard.
3.2.9.1. MF Central Ventilation Fans. A continuously operating central ventilation system serving multiple dwelling units does not need to be turned off as long as taping select dwelling unit registers will not compromise the system and the sealed registers remain sealed during the test.
The current language is compatible with the MF requirements mentioned in the comment. However, the commenter raises a good point about addressing multi-family issues that we plan to deal with in future changes to the standard.
Comment #26Page Number: 4Paragraph / Figure / Table / Note: 3.2.11.3.Comment Intent: ObjectionComment Type: TechnicalComment: Again, drawing from Adopted RESNET Guidelines for Multifamily Energy Ratings, I propose the following exception to 3.2.11.3. Proposed Change: 3.2.11.3. Non-dampered ventilation openings of continuously operating local exhaust ventilation systems (e.g., bathroom or kitchen exhaust) that connect the Conditioned Space Volume to the exterior or to Unconditioned Space Volume shall be sealed, preferably at the exterior of the enclosure. Exception: When the continuously-operating exhaust ventilation system is a shared MF central system, non-dampered exhaust-air openings of continuously operating central mechanical ventilation systems shall instead be sealed at the dwelling unit grilles. The central system does not need to be shut down as long as taping select grilles will not compromise the system and the sealed grilles remain sealed during the test. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Again, drawing from Adopted RESNET Guidelines for Multifamily Energy Ratings, I propose the following exception to 3.2.11.3.
3.2.11.3. Non-dampered ventilation openings of continuously operating local exhaust ventilation systems (e.g., bathroom or kitchen exhaust) that connect the Conditioned Space Volume to the exterior or to Unconditioned Space Volume shall be sealed, preferably at the exterior of the enclosure.
Exception: When the continuously-operating exhaust ventilation system is a shared MF central system, non-dampered exhaust-air openings of continuously operating central mechanical ventilation systems shall instead be sealed at the dwelling unit grilles. The central system does not need to be shut down as long as taping select grilles will not compromise the system and the sealed grilles remain sealed during the test.
Comment #27Page Number: 4Paragraph / Figure / Table / Note: 3.2.11.4.Comment Intent: ObjectionComment Type: TechnicalComment: Drawing on the Adopted RESNET Guidelines for Multifamily Energy Ratings, should this have clarification about which openings qualify as being part of continuously operating ventilation system? This was controversial within the MF Working Group's Performance Testing subgroup. Example: when builder uses continuous bath exhaust paired with undampered fresh air duct connected to space conditioning air handler return, wherein the bath exhaust is considered the dominant fresh air ventilation device (and the air handler has no controls to meet the standard for consistent fresh air ventilation). Also, it is generally impractical to seal these ducts on MF building exterior, and they are often inaccessible from the interior. In any case, add exception from MF Working Group guidance: Proposed Change: 3.2.11.4. Non-dampered ventilation openings of continuously operating whole-house ventilation systems that connect the Conditioned Space Volume to the exterior or to Unconditioned Space Volume shall be sealed, preferably at the exterior of the enclosure. Exception: When the continuously-operating whole-dwelling ventilation system is a shared MF central system, non-dampered openings of continuously operating central mechanical ventilation systems shall instead be sealed at the dwelling unit registers. The central system does not need to be shut down as long as taping select registers will not compromise the system and the sealed registers remain sealed during the test. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Drawing on the Adopted RESNET Guidelines for Multifamily Energy Ratings, should this have clarification about which openings qualify as being part of continuously operating ventilation system? This was controversial within the MF Working Group's Performance Testing subgroup. Example: when builder uses continuous bath exhaust paired with undampered fresh air duct connected to space conditioning air handler return, wherein the bath exhaust is considered the dominant fresh air ventilation device (and the air handler has no controls to meet the standard for consistent fresh air ventilation).
Also, it is generally impractical to seal these ducts on MF building exterior, and they are often inaccessible from the interior.
3.2.11.4. Non-dampered ventilation openings of continuously operating whole-house ventilation systems that connect the Conditioned Space Volume to the exterior or to Unconditioned Space Volume shall be sealed, preferably at the exterior of the enclosure.
Exception: When the continuously-operating whole-dwelling ventilation system is a shared MF central system, non-dampered openings of continuously operating central mechanical ventilation systems shall instead be sealed at the dwelling unit registers. The central system does not need to be shut down as long as taping select registers will not compromise the system and the sealed registers remain sealed during the test.
Comment #28Page Number: 4Paragraph / Figure / Table / Note: 3.2.14. Operable window trickle-vents and through-the-wall vents.Comment Intent: ObjectionComment Type: TechnicalComment: The adopted RESNET Guidelines for Multifamily Energy Ratings specified a little more for clarity: Proposed Change: 3.2.14. Operable window trickle-vents and through-the-wall vents. Operable window trickle-vents and through-the-wall vents (e.g. passive air intakes) shall be closed, but not sealed. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
The adopted RESNET Guidelines for Multifamily Energy Ratings specified a little more for clarity:
3.2.14. Operable window trickle-vents and through-the-wall vents. Operable window trickle-vents and through-the-wall vents (e.g. passive air intakes) shall be closed, but not sealed.
Comment #29Page Number: 4-5Paragraph / Figure / Table / Note: 3.3.1. The Blower Door shall be installed...Comment Intent: ObjectionComment Type: TechnicalComment: Strike the last sentence of this paragraph, which is addressed by new section 3.2.6 and instead create new paragraph 3.3.1.1, with MF Guidance from RESNET MF Working Group guidance, 802.4.1.2: Proposed Change: 3.3.1. The Blower Doorshall be installed in an exterior doorway or window that has an unrestricted air pathway into the building and no obstructions to airflow within five feet of the fan inlet and two feet of the fan outlet. The opening that is chosen shall be noted on the test report. If possible, the system shall not be installed in a doorway or window exposed to wind. It is permissible to use a doorway or window between the Conditioned Space Volume and an Unconditioned Space Volume as long as the Unconditioned Space Volume has an unrestricted air pathway to the outdoors and all operable exterior windows and doors of the Unconditioned Space Volume are opened to the outdoors. For multifamily dwelling units, if the main entry door is in an interior hallway then the hallway shall be well connected to outside through open windows or doors, or an exterior window or door (e.g.,leading to a deck or patio) shall be used. 3.3.1.1. Entry doors to dwelling units in multifamily residential buildings shall not be used for the blower door installation in Airtightness compartmentalization tests unless the threshold is designed and adjusted to block airflow, comparable to an exterior door threshold. Exception 1: The entry door opening may be used if the normal open area between the closed entry door and threshold is measured, recorded, and duplicated by opening a window to create an air leak of equivalent area. Airtightness compartmentalization test shall be conducted with the added leak, which serves as proxy for the entry door threshold leak. i. Vertical gaps shall be estimated visually using a tape measure or ruler and rounding down to the nearest 1/8”. Exception 2: Alternatively, the entry door opening may be used if the Corrected CFM50 blower door results are transformed to ELA (Effective Leakage Area), and the threshold leak area (documented as above in Exception 1) is added to the ELA. The resulting sum shall be treated as the temperature & altitude corrected compartmentalization test result. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Strike the last sentence of this paragraph, which is addressed by new section 3.2.6 and instead create new paragraph 3.3.1.1, with MF Guidance from RESNET MF Working Group guidance, 802.4.1.2:
3.3.1. The Blower Doorshall be installed in an exterior doorway or window that has an unrestricted air pathway into the building and no obstructions to airflow within five feet of the fan inlet and two feet of the fan outlet. The opening that is chosen shall be noted on the test report. If possible, the system shall not be installed in a doorway or window exposed to wind. It is permissible to use a doorway or window between the Conditioned Space Volume and an Unconditioned Space Volume as long as the Unconditioned Space Volume has an unrestricted air pathway to the outdoors and all operable exterior windows and doors of the Unconditioned Space Volume are opened to the outdoors. For multifamily dwelling units, if the main entry door is in an interior hallway then the hallway shall be well connected to outside through open windows or doors, or an exterior window or door (e.g.,leading to a deck or patio) shall be used.
3.3.1.1. Entry doors to dwelling units in multifamily residential buildings shall not be used for the blower door installation in Airtightness compartmentalization tests unless the threshold is designed and adjusted to block airflow, comparable to an exterior door threshold.
