Review of Substantive Changes to BSR/RESNET/ICC 380-201x PDS-02 Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: 3
Paragraph / Figure / Table / Note: 3.2.10
Comment Intent: Not an Objection
Comment Type: General

Comment:

When performing an air leakage test using pressurization testing, dwelling units with exhaust fans using a gravity damper are negatively affected. If we are testing building enclosure leakage, these fans should be allowed to be sealed as we do not want to measure the leakage of a manufactured opening. Testing in both pressurization and depressurization can yield better results.

Proposed Change:

3.2.10. Dampers

3.2.10.1. Non-motorized dampers (e.g., pressure-activated operable dampers, fixed dampers) that connect the Conditioned Space Volume to the exterior or to Unconditioned Space Volumes shall be left in their as-found positions during depressurization testing. 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.  If pressure testing, opening shall be sealed to get average between both pressurized and depressurized testing.

Response:

Reject

The comment is rejected on procedural grounds because it is not specific to a change to PDS-02, which the notice stated were the only requirements open for comment. The entire draft PDS-03 was not open for comment. 

Comment #2

Page Number: NA
Paragraph / Figure / Table / Note: NA
Comment Intent: Not an Objection
Comment Type: General

Comment:

Baseline procedure needs to be highlighted and expanded.Not at the level of each manufacturer at least influance its importance. Experiance has shown that some think it is optional.

Response:

Reject

The comment is rejected on procedural grounds because it is not specific to a change to PDS-02, which the notice stated were the only requirements open for comment. The entire draft PDS-03 was not open for comment. 

Comment #3

Page Number: 5
Paragraph / Figure / Table / Note: 3.4
Comment Intent: Objection
Comment Type: Technical

Comment:Proposed Change:

INSERT new section

3.4.2 Long-term Averaged Single-Point Airtightness Test

 

3.4.2.1. With the Air-Moving Fan turned off and sealed, the pressure difference across the enclosure shall be recorded using the Manometer, with the outside as the reference. The measurement shall represent the average value over at least a 1 minute period and shall be defined as the Pre-Test Baseline Building Pressure.

3.4.2.2. The Air-Moving Fan shall be unsealed, turned on, and adjusted to create an induced enclosure pressure difference of 50 ±3 Pa (0.2 in. ±0.012 H2O), defined as the induced enclosure pressure minus the Pre-Test Baseline Building Pressure. Note that this value is permitted to be positive or negative, which will be dependent upon whether the enclosure is pressurized or depressurized. An indication of whether the Air-Moving Fan pressurized or depressurized the house shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference can be achieved, then the average value of the induced enclosure pressure difference and the airflow at 50 Pa (0.2 in. H2O), measured over at least a 1 minute period, shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference cannot be achieved, then additional Air-Moving Fans shall be used or the highest induced enclosure pressure difference (dPmeasured) and airflow (Qmeasured) that was achieved with the equipment available, measured over at least a 1 minute period, shall be recorded. A minimum of 15 Pa (0.06 in. H2O) must be induced across the enclosure for the test to be valid.

3.4.2.3. The Air-Moving Fan shall be turned off and the home returned to its as-found condition.

3.4.2.4. If an induced enclosure pressure difference of 50 Pa (0.2 in. H2O) was not achieved in Section 3.4.1.2, then the recorded airflow (Qmeasured) shall be converted to a nominal airflow at 50 Pa (0.2 in. H2O) using Equation 1. Alternately, a Manometer that is equipped to automatically make the conversion to CFM50 or CMS50 is permitted to be used.

(equation unchanged from 3.4.1.4)

3.4.2.5. Corrected CFM50 (corrected CMS50) shall be calculated by making  the adjustments due to density and viscosity The airflow at 50 Pa shall  be corrected for altitude and temperature to determine the corrected airflow at 50 Pa using the calculations inusing Equation 4 in  Section 9 and annex A1 of ASTM E779-101, resulting in the termby substituting  CFM50 (CMS50) for C and Corrected CFM50 (corrected CMS50) for  C0.  Corrected CFM50.

3.4.2.6. The Effective Leakage Area (ELA) shall be calculated using Equation

(equation unchanged from 3.4.1.6)

3.4.23. Multi-Point Airtightness Tests

(Only section number revised)

3.5. Procedure to Apply Results of Enclosure Air Leakage Test

3.5.1. If the results of the building enclosure air leakage test are to be used for conducting a home energy rating or assessing compliance with a building enclosure leakage limit (e.g., defined by code or by an energy efficiency program), then the corrected airflow determined using a one-point test shall be adjusted using Equation 5a or 5b.

Adjusted CFM50 = 1.1 x Corrected CFM50                          (5a)

Adjusted CMS50 = 1.1 x Corrected CMS50                         (5b)

The ELA determined in Section 3.4.1.6 for a one-point air leakage test shall be adjusted using Equation 6.