Comment #30Page Number: 5Paragraph / Figure / Table / Note: 3.3.2. Tubing shall be...Comment Intent: ObjectionComment Type: TechnicalComment: Additional clarification from the Adopted RESNET Guidelines for Multifamily Energy Ratings. Proposed Change: 3.3.2. Tubing shall be installed to measure the difference in pressure between the enclosure and the outdoors in accordance with manufacturer’s instructions. The tubing, especially vertical sections, shall be positioned out of direct sunlight. The end of the reference tube must be located where it is not impacted by the turbulence created by the fan. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Additional clarification from the Adopted RESNET Guidelines for Multifamily Energy Ratings.
3.3.2. Tubing shall be installed to measure the difference in pressure between the enclosure and the outdoors in accordance with manufacturer’s instructions. The tubing, especially vertical sections, shall be positioned out of direct sunlight. The end of the reference tube must be located where it is not impacted by the turbulence created by the fan.
Comment #31Page Number: 12Paragraph / Figure / Table / Note: 4. Procedure for Measuring Airtightness of Duct SystemsComment Intent: ObjectionComment Type: TechnicalComment: Drawing from the work of the RESNET MF Working Group, there is no need to restrict the placement of the blower door to the main entry of the unit, as long as the outer side of the blower door is facing outdoor pressure conditions. Proposed Change: 4. Procedure for Measuring Airtightness of Duct Systems In addition to the test procedures in this section, test method A from ASTM E1554-13 is approved for use provided that the building and duct system preparation procedures in Section 4.2 of this standard are followed. The leakage to outside test shall be performed using a Blower Door in the main entry to the unit installed as specified in section 3.3.1 for the Airtightness Test to pressurize the individual unit with reference to outside. If the main entry doorBlower Door is in an interior hallway then the hallway shall be well connected to outside through open windows or doors,or an exterior window or door (such as to deck or patio) shall be used. Only the ducts in the home being tested shall be included in the air leakage test. Response: Reject The recommended change does not clearly improve clarity of the standard.
Drawing from the work of the RESNET MF Working Group, there is no need to restrict the placement of the blower door to the main entry of the unit, as long as the outer side of the blower door is facing outdoor pressure conditions.
4. Procedure for Measuring Airtightness of Duct Systems
In addition to the test procedures in this section, test method A from ASTM E1554-13 is approved for use provided that the building and duct system preparation procedures in Section 4.2 of this standard are followed.
The leakage to outside test shall be performed using a Blower Door in the main entry to the unit installed as specified in section 3.3.1 for the Airtightness Test to pressurize the individual unit with reference to outside. If the main entry doorBlower Door is in an interior hallway then the hallway shall be well connected to outside through open windows or doors,or an exterior window or door (such as to deck or patio) shall be used. Only the ducts in the home being tested shall be included in the air leakage test.
The recommended change does not clearly improve clarity of the standard.
Comment #32Page Number: 12Paragraph / Figure / Table / Note: 4. Procedure for Measuring Airtightness of Duct SystemsComment Intent: ObjectionComment Type: TechnicalComment: Apologies, I missed an additional edit at the end of this section in my last comment. At end of the last sentence of the section, add from RESNET MF WG guidance, pp 46-47: Proposed Change: 4. Procedure for Measuring Airtightness of Duct Systems In addition to the test procedures in this section, test method A from ASTM E1554-13 is approved for use provided that the building and duct system preparation procedures in Section 4.2 of this standard are followed. The leakage to outside test shall be performed using a Blower Door in the main entry to the unit installed as specified in section 3.3.1 for the Airtightness Test to pressurize the individual unit with reference to outside. If the main entry doorBlower Door is in an interior hallway then the hallway shall be well connected to outside through open windows or doors,or an exterior window or door (such as to deck or patio) shall be used. Only the ducts in the home being tested shall be included in the air leakage test. Duct Airtightness Testing Exception: When the sum of all duct lengths connected to a thermal conditioning component (except evaporative coolers) serving occupiable space is less than or equal to 10 ft. in length, those ducts are not required to be tested for any duct leakage (to the outside or total), unless any portion of the system (ductwork or air handler) is located in unconditioned space. When measuring supply duct length, 10 ft. is measured from the source to the register(s), including all supply trunks and branches. The 10 ft. is a total system allowance, and not the allowance for each supply run. Multifamily Dwelling Unit Exception for Duct Airtightness Testing to Outside: Testing of duct leakage to outside the dwelling unit may be skipped, and zero duct leakage to the outside modeled, if all three of the following conditions are true. The dwelling unit unguarded blower door test (compartmentalization test) demonstrates leakage no greater than 0.30 CFM50/ft2 of enclosure area. If a passive outdoor air ventilation duct is connected to the return side of the space conditioning duct system, an automatically-controlled mechanical damper must close off the outdoor air when there is no call for ventilation. This damper must be installed even for continuous ventilation strategies, such that if the power goes off, the damper closes. The entire duct system, including the manufacturer’s air handler enclosure, is within the dwelling unit’s tested pressure boundary during the dwelling unit blower door test. Note: If the duct leakage results are to be used for assessing compliance with a dwelling unit duct leakage limit (e.g., defined by code or by an energy efficiency program), application of this exception may not be appropriate unless approved by the local code official or program administrator. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Apologies, I missed an additional edit at the end of this section in my last comment.
Comment #33Page Number: 14-15Paragraph / Figure / Table / Note: 4.2.7.2. Non-dampered ventilation openings...Comment Intent: ObjectionComment Type: TechnicalComment: The MF Working Group specified these shall not be sealed. In part, this choice is based on lack of accessibility for sealing. The exterior opening is frequently inaccessible in MF buildings (away from balconies, multiple stories above the ground), and some (such as ducts connected to the return side of the air handler) are not accessible from inside. Proposed Change: 4.2.7.2. Non-dampered ventilation openings of continuously operating whole-house ventilation systems that connect the Conditioned Space Volume (including space conditioning duct systems) to the exterior or to Unconditioned Space Volume shall be sealed, preferably at the exterior of the enclosure. Exception: Such openings in multifamily dwelling units shall not be sealed, due to general lack of accessibility for doing so. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
The MF Working Group specified these shall not be sealed. In part, this choice is based on lack of accessibility for sealing. The exterior opening is frequently inaccessible in MF buildings (away from balconies, multiple stories above the ground), and some (such as ducts connected to the return side of the air handler) are not accessible from inside.
4.2.7.2. Non-dampered ventilation openings of continuously operating whole-house ventilation systems that connect the Conditioned Space Volume (including space conditioning duct systems) to the exterior or to Unconditioned Space Volume shall be sealed, preferably at the exterior of the enclosure.
Exception: Such openings in multifamily dwelling units shall not be sealed, due to general lack of accessibility for doing so.
Comment #34Page Number: 14Paragraph / Figure / Table / Note: 4.3. Exception 2Comment Intent: ObjectionComment Type: TechnicalComment: Exception 2 should reference the test pressure, i.e. 25 Pa. Also, from the RESNET MF Working Group guidance pp45-46, add Exception 3. Proposed Change: (under section 4.3. Procedure to Install Test Apparatus and Prepare for Airtightness Test) Exception 2: If the total duct leakage is less than 50 cfm (25 L/s) at 25 Pa then either method may be used. Exception 3: When a mechanical closet and/or any peripheral cavities are being used as return paths back to the air handler, the Duct Leakage Tester shall be attached to ensure these spaces are included in the duct airtightness test, i.e. Method 1 shall be applied to the grille leading into the mechanical closet or furr-down. Any building cavity plenums – ceiling, wall, floor – being used to direct air from the conditioned space to these mechanical areas must be left open to the mechanical area. Transfer grilles in the conditioned space leading to these ancillary plenums shall be sealed off. In this scenario, Method 2 may only be used if all of the following three criteria are met: A larger opening than manufacturer’s minimum return grille free area sizing is installed AND the pressure difference between the mechanical area and the conditioned space <= 3 Pa with the air handler running at high speed AND there shall be an induced pressure difference between the mechanical area and the conditioned space of less than 10% of the induced pressure difference with respect to outside. Response: Accept in Principle The editorial addition of "at 25 Pa" is reasonable. The other section will not be changed as it is not part of the draft revision changes.
Exception 2 should reference the test pressure, i.e. 25 Pa.
Also, from the RESNET MF Working Group guidance pp45-46, add Exception 3.
(under section 4.3. Procedure to Install Test Apparatus and Prepare for Airtightness Test)
Exception 2: If the total duct leakage is less than 50 cfm (25 L/s) at 25 Pa then either method may be used.
The editorial addition of "at 25 Pa" is reasonable. The other section will not be changed as it is not part of the draft revision changes.
Comment #35Page Number: 1Comment Intent: Not an ObjectionComment Type: GeneralComment: This is a general comment that encompasses the entire document and is a request that wherever applicable the RESNET Multi-Family Guidelines be interpreted and incorporated into the text of the standard. The Multi-Family Guidelines should be incorporated because a large percentage of the ratings being issued are for multi-family units. It is just as important for a rater to know how to test these units as a single family home. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
This is a general comment that encompasses the entire document and is a request that wherever applicable the RESNET Multi-Family Guidelines be interpreted and incorporated into the text of the standard.
The Multi-Family Guidelines should be incorporated because a large percentage of the ratings being issued are for multi-family units. It is just as important for a rater to know how to test these units as a single family home.
Comment #36Page Number: 2Comment Intent: ObjectionComment Type: TechnicalComment: Section 3.1.3 sets the airflow measuring device accuracy deviation limit at 5%. In Section 5.2.2.1.1 the text states tht the bag inflation device should be used three times at each outlet and the results compared. If they are within 20% of each other the readings are considered acceptable. This is not consistent with being within 5% of the actual flow. This method does not appear to be repeatable even by the same person on the same day. In Section 5.3.1.1 the text states that the airflow measurement station has to be accurate within 10% of the actual airflow. This is not consistent with the limits set in Section 3.1.3. Proposed Change: Strike Section 5.2.2 or expand 3.1.3 to 20% rather than 5%. Strike Section 5.3 or expand 3.1.3 to 10% (if you go to 20% keep Section 5.3). Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Section 3.1.3 sets the airflow measuring device accuracy deviation limit at 5%.
In Section 5.2.2.1.1 the text states tht the bag inflation device should be used three times at each outlet and the results compared. If they are within 20% of each other the readings are considered acceptable. This is not consistent with being within 5% of the actual flow. This method does not appear to be repeatable even by the same person on the same day.
In Section 5.3.1.1 the text states that the airflow measurement station has to be accurate within 10% of the actual airflow. This is not consistent with the limits set in Section 3.1.3.
Strike Section 5.2.2 or expand 3.1.3 to 20% rather than 5%.
Strike Section 5.3 or expand 3.1.3 to 10% (if you go to 20% keep Section 5.3).
Comment #37Page Number: There are noneParagraph / Figure / Table / Note: 3.1Comment Intent: ObjectionComment Type: EditorialComment: This section requires that fans and manometers be "tested annually for calibration using the manufacturer's recommended calibration procedure." This is unclear. I'm not aware that any manufacturer actually publishes their calibration procedure. Doing a test according to the manufacturer's calibration procedure is a very difficult procedure requireing very expensive equipment and requireing considerable expertise. But manufacturers do recommend certain calibration checks such as comparing a manometer against another one that has been recently calibrated or checking a fan for damaged or dirty flow sensors. This later is not a "manufacturer's recommended calibration procedure" and wording needs to be changed to clearly indicate what is intended. Response: Accept in Principle Although there is no proposed change - changes due to other comments should address this comment.
This section requires that fans and manometers be "tested annually for calibration using the manufacturer's recommended calibration procedure." This is unclear. I'm not aware that any manufacturer actually publishes their calibration procedure. Doing a test according to the manufacturer's calibration procedure is a very difficult procedure requireing very expensive equipment and requireing considerable expertise. But manufacturers do recommend certain calibration checks such as comparing a manometer against another one that has been recently calibrated or checking a fan for damaged or dirty flow sensors. This later is not a "manufacturer's recommended calibration procedure" and wording needs to be changed to clearly indicate what is intended.
Although there is no proposed change - changes due to other comments should address this comment.
Comment #38Page Number: There are noneParagraph / Figure / Table / Note: 3.2.1Comment Intent: ObjectionComment Type: TechnicalComment: Interior doors should be open but this says to close them. Response: Accept in principle Interior doors are discussed in section 3.2.6. However, the word "exterior" will be added to section 3.2.1 as an editorial change.
Interior doors should be open but this says to close them.
Interior doors are discussed in section 3.2.6. However, the word "exterior" will be added to section 3.2.1 as an editorial change.
Comment #39Page Number: noneParagraph / Figure / Table / Note: 3.2.2Comment Intent: ObjectionComment Type: TechnicalComment: Doors between the house and the garage should be closed. This isn't in the section. Response: Reject Following the logic and instructions this door WOULD be closed.
Doors between the house and the garage should be closed. This isn't in the section.
Following the logic and instructions this door WOULD be closed.
Comment #40Page Number: noneParagraph / Figure / Table / Note: 3.2.3Comment Intent: ObjectionComment Type: TechnicalComment: What if the crawlspace is clearly intended to be outside the conditioned space boundary, is intentionally very leaky to the outside but is unvented and there is an access hatch to the inside? I think whether a space is opened to the inside or outside should depend more on whether it is inside or outside the conditioned space boundary. The conditioned space boundary should be defined by the chapter or standard that deals with modeling the building, not in this standard. Response: Reject No proposed change. There is no substantive difference between "intentionally leaky" and "vented".
What if the crawlspace is clearly intended to be outside the conditioned space boundary, is intentionally very leaky to the outside but is unvented and there is an access hatch to the inside? I think whether a space is opened to the inside or outside should depend more on whether it is inside or outside the conditioned space boundary. The conditioned space boundary should be defined by the chapter or standard that deals with modeling the building, not in this standard.
No proposed change. There is no substantive difference between "intentionally leaky" and "vented".
Comment #41Page Number: noneParagraph / Figure / Table / Note: 3.2.5Comment Intent: ObjectionComment Type: TechnicalComment: Paragraph talks about "doors between basements and Conditioned Space Volume" but if basement is conditioned then isn't it part of the conditioned space volume? Shouldn't there be a statement that doors inside of the conditioned space volume shall be opened? Response: Reject No proposed change. Section 3.2.6 discusses doors inside conditioned space volume.
Paragraph talks about "doors between basements and Conditioned Space Volume" but if basement is conditioned then isn't it part of the conditioned space volume? Shouldn't there be a statement that doors inside of the conditioned space volume shall be opened?
No proposed change. Section 3.2.6 discusses doors inside conditioned space volume.
Comment #42Page Number: noneParagraph / Figure / Table / Note: 3.2.6Comment Intent: ObjectionComment Type: TechnicalComment: If Conditioned Space Volume is well defined, do we need to say anything about basement doors? Response: Reject No proposed change. Yes, it is necessary to discuss door opening for clarity and consistency. Section 3.2.5 discusses basement door positioning.
If Conditioned Space Volume is well defined, do we need to say anything about basement doors?
No proposed change. Yes, it is necessary to discuss door opening for clarity and consistency. Section 3.2.5 discusses basement door positioning.
Comment #43Page Number: noneParagraph / Figure / Table / Note: 3.2.10.2Comment Intent: Not an ObjectionComment Type: EditorialComment: I believe Conditioned Space Volume is the intended term, not conditioned space. Response: Accept This comment is not specific to changes to draft version PDS-01. However, the change is editorial and will be made to the next draft.
I believe Conditioned Space Volume is the intended term, not conditioned space.
This comment is not specific to changes to draft version PDS-01. However, the change is editorial and will be made to the next draft.
Comment #44Page Number: noneParagraph / Figure / Table / Note: 3.4.1.2Comment Intent: ObjectionComment Type: EditorialComment: It's really confusing to define the induced enclosure pressure difference as the induced enclosure pressure minus the baseline. All pressures we measure are pressure differences, including the induced enclosure pressure, which is not defined. The last sentence of this section states that "a minimum of 15 Pa must be induced..." Is this supposed to be the induced enclosure pressure or the induced enclosure pressure difference? Terminology needs to be made more clear. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
It's really confusing to define the induced enclosure pressure difference as the induced enclosure pressure minus the baseline. All pressures we measure are pressure differences, including the induced enclosure pressure, which is not defined.
The last sentence of this section states that "a minimum of 15 Pa must be induced..." Is this supposed to be the induced enclosure pressure or the induced enclosure pressure difference? Terminology needs to be made more clear.
Comment #45Page Number: noneParagraph / Figure / Table / Note: 3.4.1.6Comment Intent: ObjectionComment Type: TechnicalComment: These 2 ELAs differ from each other by about 50%. Something is wrong. Response: Accept The equation for CMS50 should divide by 13.6 NOT 9.13.
These 2 ELAs differ from each other by about 50%. Something is wrong.
The equation for CMS50 should divide by 13.6 NOT 9.13.