Adjusted ELA = 1.1 x ELA                    (6)

Response:

Reject

The comment is rejected on procedural grounds because it is not specific to a change to PDS-02, which the notice stated were the only requirements open for comment. The entire draft PDS-03 was not open for comment. The committee may consider this proposal in future revisions of the standard.

Comment #4

Page Number: 5
Paragraph / Figure / Table / Note: 3.4
Comment Intent: Objection
Comment Type: Technical

Comment:Proposed Change:

INSERT new section

3.4.2 Long-term Averaged Single-Point Airtightness Test

 

3.4.2.1. With the Air-Moving Fan turned off and sealed, the pressure difference across the enclosure shall be recorded using the Manometer, with the outside as the reference. The measurement shall represent the average value over at least a 1 minute period and shall be defined as the Pre-Test Baseline Building Pressure.

3.4.2.2. The Air-Moving Fan shall be unsealed, turned on, and adjusted to create an induced enclosure pressure difference of 50 ±3 Pa (0.2 in. ±0.012 H2O), defined as the induced enclosure pressure minus the Pre-Test Baseline Building Pressure. Note that this value is permitted to be positive or negative, which will be dependent upon whether the enclosure is pressurized or depressurized. An indication of whether the Air-Moving Fan pressurized or depressurized the house shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference can be achieved, then the average value of the induced enclosure pressure difference and the airflow at 50 Pa (0.2 in. H2O), measured over at least a 1 minute period, shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference cannot be achieved, then additional Air-Moving Fans shall be used or the highest induced enclosure pressure difference (dPmeasured) and airflow (Qmeasured) that was achieved with the equipment available, measured over at least a 1 minute period, shall be recorded. A minimum of 15 Pa (0.06 in. H2O) must be induced across the enclosure for the test to be valid.

3.4.2.3. The Air-Moving Fan shall be turned off and the home returned to its as-found condition.

3.4.2.4. If an induced enclosure pressure difference of 50 Pa (0.2 in. H2O) was not achieved in Section 3.4.1.2, then the recorded airflow (Qmeasured) shall be converted to a nominal airflow at 50 Pa (0.2 in. H2O) using Equation 1. Alternately, a Manometer that is equipped to automatically make the conversion to CFM50 or CMS50 is permitted to be used.

(equation unchanged from 3.4.1.4)

3.4.2.5. Corrected CFM50 (corrected CMS50) shall be calculated by making  the adjustments due to density and viscosity The airflow at 50 Pa shall  be corrected for altitude and temperature to determine the corrected airflow at 50 Pa using the calculations inusing Equation 4 in  Section 9 and annex A1 of ASTM E779-101, resulting in the termby substituting  CFM50 (CMS50) for C and Corrected CFM50 (corrected CMS50) for  C0.  Corrected CFM50.

3.4.2.6. The Effective Leakage Area (ELA) shall be calculated using Equation

(equation unchanged from 3.4.1.6)

3.4.23. Multi-Point Airtightness Tests

(Only section number revised)

3.5. Procedure to Apply Results of Enclosure Air Leakage Test

3.5.1. If the results of the building enclosure air leakage test are to be used for conducting a home energy rating or assessing compliance with a building enclosure leakage limit (e.g., defined by code or by an energy efficiency program), then the corrected airflow determined using a one-point test shall be adjusted using Equation 5a or 5b.

Adjusted CFM50 = 1.1 x Corrected CFM50                          (5a)

Adjusted CMS50 = 1.1 x Corrected CMS50                         (5b)

The ELA determined in Section 3.4.1.6 for a one-point air leakage test shall be adjusted using Equation 6.

Adjusted ELA = 1.1 x ELA                    (6)

Response:

Reject

The comment is rejected on procedural grounds because it is not specific to a change to PDS-02, which the notice stated were the only requirements open for comment. The entire draft PDS-03 was not open for comment. The committee may consider this proposal in future revisions of the standard.

Comment #5

Page Number: 5
Paragraph / Figure / Table / Note: 3.4
Comment Intent: Objection
Comment Type: Technical

Comment:

In regards to air-tightness testing, this Standard greatly preferences multi-point blower testing by establishing a 10% penalty to all single-point blower door tests.  The assumption behind this is that multi-point blower door tests are inherently more accurate than single-point tests.   Also that this assumed increase in accuracy is worth the added monetary expense to Raters and RFIs of deploying laptops (or tablets once Retrotech and TEC release apps) into the field to run this test.  