Comment #46Page Number: noneParagraph / Figure / Table / Note: 3.4.2Comment Intent: ObjectionComment Type: TechnicalComment: There should be a post baseline pressure measurement. When pressures are fluctuating the fluctuation of the baseline is about the same as the fluctuation of the test pressure difference. When subtracting to get the induced pressure the error in the baseline is as important as the error in the induced pressure. Therefore the baseline should be measured for about the same length of time as the total of the test pressures. Taking a post baseline gets closer to this. Also if wind shifts during the test the average of the pre and post baselines would be a better estimate. There should also be some estimate of errors due to wind, which are often the largest source of errors. Chapter 8, E779, EN13829, ISO..., CGSB149.1, etc all do this in a reasonable way. The user needs to get some feedback on precision errors and I don't think it made any sense to remove this. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
There should be a post baseline pressure measurement. When pressures are fluctuating the fluctuation of the baseline is about the same as the fluctuation of the test pressure difference. When subtracting to get the induced pressure the error in the baseline is as important as the error in the induced pressure. Therefore the baseline should be measured for about the same length of time as the total of the test pressures. Taking a post baseline gets closer to this. Also if wind shifts during the test the average of the pre and post baselines would be a better estimate.
There should also be some estimate of errors due to wind, which are often the largest source of errors. Chapter 8, E779, EN13829, ISO..., CGSB149.1, etc all do this in a reasonable way. The user needs to get some feedback on precision errors and I don't think it made any sense to remove this.
Comment #47Page Number: noneParagraph / Figure / Table / Note: 3.5.2Comment Intent: ObjectionComment Type: TechnicalComment: Equation 7b is wrong. 60 should be replaced with 3600 Response: Accept The equation is wrong. The correction will be made.
Equation 7b is wrong. 60 should be replaced with 3600
The equation is wrong. The correction will be made.
Comment #48Page Number: noneParagraph / Figure / Table / Note: 4Comment Intent: ObjectionComment Type: TechnicalComment: If method A in E1554 will be used there needs to be a way to convert it to CFM25 since that is what most testers who are verifying compliance with an energy code (IECC 2012 for example). Hers raters are also often used to measuring airtightness at 25 Pa instead of leakage under normal operation. The fact that E1554 measures a completely different thing than CFM25 at least needs to be mentioned. E1554 does not measure airtightness, which is in the title of section 4. My recommendation is to drop the reference to E1554. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
If method A in E1554 will be used there needs to be a way to convert it to CFM25 since that is what most testers who are verifying compliance with an energy code (IECC 2012 for example). Hers raters are also often used to measuring airtightness at 25 Pa instead of leakage under normal operation. The fact that E1554 measures a completely different thing than CFM25 at least needs to be mentioned. E1554 does not measure airtightness, which is in the title of section 4. My recommendation is to drop the reference to E1554.
Comment #49Page Number: noneParagraph / Figure / Table / Note: 4Comment Intent: Not an ObjectionComment Type: TechnicalComment: When testing leakage to outside the blower door should be allowed to be installed in a window or door between the unit and the outside. It doesn't need to be a blower door fan. It could be any fan that is capable of getting the unit to the desired pressure. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
When testing leakage to outside the blower door should be allowed to be installed in a window or door between the unit and the outside. It doesn't need to be a blower door fan. It could be any fan that is capable of getting the unit to the desired pressure.
Comment #50Page Number: noneParagraph / Figure / Table / Note: 4.1Comment Intent: ObjectionComment Type: TechnicalComment: Same comment about calibration as I have for blower doors Response: Accept The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration procedure. The equipment listed in this section shall have their calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.
Same comment about calibration as I have for blower doors
Comment #51Page Number: noneParagraph / Figure / Table / Note: 4.2.8Comment Intent: Not an ObjectionComment Type: EditorialComment: I don't understand what the "face" of a duct boot is. I think this needs a diagram to be clear. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
I don't understand what the "face" of a duct boot is. I think this needs a diagram to be clear.
Comment #52Page Number: noneParagraph / Figure / Table / Note: 5.1.1.2.2Comment Intent: Not an ObjectionComment Type: TechnicalComment: The required accuracy of the manometer is 1% or .25Pa, but this section requires that zero pressure be obtained within .1Pa. This is inconsistent. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
The required accuracy of the manometer is 1% or .25Pa, but this section requires that zero pressure be obtained within .1Pa. This is inconsistent.
Comment #53Page Number: noneParagraph / Figure / Table / Note: 5.3.1.1Comment Intent: ObjectionComment Type: TechnicalComment: The airflow measurement stations that I have used many times all have 4 measuring points and I have found that they perform well in a piece of straight duct. I don't think it will make much difference to require 5 and am not aware of any stations that have 5. This seems arbitrary. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
The airflow measurement stations that I have used many times all have 4 measuring points and I have found that they perform well in a piece of straight duct. I don't think it will make much difference to require 5 and am not aware of any stations that have 5. This seems arbitrary.
Comment #54Page Number: noneParagraph / Figure / Table / Note: 7Comment Intent: ObjectionComment Type: TechnicalComment: Including the volume of a vented attic or crawlspace or garage as unconditioned space and therefore as infiltration space is a very bad idea. These spaces are usually considered outside the thermal boundary and the airtightness boundary. When measuring ACH50 these spaces have never been included by anyone in the world as part of the volume. THis just makes no sense at all. This makes me seriously question the definitions of Conditioned, Unconditioned, and Infiltration Volume and I think this all has to be seriously reviewed by the committee and also the committee in charge of rating calculations. Something is very wrong. This is very different from the Conditioned Space Boundary definition that is in Chapter 8. Response: Accept in Principle The comment is partially correct -vented crawlspaces are already excluded. We had intended to exclude vented attics but a bullet was missing from the list. The text has been changed to eliminate all attics from infiltration volume.
Including the volume of a vented attic or crawlspace or garage as unconditioned space and therefore as infiltration space is a very bad idea. These spaces are usually considered outside the thermal boundary and the airtightness boundary. When measuring ACH50 these spaces have never been included by anyone in the world as part of the volume. THis just makes no sense at all. This makes me seriously question the definitions of Conditioned, Unconditioned, and Infiltration Volume and I think this all has to be seriously reviewed by the committee and also the committee in charge of rating calculations. Something is very wrong. This is very different from the Conditioned Space Boundary definition that is in Chapter 8.
The comment is partially correct -vented crawlspaces are already excluded. We had intended to exclude vented attics but a bullet was missing from the list. The text has been changed to eliminate all attics from infiltration volume.
Comment #55Page Number: 1, 12, 19, 20, 21Paragraph / Figure / Table / Note: 3.1, 4.1, 5.1.1, 5.1.2.1, 5.1.3.1Comment Intent: Not an ObjectionComment Type: TechnicalComment: This comment is issued on behalf of the Standards Committee of the Northeast HERS AllianceThe language listed below is similar to that in each of the sections cited. The justification for the proposed change is that an annual calibration check is unneccessary if it is not recommended by the manufacturer of the equipment being used. In this case, the manfacturer's calibration schedule should be allowed. Proposed Change: The equipment below shall be tested at least annually or in accordance with the manufacturer’s calibration schedule, whichever is less frequent, for calibration using the manufacturer’s calibration procedure. Response: Accept in Principle The equipment listed in this section shall be tested annually for calibration using the manufacturer’s recommended calibration procedure. The equipment listed in this section shall have their calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.
This comment is issued on behalf of the Standards Committee of the Northeast HERS AllianceThe language listed below is similar to that in each of the sections cited.
The justification for the proposed change is that an annual calibration check is unneccessary if it is not recommended by the manufacturer of the equipment being used. In this case, the manfacturer's calibration schedule should be allowed.
The equipment below shall be tested at least annually or in accordance with the manufacturer’s calibration schedule, whichever is less frequent, for calibration using the manufacturer’s calibration procedure.
Comment #56Page Number: 21Paragraph / Figure / Table / Note: 5.2Comment Intent: ObjectionComment Type: TechnicalComment: This comment is issued by the Standards Committee of the Northeast HERS Alliance. We disagree with the exclusion of passive flow hoods for use in testing ventilation airflow on the supply side in light of: The very small scope of study that showed the inaccuracy of these flow hoods; The allowance of a “bag” test which permits variance in results of up to 20%; Except for in very low load homes, the relatively small impact that this has on the actual rating score; The economic hardship it places on Raters who have invested in this type of equipment as the “gold standard” of air flow testing. Proposed Change: ...The airflow is permitted to be measured using a Powered Flow Hood (Section 5.2.1), or using a Bag Inflation Device (Section 5.2.2) or a Passive Flow Hood (Section 5.2.3). Note: Sections describing the Passive Flow Hood and the techniques used for this test using the passive flow hood would need to be added. Wording for these sections would be similar to that for the procedure for measuring air flow at inlet terminal with a passive flow hood in Section 5.1.3. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
This comment is issued by the Standards Committee of the Northeast HERS Alliance.
We disagree with the exclusion of passive flow hoods for use in testing ventilation airflow on the supply side in light of:
...The airflow is permitted to be measured using a Powered Flow Hood (Section 5.2.1), or using a Bag Inflation Device (Section 5.2.2) or a Passive Flow Hood (Section 5.2.3).
Note: Sections describing the Passive Flow Hood and the techniques used for this test using the passive flow hood would need to be added. Wording for these sections would be similar to that for the procedure for measuring air flow at inlet terminal with a passive flow hood in Section 5.1.3.
Comment #57Page Number: 25Paragraph / Figure / Table / Note: DefinitionsComment Intent: ObjectionComment Type: TechnicalComment: This comment has been issued on behalf of the Standards Committee of the Northeast HERS Alliance. Definition of Conditioned Floor Area – We disagree with the bullet relating to the inclusion of basement floor area only when if it is included in the Manual J, S and D. This sets an unrealistically high bar. It requires that all three steps have been completed (not a requirement for completing a HERS Rating). It requires that the information is provided to the HERS rater (also not a requirement for a HERS Rating). It is our recommendation that an alternative criteria be provided for inclusion of a basement as conditioned floor area based solely on visual inspection. Response: Accept in Principle One goal of the committee in drafting Standard 380 was to develop more objective, rather than subjective, definitions to ensure consistent application of the standard. With that said, the committee understands that obtaining a Manual J, S, and D report is not standard practice today for Raters and that it may be appropriate to add an alternative compliance option for basements that is based upon finishes. To address the comment, the definition for Conditioned Floor Area and Conditioned Space Volume will be modified by adding the following option for basements: "Verified through visual inspection that the basement is an enclosed area that is suitable for year-round use, employing wall, floor, and ceiling finishes that are similar to the rest of the house."
This comment has been issued on behalf of the Standards Committee of the Northeast HERS Alliance.
Definition of Conditioned Floor Area – We disagree with the bullet relating to the inclusion of basement floor area only when if it is included in the Manual J, S and D. This sets an unrealistically high bar. It requires that all three steps have been completed (not a requirement for completing a HERS Rating). It requires that the information is provided to the HERS rater (also not a requirement for a HERS Rating). It is our recommendation that an alternative criteria be provided for inclusion of a basement as conditioned floor area based solely on visual inspection.
One goal of the committee in drafting Standard 380 was to develop more objective, rather than subjective, definitions to ensure consistent application of the standard. With that said, the committee understands that obtaining a Manual J, S, and D report is not standard practice today for Raters and that it may be appropriate to add an alternative compliance option for basements that is based upon finishes. To address the comment, the definition for Conditioned Floor Area and Conditioned Space Volume will be modified by adding the following option for basements: "Verified through visual inspection that the basement is an enclosed area that is suitable for year-round use, employing wall, floor, and ceiling finishes that are similar to the rest of the house."
Comment #58Page Number: 11Paragraph / Figure / Table / Note: 3.5Comment Intent: ObjectionComment Type: TechnicalComment:Proposed Change: THis comment is issued on behalf of the Standards Committee of the Northeast HERS Alliance. We are in aggreement with and support of the contents of Comment #8 regarding the inclusion of repeated single-point tests and longer term average tests as approved methods for conducting air infitration testing without the inclusion of an adjustment factor. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
THis comment is issued on behalf of the Standards Committee of the Northeast HERS Alliance.
We are in aggreement with and support of the contents of Comment #8 regarding the inclusion of repeated single-point tests and longer term average tests as approved methods for conducting air infitration testing without the inclusion of an adjustment factor.
Comment #59Page Number: 6, 10, 16Paragraph / Figure / Table / Note: 3.4.1.3, 3.4.2.3, 4.4.1.4Comment Intent: Not an ObjectionComment Type: EditorialComment: Change "as-found" to "pre-test" and add language regarding unsafe conditions for existing homes. Proposed Change: The Air-Moving Fan shall be turned off and the home returned to its as-found pre-test condition, unless the Rater determined that the pre-testing condition poses a health or safety risk to the building occupants. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Change "as-found" to "pre-test" and add language regarding unsafe conditions for existing homes.
The Air-Moving Fan shall be turned off and the home returned to its as-found pre-test condition, unless the Rater determined that the pre-testing condition poses a health or safety risk to the building occupants.
Comment #60Page Number: 1, 12, 18Paragraph / Figure / Table / Note: 2.1, 3.2, 4, 5Comment Intent: Not an ObjectionComment Type: EditorialComment: The standards should reference the RESNET MF Guidelines for performing testing on dewlling units in MF buildings. Proposed Change: insert "For tests on dwelling units withing multifamily buildings, Raters shall use the performance testing guidelines specified in the RESNET Guidelines for Multifamily Energy Ratings" Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
The standards should reference the RESNET MF Guidelines for performing testing on dewlling units in MF buildings.
insert "For tests on dwelling units withing multifamily buildings, Raters shall use the performance testing guidelines specified in the
RESNET Guidelines for Multifamily Energy Ratings"
Comment #61Page Number: 2Paragraph / Figure / Table / Note: 3.2.3Comment Intent: ObjectionComment Type: TechnicalComment: The use of the presence of venting in a crawlspace as a proxy for whether the crawlspace is within the pressure boundary of the home does not account for an unvented crawlspace that is clearly intended to be outside the pressure boundary (insulation and airsealing provided at the floor over crawlspace level). The old definition, while less clear, resulted in better direction on this issue. Response: Reject The text in the standard is an approach that gets us away from poor definitions of conditioned space boundary that led to confusion in other applications.
The use of the presence of venting in a crawlspace as a proxy for whether the crawlspace is within the pressure boundary of the home does not account for an unvented crawlspace that is clearly intended to be outside the pressure boundary (insulation and airsealing provided at the floor over crawlspace level). The old definition, while less clear, resulted in better direction on this issue.
The text in the standard is an approach that gets us away from poor definitions of conditioned space boundary that led to confusion in other applications.
Comment #62Page Number: 2Paragraph / Figure / Table / Note: 3.2.1Comment Intent: Not an ObjectionComment Type: EditorialComment: Language should be improved to be more consistent throughout document. Proposed Change: "All exterior doors and windows between the Airtightness Testing Volume and unconditioned space shall be closed….” Response: Reject Does not improve clarity of the standard.
Language should be improved to be more consistent throughout document.
"All exterior doors and windows between the Airtightness Testing Volume and unconditioned space shall be closed….”
Does not improve clarity of the standard.
Comment #63Page Number: 6, 12Comment Intent: Not an ObjectionComment Type: GeneralComment: If ASTM standards are going to be referenced, but the specific components not detailed in the standards, RESNET should at the very least make these starndards available for review by Raters/Providers so we don't all have to purchase them. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
If ASTM standards are going to be referenced, but the specific components not detailed in the standards, RESNET should at the very least make these starndards available for review by Raters/Providers so we don't all have to purchase them.
Comment #64Page Number: 2Paragraph / Figure / Table / Note: 3.2.3Comment Intent: ObjectionComment Type: TechnicalComment: Not all unvented crawlspaces are necessarily part of the buildling thermal envelope and therefore should not always be included in Airtightness Testing Volume. Proposed Change: Crawlspaces. If a crawlspace is unvented and has air sealed and insulated foundation walls that comprise the building thermal envelope, the interior access doors and hatches between the house and the crawlspace shall be opened and exterior crawlspace access doors, vents, and hatches shall be closed. If a crawlspace is vented, or is unvented and has an insulated and air sealed floor above the crawlspace that comprise the building thermal envelope interior access doors and hatches shall be closed andcrawlspace vents shall be left in their as-found position and their position shallbe recorded on the test report Response: Reject The way the definitions are structured, an unconditioned space volume (like an unvented crawlspace) should not be excluded from Infiltration Volume, even though it will be excluded from Conditioned Space Volume. Including the air sealed crawlspace in the infiltration volume will not impact HERS ratings. The infiltration volume is used to estimate ACH and is primarily used to examine compliance with building codes/standards that specify maximum allowable ACH - in which case the sealed crawlspace will lead to a slightly lower ACH for a given envelope air flow and house volume. This is an acceptable compromise compared to the difficulty and inconsistency associated with other methods of defining infiltration volume. In this way standard 380 errs on the side of consistency.