I object to the underlieing assumption based directly on comments made on the RESNET required QA Roundtable Webinar on 8/27/2015.  At that roundtable the question was posed to TEC and Retrotech if multi-point blower door tests were more accurate than the traditional single-point test.  The response from Colin Genge of Retrotech, which Frank Spevak of TEC concurred with, was that multi-point blower door tests conducted with 5 points (per the RESNET standard) are not any more accurate than single-point tests and that an increase in accuracy would only be achieved if hundreds of points were recorded.  Colin and Frank suggested that the time-average function which both of their base equipment packages support (without adding laptop controlled programs; i.e. techtite for TEC) would yield the same level of accuracy as a multi-point test.  Further is was noted by Colin that a multi-point test is difficult to QA because it is does not yield easily repeatable results.

Based on this discussion at the RESNET QA Roundtable I am proprosing an additional blower door testing method which I am calling a "Long-term Averaged Single-Point Airtightness Test".  The proposed durations (1 minutes for baseline and 2 minutes at 50 Pa) over which to gather data points for the time-average is based on a subsequent conversation with Colin Genge via email.

It is my belief that this new testing method will achieve the same level of accuracy as the multi-point test method in a fashion that is both more cost effective and repeatable.

Proposed Change:

INSERT new section

3.4.2 Long-term Averaged Single-Point Airtightness Test

 

3.4.2.1. With the Air-Moving Fan turned off and sealed, the pressure difference across the enclosure shall be recorded using the Manometer, with the outside as the reference. The measurement shall represent the average value over at least a 1 minute period and shall be defined as the Pre-Test Baseline Building Pressure.

3.4.2.2. The Air-Moving Fan shall be unsealed, turned on, and adjusted to create an induced enclosure pressure difference of 50 ±3 Pa (0.2 in. ±0.012 H2O), defined as the induced enclosure pressure minus the Pre-Test Baseline Building Pressure. Note that this value is permitted to be positive or negative, which will be dependent upon whether the enclosure is pressurized or depressurized. An indication of whether the Air-Moving Fan pressurized or depressurized the house shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference can be achieved, then the average value of the induced enclosure pressure difference and the airflow at 50 Pa (0.2 in. H2O), measured over at least a 1 minute period, shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference cannot be achieved, then additional Air-Moving Fans shall be used or the highest induced enclosure pressure difference (dPmeasured) and airflow (Qmeasured) that was achieved with the equipment available, measured over at least a 1 minute period, shall be recorded. A minimum of 15 Pa (0.06 in. H2O) must be induced across the enclosure for the test to be valid.

3.4.2.3. The Air-Moving Fan shall be turned off and the home returned to its as-found condition.

3.4.2.4. If an induced enclosure pressure difference of 50 Pa (0.2 in. H2O) was not achieved in Section 3.4.1.2, then the recorded airflow (Qmeasured) shall be converted to a nominal airflow at 50 Pa (0.2 in. H2O) using Equation 1. Alternately, a Manometer that is equipped to automatically make the conversion to CFM50 or CMS50 is permitted to be used.

(equation unchanged from 3.4.1.4)

3.4.2.5. Corrected CFM50 (corrected CMS50) shall be calculated by making  the adjustments due to density and viscosity The airflow at 50 Pa shall  be corrected for altitude and temperature to determine the corrected airflow at 50 Pa using the calculations inusing Equation 4 in  Section 9 and annex A1 of ASTM E779-101, resulting in the termby substituting  CFM50 (CMS50) for C and Corrected CFM50 (corrected CMS50) for  C0.  Corrected CFM50.

3.4.2.6. The Effective Leakage Area (ELA) shall be calculated using Equation

(equation unchanged from 3.4.1.6)

3.4.23. Multi-Point Airtightness Tests

(Only section number revised; all text remains the same)

3.5. Procedure to Apply Results of Enclosure Air Leakage Test

3.5.1. If the results of the building enclosure air leakage test are to be used for conducting a home energy rating or assessing compliance with a building enclosure leakage limit (e.g., defined by code or by an energy efficiency program), then the corrected airflow determined using a one-point test shall be adjusted using Equation 5a or 5b.

Adjusted CFM50 = 1.1 x Corrected CFM50                          (5a)

Adjusted CMS50 = 1.1 x Corrected CMS50                         (5b)

The ELA determined in Section 3.4.1.6 for a one-point air leakage test shall be adjusted using Equation 6.

Adjusted ELA = 1.1 x ELA                    (6)

Other applications of building enclosure air leakage testing and the results of multi-point and long-term averaged single-point testing do not require the corrections in this section.

Response:

Reject

The comment is rejected on procedural grounds because it is not specific to a change to PDS-02, which the notice stated were the only requirements open for comment. The entire draft PDS-03 was not open for comment. The committee may consider this proposal in future revisions of the standard.

Comment #6

Page Number: 5
Paragraph / Figure / Table / Note: 3.4
Comment Intent: Objection
Comment Type: Technical

Comment:

In regards to air-tightness testing, this Standard greatly preferences multi-point blower testing by establishing a 10% penalty to all single-point blower door tests.  The assumption behind this is that multi-point blower door tests are inherently more accurate than single-point tests.   Also that this assumed increase in accuracy is worth the added monetary expense to Raters and RFIs of deploying laptops (or tablets once Retrotech and TEC release apps) into the field to run this test.  

I object to the underlieing assumption based directly on comments made on the RESNET required QA Roundtable Webinar on 8/27/2015.  At that roundtable the question was posed to TEC and Retrotech if multi-point blower door tests were more accurate than the traditional single-point test.  The response from Colin Genge of Retrotech, which Frank Spevak of TEC concurred with, was that multi-point blower door tests conducted with 5 points (per the RESNET standard) are not any more accurate than single-point tests and that an increase in accuracy would only be achieved if hundreds of points were recorded.  Colin and Frank suggested that the time-average function which both of their base equipment packages support (without adding laptop controlled programs; i.e. techtite for TEC) would yield the same level of accuracy as a multi-point test.  Further is was noted by Colin that a multi-point test is difficult to QA because it is does not yield easily repeatable results.

Based on this discussion at the RESNET QA Roundtable I am proprosing an additional blower door testing method which I am calling a "Long-term Averaged Single-Point Airtightness Test".  The proposed durations (1 minutes for baseline and 2 minutes at 50 Pa) over which to gather data points for the time-average is based on a subsequent conversation with Colin Genge via email.

It is my belief that this new testing method will achieve the same level of accuracy as the multi-point test method in a fashion that is both more cost effective and repeatable.

Proposed Change:

INSERT new section

3.4.2 Long-term Averaged Single-Point Airtightness Test

 

3.4.2.1. With the Air-Moving Fan turned off and sealed, the pressure difference across the enclosure shall be recorded using the Manometer, with the outside as the reference. The measurement shall represent the average value over at least a 1 minute period and shall be defined as the Pre-Test Baseline Building Pressure.

3.4.2.2. The Air-Moving Fan shall be unsealed, turned on, and adjusted to create an induced enclosure pressure difference of 50 ±3 Pa (0.2 in. ±0.012 H2O), defined as the induced enclosure pressure minus the Pre-Test Baseline Building Pressure. Note that this value is permitted to be positive or negative, which will be dependent upon whether the enclosure is pressurized or depressurized. An indication of whether the Air-Moving Fan pressurized or depressurized the house shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference can be achieved, then the average value of the induced enclosure pressure difference and the airflow at 50 Pa (0.2 in. H2O), measured over at least a 1 minute period, shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference cannot be achieved, then additional Air-Moving Fans shall be used or the highest induced enclosure pressure difference (dPmeasured) and airflow (Qmeasured) that was achieved with the equipment available, measured over at least a 1 minute period, shall be recorded. A minimum of 15 Pa (0.06 in. H2O) must be induced across the enclosure for the test to be valid.

3.4.2.3. The Air-Moving Fan shall be turned off and the home returned to its as-found condition.

3.4.2.4. If an induced enclosure pressure difference of 50 Pa (0.2 in. H2O) was not achieved in Section 3.4.1.2, then the recorded airflow (Qmeasured) shall be converted to a nominal airflow at 50 Pa (0.2 in. H2O) using Equation 1. Alternately, a Manometer that is equipped to automatically make the conversion to CFM50 or CMS50 is permitted to be used.

(equation unchanged from 3.4.1.4)

3.4.2.5. Corrected CFM50 (corrected CMS50) shall be calculated by making  the adjustments due to density and viscosity The airflow at 50 Pa shall  be corrected for altitude and temperature to determine the corrected airflow at 50 Pa using the calculations inusing Equation 4 in  Section 9 and annex A1 of ASTM E779-101, resulting in the termby substituting  CFM50 (CMS50) for C and Corrected CFM50 (corrected CMS50) for  C0.  Corrected CFM50.

3.4.2.6. The Effective Leakage Area (ELA) shall be calculated using Equation

(equation unchanged from 3.4.1.6)

3.4.23. Multi-Point Airtightness Tests

(Only section number revised; all text remains the same)

3.5. Procedure to Apply Results of Enclosure Air Leakage Test

3.5.1. If the results of the building enclosure air leakage test are to be used for conducting a home energy rating or assessing compliance with a building enclosure leakage limit (e.g., defined by code or by an energy efficiency program), then the corrected airflow determined using a one-point test shall be adjusted using Equation 5a or 5b.

Adjusted CFM50 = 1.1 x Corrected CFM50                          (5a)

Adjusted CMS50 = 1.1 x Corrected CMS50                         (5b)

The ELA determined in Section 3.4.1.6 for a one-point air leakage test shall be adjusted using Equation 6.

Adjusted ELA = 1.1 x ELA                    (6)

Other applications of building enclosure air leakage testing and the results of multi-point and long-term averaged single-point testing do not require the corrections in this section.