Not all unvented crawlspaces are necessarily part of the buildling thermal envelope and therefore should not always be included in Airtightness Testing Volume.
Crawlspaces. If a crawlspace is unvented and has air sealed and insulated foundation walls that comprise the building thermal envelope, the interior access doors and hatches between the house and the crawlspace shall be opened and exterior crawlspace access doors, vents, and hatches shall be closed. If a crawlspace is vented, or is unvented and has an insulated and air sealed floor above the crawlspace that comprise the building thermal envelope interior access doors and hatches shall be closed andcrawlspace vents shall be left in their as-found position and their position shallbe recorded on the test report
The way the definitions are structured, an unconditioned space volume (like an unvented crawlspace) should not be excluded from Infiltration Volume, even though it will be excluded from Conditioned Space Volume. Including the air sealed crawlspace in the infiltration volume will not impact HERS ratings. The infiltration volume is used to estimate ACH and is primarily used to examine compliance with building codes/standards that specify maximum allowable ACH - in which case the sealed crawlspace will lead to a slightly lower ACH for a given envelope air flow and house volume. This is an acceptable compromise compared to the difficulty and inconsistency associated with other methods of defining infiltration volume. In this way standard 380 errs on the side of consistency.
Comment #65Page Number: 2Paragraph / Figure / Table / Note: 3.2.3, 3.2.4, 3.2.5Comment Intent: Not an ObjectionComment Type: TechnicalComment: How should best be performed if either crawlspace, basement, or attic are insulated at their exterior surface and therefore comprise the building thermal envelope, but they do not have interior access hatches/doors? Proposed Change: Add a provision "If either a crawlspace, attic or basement are considreed to be a part of the building thermal envelope, but do not contain interior hatches/doors to connect the main body of the home to such spaces during testing, the Rater shall attempt to uniformly adjust the pressure of these spaces to the same level as the main body of the home using a separate air moving fan. If Rater is able to achieve a uniform test pressure the same as the main body of the home, then the volume such spaces shall be included within the Airtightness Testing Volume. If the Rater is unable to achieve uniform test presure same as the main body of the home, the volume of such spaces shall not be included in Airtightness Testing Volume. Response: Reject If there are no access doors the home is tested "as-is". We cannot expect a rater to perform multi-blower door testing.
How should best be performed if either crawlspace, basement, or attic are insulated at their exterior surface and therefore comprise the building thermal envelope, but they do not have interior access hatches/doors?
Add a provision "If either a crawlspace, attic or basement are considreed to be a part of the building thermal envelope, but do not contain interior hatches/doors to connect the main body of the home to such spaces during testing, the Rater shall attempt to uniformly adjust the pressure of these spaces to the same level as the main body of the home using a separate air moving fan. If Rater is able to achieve a uniform test pressure the same as the main body of the home, then the volume such spaces shall be included within the Airtightness Testing Volume. If the Rater is unable to achieve uniform test presure same as the main body of the home, the volume of such spaces shall not be included in Airtightness Testing Volume.
If there are no access doors the home is tested "as-is". We cannot expect a rater to perform multi-blower door testing.
Comment #66Page Number: 2Paragraph / Figure / Table / Note: 3.2.5Comment Intent: ObjectionComment Type: TechnicalComment: The laguage in this section could potneitallly cause basements that are part of the Building Thermal Envelope and which are direclty conditoined to be excluded from Airtightness Testing Volume if such spaces have insulated floors above. Proposed Change: Basements. All doors between basements and Conditioned Space Volume shall be opened unless the basement is determined to be outside of the building thermal envelope (i.e. floor above the basement is air sealed and insulated, and foundation walls are sealed/insulated to a lesser degree) in which case the door between the basement and Conditioned Space Volume shall be closed. Response: Reject The comment is incomplete as it raises an additional problem of knowing when enough insulation is enough. Without suggested language that allows this decision to be made we cannot include the commenter’s suggestion.
The laguage in this section could potneitallly cause basements that are part of the Building Thermal Envelope and which are direclty conditoined to be excluded from Airtightness Testing Volume if such spaces have insulated floors above.
Basements. All doors between basements and Conditioned Space Volume shall be opened unless the basement is determined to be outside of the building thermal envelope (i.e. floor above the basement is air sealed and insulated, and foundation walls are sealed/insulated to a lesser degree) in which case the door between the basement and Conditioned Space Volume shall be closed.
The comment is incomplete as it raises an additional problem of knowing when enough insulation is enough. Without suggested language that allows this decision to be made we cannot include the commenter’s suggestion.
Comment #67Page Number: 3Paragraph / Figure / Table / Note: 3.2.10Comment Intent: Not an ObjectionComment Type: EditorialComment: The wording of 3.2.10.1 and 3.2.10.2 are not consistent. One uses Conditioned Space Volume vs Unconditioned Space Volume, whereas the other uses Conditioned space vs unconditoined space. The defined term Unconditioned Space Volume and its use thorughout the standard lead to unnecessary amounts of confusion and math to explain relatively simple concepts. Unconditioned, semi-conditioned and conditioned space can be properly defined and we can use those as defintiions instead which will lead to less confusion, new terms, and silly math. Proposed Change: Non-motorized dampers (e.g., pressure-activated operable dampers, fixed dampers) that connect the Conditioned Space Volume conditioned or semi-conditioned space to the exterior or to uUnconditioned sSpace Volumes unconditioned space shall be left in their as-found positions. For example, a fixed damper in a duct supplying outdoor air for an intermittent ventilation system that utilizes the HVAC fan shall be left in its as-found position. Response: Accept in Principle Wording in 3.2.10.2 hanged for consistency to use the term "conditioned space volume".
The wording of 3.2.10.1 and 3.2.10.2 are not consistent. One uses Conditioned Space Volume vs Unconditioned Space Volume, whereas the other uses Conditioned space vs unconditoined space. The defined term Unconditioned Space Volume and its use thorughout the standard lead to unnecessary amounts of confusion and math to explain relatively simple concepts. Unconditioned, semi-conditioned and conditioned space can be properly defined and we can use those as defintiions instead which will lead to less confusion, new terms, and silly math.
Non-motorized dampers (e.g., pressure-activated operable dampers, fixed dampers) that connect the Conditioned Space Volume conditioned or semi-conditioned space to the exterior or to uUnconditioned sSpace Volumes unconditioned space shall be left in their as-found positions. For example, a fixed damper in a duct supplying outdoor air for an intermittent ventilation system that utilizes the HVAC fan shall be left in its as-found position.
Wording in 3.2.10.2 hanged for consistency to use the term "conditioned space volume".
Comment #68Page Number: 26Paragraph / Figure / Table / Note: DefinitionsComment Intent: ObjectionComment Type: EditorialComment: The defined term Unconditioned Space Volume and its use thorughout the standard lead to unnecessary amounts of confusion and math to explain relatively simple concepts. Unconditioned, semi-conditioned and conditioned space can be properly defined and we can use those as defintiions instead which will lead to less confusion, new terms, and silly math. It is recommended to keep the Conditioned Space Volume definition, add a definitoin of both Conditoned Space, unconditioned space, semi-conditioned space, get rid of Unconditioned Space Volume, and change title of "Infiltration Volume" to "Airtightness Testing Volume" Proposed Change: Infiltration Volume Airtightness Testing Volume– The sum of the volumes of Conditioned Space and Semi-conditioned Space. Space Volume in the dwelling unit, minus the volume of: ? Floor cavities that have Unconditioned Space Volume both above and below, ? Unconditioned wall cavities, ? Attics that are air sealed and insulated at the roof deck, ? Vented crawlspaces, ? Garages, ? Basements, if the door between the basement and Conditioned Space Volume is closed during enclosure air leakage testing (Section 3.2.5), and, ? Thermally isolated sunrooms. Unconditioned Space Volume - The volume within a building that is not Conditioned Space Volume but which may contain heat sources or sinks that influence the temperature of the area or room. The following specific spaces are addressed to ensure consistent application of this definition: ? The volume of a floor cavity shall be included, unless the volume both above and below the floor cavity meets the definition of Conditioned Space Volume. ? The volume of a wall cavity shall be included, unless the wall cavity meets the definition of Conditioned Space Volume. ? The volume of a vented attic shall be included. ? The volume of a vented crawlspace shall be included. ? The volume of a garage shall be included, even if it is conditioned. ? The volume of a thermally isolated sunroom shall be included. ? The volume of an attic sealed and insulated at the roof deck, an unvented crawlspace, or a basement shall be included unless it meets the definition of Conditioned Space Volume. Add definitons of conditoined space, semi-conditoined space, unconditioned space. Response: Reject The committee has decided that the definitions are required for clarity and precision in the standard. The commenter has not shown why "confusion and math" are leading to problems.
The defined term Unconditioned Space Volume and its use thorughout the standard lead to unnecessary amounts of confusion and math to explain relatively simple concepts. Unconditioned, semi-conditioned and conditioned space can be properly defined and we can use those as defintiions instead which will lead to less confusion, new terms, and silly math.
It is recommended to keep the Conditioned Space Volume definition, add a definitoin of both Conditoned Space, unconditioned space, semi-conditioned space, get rid of Unconditioned Space Volume, and change title of "Infiltration Volume" to "Airtightness Testing Volume"
Infiltration Volume Airtightness Testing Volume– The sum of the volumes of Conditioned Space and Semi-conditioned Space. Space Volume in the dwelling unit, minus the volume of: ? Floor cavities that have Unconditioned Space Volume both above and below, ? Unconditioned wall cavities, ? Attics that are air sealed and insulated at the roof deck, ? Vented crawlspaces, ? Garages, ? Basements, if the door between the basement and Conditioned Space Volume is closed during enclosure air leakage testing (Section 3.2.5), and, ? Thermally isolated sunrooms. Unconditioned Space Volume - The volume within a building that is not Conditioned Space Volume but which may contain heat sources or sinks that influence the temperature of the area or room. The following specific spaces are addressed to ensure consistent application of this definition: ? The volume of a floor cavity shall be included, unless the volume both above and below the floor cavity meets the definition of Conditioned Space Volume. ? The volume of a wall cavity shall be included, unless the wall cavity meets the definition of Conditioned Space Volume. ? The volume of a vented attic shall be included. ? The volume of a vented crawlspace shall be included. ? The volume of a garage shall be included, even if it is conditioned. ? The volume of a thermally isolated sunroom shall be included. ? The volume of an attic sealed and insulated at the roof deck, an unvented crawlspace, or a basement shall be included unless it meets the definition of Conditioned Space Volume.
Add definitons of conditoined space, semi-conditoined space, unconditioned space.
The committee has decided that the definitions are required for clarity and precision in the standard. The commenter has not shown why "confusion and math" are leading to problems.
Comment #69Page Number: 11Paragraph / Figure / Table / Note: 3.5.1Comment Intent: ObjectionComment Type: TechnicalComment: Why are we saying that a one point blower door test cannot be used in a rating unless adding a 10% fudge factor? Where is the empirical evidence to show why this is a valid adjustment? I understand that one point testing is not always the most accurate, but it is not always inaccurate either. Regardless, where does 10% fudge factor come from? Is there a scientific validation for this number, or is it simply a number made up by the committee intended to penalize single point testing? o Recommendation: Although the previous guidance given on defining tests as Standard vs Reduced Accuracy were not perfect, they at least allowed for a test to be ran on a generally calm day without much hassle. This is arguably most tests on most days. I recommend you revert the language to the current Chapter 8 language for characterizing tests and base it off of this. Proposed Change: Revert back to Chapter 8 definitions for Standard vs Reduced level of accuracy testing. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Why are we saying that a one point blower door test cannot be used in a rating unless adding a 10% fudge factor? Where is the empirical evidence to show why this is a valid adjustment? I understand that one point testing is not always the most accurate, but it is not always inaccurate either. Regardless, where does 10% fudge factor come from? Is there a scientific validation for this number, or is it simply a number made up by the committee intended to penalize single point testing?
o Recommendation: Although the previous guidance given on defining tests as Standard vs Reduced Accuracy were not perfect, they at least allowed for a test to be ran on a generally calm day without much hassle. This is arguably most tests on most days. I recommend you revert the language to the current Chapter 8 language for characterizing tests and base it off of this.
Revert back to Chapter 8 definitions for Standard vs Reduced level of accuracy testing.
Comment #70Page Number: 11Paragraph / Figure / Table / Note: 3.5.2Comment Intent: Not an ObjectionComment Type: EditorialComment: o Is this stating that if converting to ACH50, one does not need to use Corrected or Adjusted CFM50 values? Proposed Change: Please clarify Response: Accept in principle The word "Adjusted" has been added for clarity.
o Is this stating that if converting to ACH50, one does not need to use Corrected or Adjusted CFM50 values?
Please clarify
The word "Adjusted" has been added for clarity.
Comment #71Page Number: 10Paragraph / Figure / Table / Note: 3.4Comment Intent: ObjectionComment Type: TechnicalComment: o Why no allowance for repeated single point testing? This was a valid method of performing these tests which results in increased accuracy Proposed Change: o Bring back protocols and procedures for repated single point testing. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
o Why no allowance for repeated single point testing? This was a valid method of performing these tests which results in increased accuracy
o Bring back protocols and procedures for repated single point testing.
Comment #72Page Number: 12Paragraph / Figure / Table / Note: 4Comment Intent: Not an ObjectionComment Type: EditorialComment: o “Only the ducts in the home being tested shall be included in the air leakage test” o Is air leakage test in this instance referring to blower door testing or duct tightness testing? Please clarify o Also, it seems elsewhere in the standards, there is an intent to define these tests as “tightness” testing. Please make consistent here Proposed Change: o “Only the ducts in the home being tested shall be included in the air leakage test” duct tightness test. Response: Accept in principle Removed the words "air leakage" for clarity
o “Only the ducts in the home being tested shall be included in the air leakage test”
o Is air leakage test in this instance referring to blower door testing or duct tightness testing? Please clarify
o Also, it seems elsewhere in the standards, there is an intent to define these tests as “tightness” testing. Please make consistent here
o “Only the ducts in the home being tested shall be included in the air leakage test” duct tightness test.
Removed the words "air leakage" for clarity
Comment #73Page Number: 12Paragraph / Figure / Table / Note: 4.1.5Comment Intent: Not an ObjectionComment Type: EditorialComment: o Should this be “Duct tightness tester” for consistency? Proposed Change: Duct Leakage Tightness Tester. Response: Reject There is no need for consistency here. Tightness generally refers to the metric being used (e.g., CFM25) whereas the actual testing requires measurement of air flows hence the use of “leakage” rather than “tightness”.
o Should this be “Duct tightness tester” for consistency?
Duct Leakage Tightness Tester.
There is no need for consistency here. Tightness generally refers to the metric being used (e.g., CFM25) whereas the actual testing requires measurement of air flows hence the use of “leakage” rather than “tightness”.
Comment #74Page Number: 12Paragraph / Figure / Table / Note: 4.2Comment Intent: Not an ObjectionComment Type: GeneralComment: No provisions for rough-in duct testing? Proposed Change: Bring back Chapter 8's standards language for rough in testing. Response: Reject No proposed change. It is possible to test at rough-in.
No provisions for rough-in duct testing?
Bring back Chapter 8's standards language for rough in testing.
No proposed change. It is possible to test at rough-in.
Comment #75Page Number: 14Paragraph / Figure / Table / Note: 4.2.8Comment Intent: ObjectionComment Type: TechnicalComment: Taping ducts on carpet over face/inside boot should only be permitted if the Rater visually verifies that the duct boot is sealed to the finished surface. If it is not, it should not be permitted and the duct should be taped on the surface of the register. Proposed Change: "Registers atop carpets are permitted to be removed and the face of the duct boot temporarily sealed during testing so long as the Rater has verified that the duct boot to finsihed surface connections have been permanently sealed. If boot to finished surface connection has not been sealed, the Rater shall tape the top of the register." Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
Taping ducts on carpet over face/inside boot should only be permitted if the Rater visually verifies that the duct boot is sealed to the finished surface. If it is not, it should not be permitted and the duct should be taped on the surface of the register.
"Registers atop carpets are permitted to be removed and the face of the duct boot temporarily sealed during testing so long as the Rater has verified that the duct boot to finsihed surface connections have been permanently sealed. If boot to finished surface connection has not been sealed, the Rater shall tape the top of the register."
Comment #76Page Number: 14Paragraph / Figure / Table / Note: 4.3 exception 2Comment Intent: ObjectionComment Type: TechnicalComment: o Exception 2: Is this intended to mean 50 CFM25? Proposed Change: Exception 2: If the measured total duct leakage is less than 50 cfm@25 Pa (25 L/s) then either method may be used. Response: Accept Added "at 25 Pa" for clarity.
o Exception 2: Is this intended to mean 50 CFM25?