Response:

Reject

The comment is rejected on procedural grounds because it is not specific to a change to PDS-02, which the notice stated were the only requirements open for comment. The entire draft PDS-03 was not open for comment. The committee may consider this proposal in future revisions of the standard.

Comment #7

Page Number: 5
Paragraph / Figure / Table / Note: 3.4
Comment Intent: Objection
Comment Type: Technical

Comment:

In regards to air-tightness testing, this Standard greatly preferences multi-point blower testing by establishing a 10% penalty to all single-point blower door tests.  The assumption behind this is that multi-point blower door tests are inherently more accurate than single-point tests.   Also that this assumed increase in accuracy is worth the added monetary expense to Raters and RFIs of deploying laptops (or tablets once Retrotech and TEC release apps) into the field to run this test.  

I object to the underlieing assumption based directly on comments made on the RESNET required QA Roundtable Webinar on 8/27/2015.  At that roundtable the question was posed to TEC and Retrotech if multi-point blower door tests were more accurate than the traditional single-point test.  The response from Colin Genge of Retrotech, which Frank Spevak of TEC concurred with, was that multi-point blower door tests conducted with 5 points (per the RESNET standard) are not any more accurate than single-point tests and that an increase in accuracy would only be achieved if hundreds of points were recorded.  Colin and Frank suggested that the time-average function which both of their base equipment packages support (without adding laptop controlled programs; i.e. techtite for TEC) would yield the same level of accuracy as a multi-point test.  Further is was noted by Colin that a multi-point test is difficult to QA because it is does not yield easily repeatable results.

Based on this discussion at the RESNET QA Roundtable I am proprosing an additional blower door testing method which I am calling a "Long-term Averaged Single-Point Airtightness Test".  The proposed durations (1 minutes for baseline and 2 minutes at 50 Pa) over which to gather data points for the time-average is based on a subsequent conversation with Colin Genge via email.

It is my belief that this new testing method will achieve the same level of accuracy as the multi-point test method in a fashion that is both more cost effective and repeatable.

 

Proposed Change:

INSERT new section

3.4.2 Long-term Averaged Single-Point Airtightness Test

 

3.4.2.1. With the Air-Moving Fan turned off and sealed, the pressure difference across the enclosure shall be recorded using the Manometer, with the outside as the reference. The measurement shall represent the average value over at least a 1 minute period and shall be defined as the Pre-Test Baseline Building Pressure.

3.4.2.2. The Air-Moving Fan shall be unsealed, turned on, and adjusted to create an induced enclosure pressure difference of 50 ±3 Pa (0.2 in. ±0.012 H2O), defined as the induced enclosure pressure minus the Pre-Test Baseline Building Pressure. Note that this value is permitted to be positive or negative, which will be dependent upon whether the enclosure is pressurized or depressurized. An indication of whether the Air-Moving Fan pressurized or depressurized the house shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference can be achieved, then the average value of the induced enclosure pressure difference and the airflow at 50 Pa (0.2 in. H2O), measured over at least a 1 minute period, shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference cannot be achieved, then additional Air-Moving Fans shall be used or the highest induced enclosure pressure difference (dPmeasured) and airflow (Qmeasured) that was achieved with the equipment available, measured over at least a 1 minute period, shall be recorded. A minimum of 15 Pa (0.06 in. H2O) must be induced across the enclosure for the test to be valid.

3.4.2.3. The Air-Moving Fan shall be turned off and the home returned to its as-found condition.

3.4.2.4. If an induced enclosure pressure difference of 50 Pa (0.2 in. H2O) was not achieved in Section 3.4.1.2, then the recorded airflow (Qmeasured) shall be converted to a nominal airflow at 50 Pa (0.2 in. H2O) using Equation 1. Alternately, a Manometer that is equipped to automatically make the conversion to CFM50 or CMS50 is permitted to be used.

(equation unchanged from 3.4.1.4)

3.4.2.5. Corrected CFM50 (corrected CMS50) shall be calculated by making  the adjustments due to density and viscosity The airflow at 50 Pa shall  be corrected for altitude and temperature to determine the corrected airflow at 50 Pa using the calculations inusing Equation 4 in  Section 9 and annex A1 of ASTM E779-101, resulting in the termby substituting  CFM50 (CMS50) for C and Corrected CFM50 (corrected CMS50) for  C0.  Corrected CFM50.

3.4.2.6. The Effective Leakage Area (ELA) shall be calculated using Equation

(equation unchanged from 3.4.1.6)

3.4.23. Multi-Point Airtightness Tests

(Only section number revised; all text remains the same)

3.5. Procedure to Apply Results of Enclosure Air Leakage Test

3.5.1. If the results of the building enclosure air leakage test are to be used for conducting a home energy rating or assessing compliance with a building enclosure leakage limit (e.g., defined by code or by an energy efficiency program), then the corrected airflow determined using a one-point test shall be adjusted using Equation 5a or 5b.