Exception 2: If the measured total duct leakage is less than 50 cfm@25 Pa (25 L/s) then either method may be used.
Added "at 25 Pa" for clarity.
Comment #77Page Number: 18Paragraph / Figure / Table / Note: 4.5Comment Intent: ObjectionComment Type: TechnicalComment: o If single point blower door tests are unacceptable for ratings unless multiplied by a 10% fudge factor, why duct leakage test results permitted to be performed as single point tests unadjusted? o In my experience, the variability of leakage to outside test results based on atmospheric conditions at the time of the test are just as great if not moreso than envelope leakage. Also, given that the thresholds for these tests are typically more stringent in comparison to envelope leakage tests, seemingly we would want an equal or more stringent testing protocol for such systems o Why not just require a long term time average test be performed, or a repeated single point test or multipoint test for ducts? That or just permit both blower door and duct leakage tests to be performed single point IF the testing condition is a Standard level of testing condition. If it is reduced for blower door, then duct leakage tests should either be multiplied by 10% fudge factor or performed repeated single point or multipoint Proposed Change: Make consistent the expectations of single point vs multipoint testing for both duct tighteness and building enclosure tightness tests. Permit single point tests for both if the testing environment is characterized as a Standard level of accuracy testing environment. If Reduced then either require 10% fudge factor, repeated single point or multipoint tests for BOTH duct tigntess and buildling enclosure air tightness tests. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
o If single point blower door tests are unacceptable for ratings unless multiplied by a 10% fudge factor, why duct leakage test results permitted to be performed as single point tests unadjusted?
o In my experience, the variability of leakage to outside test results based on atmospheric conditions at the time of the test are just as great if not moreso than envelope leakage. Also, given that the thresholds for these tests are typically more stringent in comparison to envelope leakage tests, seemingly we would want an equal or more stringent testing protocol for such systems
o Why not just require a long term time average test be performed, or a repeated single point test or multipoint test for ducts? That or just permit both blower door and duct leakage tests to be performed single point IF the testing condition is a Standard level of testing condition. If it is reduced for blower door, then duct leakage tests should either be multiplied by 10% fudge factor or performed repeated single point or multipoint
Make consistent the expectations of single point vs multipoint testing for both duct tighteness and building enclosure tightness tests. Permit single point tests for both if the testing environment is characterized as a Standard level of accuracy testing environment. If Reduced then either require 10% fudge factor, repeated single point or multipoint tests for BOTH duct tigntess and buildling enclosure air tightness tests.
Comment #78Page Number: 18Paragraph / Figure / Table / Note: 4.5Comment Intent: Not an ObjectionComment Type: GeneralComment: o Should duct leakage numbers de adjusted for air density such as blower door test results? Proposed Change: If psosible, amke air density correction facotrs consistent for both duct tightness and building enclsoure air tightness tests Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
o Should duct leakage numbers de adjusted for air density such as blower door test results?
If psosible, amke air density correction facotrs consistent for both duct tightness and building enclsoure air tightness tests
Comment #79Page Number: 19Paragraph / Figure / Table / Note: 5.1 + 5.2Comment Intent: ObjectionComment Type: TechnicalComment: o Measuring inlets from ambient conditions should only be permitted if the testing characterized as non-windy conditions. o Attempting to measure air volume from the exterior of the building on a windy day is useless and entirely error prone. This standard must regulate and explicitly disallow such testing practice if it is windy. This would also apply for measuring outlets from the exterior. Proposed Change: This Section defines procedures to measure the airflow of a mechanical ventilation system at an inlet terminal. The airflow is permitted to be measured using a Powered Flow Hood (Section 5.1.1); using an Airflow Resistance Device (Section 5.1.2); or using a Passive Flow Hood (Section 5.1.3). If the atmospheric conditions at the time of the test are determiend by the Rater to be excessively windy, Rater shall not be permitted to test aiflow of inlet or outlet terminals from ambient conditions Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
o Measuring inlets from ambient conditions should only be permitted if the testing characterized as non-windy conditions.
o Attempting to measure air volume from the exterior of the building on a windy day is useless and entirely error prone. This standard must regulate and explicitly disallow such testing practice if it is windy.
This would also apply for measuring outlets from the exterior.
This Section defines procedures to measure the airflow of a mechanical ventilation system at an inlet terminal. The airflow is permitted to be measured using a Powered Flow Hood (Section 5.1.1); using an Airflow Resistance Device (Section 5.1.2); or using a Passive Flow Hood (Section 5.1.3). If the atmospheric conditions at the time of the test are determiend by the Rater to be excessively windy, Rater shall not be permitted to test aiflow of inlet or outlet terminals from ambient conditions
Comment #80Page Number: 22Paragraph / Figure / Table / Note: 5.3Comment Intent: ObjectionComment Type: TechnicalComment: o This standard should permit other induct measurement testing devices to be used such as hot wire anemometers and pitot tubes and should discuss their specific applications. o I do not believe this committee has any sound science to disallow the use of by far the most popular and widely used in-duct testing devices in the history of air volume measurement. o Although it is true that the use of such devices could be prone to user error, this is the case for any and all tests defined by this standard (especially bags!). Therefore, it should be the goal of this standard to set acceptable protocols for use instead of simply writing off entire categories and classes of tools that have a history of widespread use and acceptance. o Also, should have separate provisions for measuring round vs rectangular duct Proposed Change: This standard should be written to be inclusive of other induct measurement devices such as hot wire anemometers, pitot tubes, etc referncing appropriate time averaged traverse processes, and should have separate defintions for measuring rectuangular vs round duct. Response: Reject The comment is not specific to changes to the first public review draft, which are the only portions of the proposed standard open for comment in this second public review period. The comment will be retained for review during the first scheduled update to the standard subsequent to its final approval and publication.
o This standard should permit other induct measurement testing devices to be used such as hot wire anemometers and pitot tubes and should discuss their specific applications.
o I do not believe this committee has any sound science to disallow the use of by far the most popular and widely used in-duct testing devices in the history of air volume measurement.
o Although it is true that the use of such devices could be prone to user error, this is the case for any and all tests defined by this standard (especially bags!). Therefore, it should be the goal of this standard to set acceptable protocols for use instead of simply writing off entire categories and classes of tools that have a history of widespread use and acceptance.
o Also, should have separate provisions for measuring round vs rectangular duct
This standard should be written to be inclusive of other induct measurement devices such as hot wire anemometers, pitot tubes, etc referncing appropriate time averaged traverse processes, and should have separate defintions for measuring rectuangular vs round duct.
Comment #81Page Number: 25Paragraph / Figure / Table / Note: Defintions CFAComment Intent: ObjectionComment Type: TechnicalComment: o § Manual J and S, not necessarily D (hydronic) § Heating and cooling changed to “space conditioning” § Include provisions to include basements that are finished and directly conditioned in existing homes where Manual J not present § Field verification that equipment/distribution system installed per design (visual verification of size/location of distribution devices and terminals) Proposed Change: The floor area of a basement shall only be included if the Rater has obtained a Manual J, S and either B or D report and verified that the space conditoining equipment and distribution system are designed to offset the entire design load of the volume.The rater shall field verify that equipment/distribution systems are insallaed per design (visual verification of size/location of distribution devices and terminals) in order to include space within CFA. In the event that the Rater is being performed on an existing home, the Rater shall include basements within the building thermal envelope that are finished and direclty condtoined within CFA without a Manual J being documented. Response: Accept in Principle The standard has been edited to allow both B and D, but not other changes that are not necessary in this standard.
o
§ Manual J and S, not necessarily D (hydronic)
§ Heating and cooling changed to “space conditioning”
§ Include provisions to include basements that are finished and directly conditioned in existing homes where Manual J not present
§ Field verification that equipment/distribution system installed per design (visual verification of size/location of distribution devices and terminals)
The floor area of a basement shall only be included if the Rater has obtained a Manual J, S and either B or D report and verified that the space conditoining equipment and distribution system are designed to offset the entire design load of the volume.The rater shall field verify that equipment/distribution systems are insallaed per design (visual verification of size/location of distribution devices and terminals) in order to include space within CFA. In the event that the Rater is being performed on an existing home, the Rater shall include basements within the building thermal envelope that are finished and direclty condtoined within CFA without a Manual J being documented.
The standard has been edited to allow both B and D, but not other changes that are not necessary in this standard.