Adjusted CFM50 = 1.1 x Corrected CFM50                          (5a)

Adjusted CMS50 = 1.1 x Corrected CMS50                         (5b)

The ELA determined in Section 3.4.1.6 for a one-point air leakage test shall be adjusted using Equation 6.

Adjusted ELA = 1.1 x ELA                    (6)

Other applications of building enclosure air leakage testing and the results of multi-point and long-term averaged single-point testing do not require the corrections in this section.

Response:

Reject

The comment is rejected on procedural grounds because it is not specific to a change to PDS-02, which the notice stated were the only requirements open for comment. The entire draft PDS-03 was not open for comment. The committee may consider this proposal in future revisions of the standard.

Comment #8

Page Number: BSR/RESNET/ICC 380-201x PDS-02
Paragraph / Figure / Table / Note: BSR/RESNET/ICC 380-201x PDS-02
Comment Intent: Objection
Comment Type: Technical

Comment:

Add additional testing option in addition to the multi-point testing for building infiltration. 

Proposed Change:

3.4.2 Long-term Averaged Single-Point Airtightness Test

 

3.4.2.1. With the Air-Moving Fan turned off and sealed, the pressure difference across the enclosure shall be recorded using the Manometer, with the outside as the reference. The measurement shall represent the average value over at least a 1 minute period and shall be defined as the Pre-Test Baseline Building Pressure.

3.4.2.2. The Air-Moving Fan shall be unsealed, turned on, and adjusted to create an induced enclosure pressure difference of 50 ±3 Pa (0.2 in. ±0.012 H2O), defined as the induced enclosure pressure minus the Pre-Test Baseline Building Pressure. Note that this value is permitted to be positive or negative, which will be dependent upon whether the enclosure is pressurized or depressurized. An indication of whether the Air-Moving Fan pressurized or depressurized the house shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference can be achieved, then the average value of the induced enclosure pressure difference and the airflow at 50 Pa (0.2 in. H2O), measured over at least a 1 minute period, shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference cannot be achieved, then additional Air-Moving Fans shall be used or the highest induced enclosure pressure difference (dPmeasured) and airflow (Qmeasured) that was achieved with the equipment available, measured over at least a 1 minute period, shall be recorded. A minimum of 15 Pa (0.06 in. H2O) must be induced across the enclosure for the test to be valid.

3.4.2.3. The Air-Moving Fan shall be turned off and the home returned to its as-found condition.

3.4.2.4. If an induced enclosure pressure difference of 50 Pa (0.2 in. H2O) was not achieved in Section 3.4.1.2, then the recorded airflow (Qmeasured) shall be converted to a nominal airflow at 50 Pa (0.2 in. H2O) using Equation 1. Alternately, a Manometer that is equipped to automatically make the conversion to CFM50 or CMS50 is permitted to be used.

 

3.4.2.5. Corrected CFM50 (corrected CMS50) shall be calculated by making  the adjustments due to density and viscosity The airflow at 50 Pa shall  be corrected for altitude and temperature to determine the corrected airflow at 50 Pa using the calculations inusing Equation 4 in  Section 9 and annex A1 of ASTM E779-101, resulting in the termby substituting  CFM50 (CMS50) for C and Corrected CFM50 (corrected CMS50) for  C0.  Corrected CFM50.

3.4.2.6. The Effective Leakage Area (ELA) shall be calculated using Equation

Response:

Reject

The comment is rejected on procedural grounds because it is not specific to a change to PDS-02, which the notice stated were the only requirements open for comment. The entire draft PDS-03 was not open for comment. The committee may consider this proposal in future revisions of the standard.

Comment #9

Page Number: 5
Paragraph / Figure / Table / Note: 3.4
Comment Intent: Objection
Comment Type: Technical

Comment:

Looking at all  scenarios and methods It seems the Multi point  testing method  proposed is intended for large commercial type structures. I suggest  the Time Average method could be  most suitable for  residential dwellings. i don’t have any issue with the Single Point method, its  the 5- 10% penalty  that  would  have a particularly painful impact on  the small apartment units Again, . My main issue  with Multi Point test is,  while  this makes sense for large, typically commercial  buildings, it is overkill for Single Family homes and Multi Family apartments.  

 

I strongly agree with these comments also

 In regards to air-tightness testing, this Standard greatly preferences multi-point blower testing by establishing a 10% penalty to all single-point blower door tests.  The assumption behind this is that multi-point blower door tests are inherently more accurate than single-point tests.   Also that this assumed increase in accuracy is worth the added monetary expense to Raters and RFIs of deploying laptops (or tablets once Retrotech and TEC release apps) into the field to run this test.  

I object to the underlieing assumption based directly on comments made on the RESNET required QA Roundtable Webinar on 8/27/2015.  At that roundtable the question was posed to TEC and Retrotech if multi-point blower door tests were more accurate than the traditional single-point test.  The response from Colin Genge of Retrotech, which Frank Spevak of TEC concurred with, was that multi-point blower door tests conducted with 5 points (per the RESNET standard) are not any more accurate than single-point tests and that an increase in accuracy would only be achieved if hundreds of points were recorded.  Colin and Frank suggested that the time-average function which both of their base equipment packages support (without adding laptop controlled programs; i.e. techtite for TEC) would yield the same level of accuracy as a multi-point test.  Further is was noted by Colin that a multi-point test is difficult to QA because it is does not yield easily repeatable results.

Based on this discussion at the RESNET QA Roundtable I am proprosing an additional blower door testing method which I am calling a "Long-term Averaged Single-Point Airtightness Test".  The proposed durations (1 minutes for baseline and 2 minutes at 50 Pa) over which to gather data points for the time-average is based on a subsequent conversation with Colin Genge via email.

It is my belief that this new testing method will achieve the same level of accuracy as the multi-point test method in a fashion that is both more cost effective and repeatable.

Proposed Change:

INSERT new section

3.4.2 Long-term Averaged Single-Point Airtightness Test

 

3.4.2.1. With the Air-Moving Fan turned off and sealed, the pressure difference across the enclosure shall be recorded using the Manometer, with the outside as the reference. The measurement shall represent the average value over at least a 1 minute period and shall be defined as the Pre-Test Baseline Building Pressure.

3.4.2.2. The Air-Moving Fan shall be unsealed, turned on, and adjusted to create an induced enclosure pressure difference of 50 ±3 Pa (0.2 in. ±0.012 H2O), defined as the induced enclosure pressure minus the Pre-Test Baseline Building Pressure. Note that this value is permitted to be positive or negative, which will be dependent upon whether the enclosure is pressurized or depressurized. An indication of whether the Air-Moving Fan pressurized or depressurized the house shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference can be achieved, then the average value of the induced enclosure pressure difference and the airflow at 50 Pa (0.2 in. H2O), measured over at least a 1 minute period, shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference cannot be achieved, then additional Air-Moving Fans shall be used or the highest induced enclosure pressure difference (dPmeasured) and airflow (Qmeasured) that was achieved with the equipment available, measured over at least a 1 minute period, shall be recorded. A minimum of 15 Pa (0.06 in. H2O) must be induced across the enclosure for the test to be valid.

3.4.2.3. The Air-Moving Fan shall be turned off and the home returned to its as-found condition.

3.4.2.4. If an induced enclosure pressure difference of 50 Pa (0.2 in. H2O) was not achieved in Section 3.4.1.2, then the recorded airflow (Qmeasured) shall be converted to a nominal airflow at 50 Pa (0.2 in. H2O) using Equation 1. Alternately, a Manometer that is equipped to automatically make the conversion to CFM50 or CMS50 is permitted to be used.

(equation unchanged from 3.4.1.4)

3.4.2.5. Corrected CFM50 (corrected CMS50) shall be calculated by making  the adjustments due to density and viscosity The airflow at 50 Pa shall  be corrected for altitude and temperature to determine the corrected airflow at 50 Pa using the calculations inusing Equation 4 in  Section 9 and annex A1 of ASTM E779-101, resulting in the termby substituting  CFM50 (CMS50) for C and Corrected CFM50 (corrected CMS50) for  C0.  Corrected CFM50.

3.4.2.6. The Effective Leakage Area (ELA) shall be calculated using Equation

(equation unchanged from 3.4.1.6)

3.4.23. Multi-Point Airtightness Tests

(Only section number revised; all text remains the same)

3.5. Procedure to Apply Results of Enclosure Air Leakage Test

3.5.1. If the results of the building enclosure air leakage test are to be used for conducting a home energy rating or assessing compliance with a building enclosure leakage limit (e.g., defined by code or by an energy efficiency program), then the corrected airflow determined using a one-point test shall be adjusted using Equation 5a or 5b.

Adjusted CFM50 = 1.1 x Corrected CFM50                          (5a)

Adjusted CMS50 = 1.1 x Corrected CMS50                         (5b)

The ELA determined in Section 3.4.1.6 for a one-point air leakage test shall be adjusted using Equation 6.

Adjusted ELA = 1.1 x ELA                    (6)

Other applications of building enclosure air leakage testing and the results of multi-point and long-term averaged single-point testing do not require the corrections in this section.

Response:

Reject

The comment is rejected on procedural grounds because it is not specific to a change to PDS-02, which the notice stated were the only requirements open for comment. The entire draft PDS-03 was not open for comment. The committee may consider this proposal in future revisions of the standard.

Comment #10

Page Number: 5
Paragraph / Figure / Table / Note: 3.4
Comment Intent: Objection
Comment Type: Technical

Comment:

Comment:

In regards to air-tightness testing, this Standard greatly preferences multi-point blower testing by establishing a 10% penalty to all single-point blower door tests.  The assumption behind this is that multi-point blower door tests are inherently more accurate than single-point tests.   Also that this assumed increase in accuracy is worth the added monetary expense to Raters and RFIs of deploying laptops (or tablets once Retrotech and TEC release apps) into the field to run this test.  

I object to the underlieing assumption based directly on comments made on the RESNET required QA Roundtable Webinar on 8/27/2015.  At that roundtable the question was posed to TEC and Retrotech if multi-point blower door tests were more accurate than the traditional single-point test.  The response from Colin Genge of Retrotech, which Frank Spevak of TEC concurred with, was that multi-point blower door tests conducted with 5 points (per the RESNET standard) are not any more accurate than single-point tests and that an increase in accuracy would only be achieved if hundreds of points were recorded.  Colin and Frank suggested that the time-average function which both of their base equipment packages support (without adding laptop controlled programs; i.e. techtite for TEC) would yield the same level of accuracy as a multi-point test.  Further is was noted by Colin that a multi-point test is difficult to QA because it is does not yield easily repeatable results.

Based on this discussion at the RESNET QA Roundtable I am proprosing an additional blower door testing method which I am calling a "Long-term Averaged Single-Point Airtightness Test".  The proposed durations (1 minutes for baseline and 2 minutes at 50 Pa) over which to gather data points for the time-average is based on a subsequent conversation with Colin Genge via email.

It is my belief that this new testing method will achieve the same level of accuracy as the multi-point test method in a fashion that is both more cost effective and repeatable.

 

Proposed Change:

INSERT new section

3.4.2 Long-term Averaged Single-Point Airtightness Test

 

3.4.2.1. With the Air-Moving Fan turned off and sealed, the pressure difference across the enclosure shall be recorded using the Manometer, with the outside as the reference. The measurement shall represent the average value over at least a 1 minute period and shall be defined as the Pre-Test Baseline Building Pressure.

3.4.2.2. The Air-Moving Fan shall be unsealed, turned on, and adjusted to create an induced enclosure pressure difference of 50 ±3 Pa (0.2 in. ±0.012 H2O), defined as the induced enclosure pressure minus the Pre-Test Baseline Building Pressure. Note that this value is permitted to be positive or negative, which will be dependent upon whether the enclosure is pressurized or depressurized. An indication of whether the Air-Moving Fan pressurized or depressurized the house shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference can be achieved, then the average value of the induced enclosure pressure difference and the airflow at 50 Pa (0.2 in. H2O), measured over at least a 1 minute period, shall be recorded.

If a 50 Pa (0.2 in. H2O) induced enclosure pressure difference cannot be achieved, then additional Air-Moving Fans shall be used or the highest induced enclosure pressure difference (dPmeasured) and airflow (Qmeasured) that was achieved with the equipment available, measured over at least a 1 minute period, shall be recorded. A minimum of 15 Pa (0.06 in. H2O) must be induced across the enclosure for the test to be valid.

3.4.2.3. The Air-Moving Fan shall be turned off and the home returned to its as-found condition.

3.4.2.4. If an induced enclosure pressure difference of 50 Pa (0.2 in. H2O) was not achieved in Section 3.4.1.2, then the recorded airflow (Qmeasured) shall be converted to a nominal airflow at 50 Pa (0.2 in. H2O) using Equation 1. Alternately, a Manometer that is equipped to automatically make the conversion to CFM50 or CMS50 is permitted to be used.

(equation unchanged from 3.4.1.4)

3.4.2.5. Corrected CFM50 (corrected CMS50) shall be calculated by making  the adjustments due to density and viscosity The airflow at 50 Pa shall  be corrected for altitude and temperature to determine the corrected airflow at 50 Pa using the calculations inusing Equation 4 in  Section 9 and annex A1 of ASTM E779-101, resulting in the termby substituting  CFM50 (CMS50) for C and Corrected CFM50 (corrected CMS50) for  C0.  Corrected CFM50.

3.4.2.6. The Effective Leakage Area (ELA) shall be calculated using Equation

(equation unchanged from 3.4.1.6)

3.4.23. Multi-Point Airtightness Tests

(Only section number revised; all text remains the same)

3.5. Procedure to Apply Results of Enclosure Air Leakage Test

3.5.1. If the results of the building enclosure air leakage test are to be used for conducting a home energy rating or assessing compliance with a building enclosure leakage limit (e.g., defined by code or by an energy efficiency program), then the corrected airflow determined using a one-point test shall be adjusted using Equation 5a or 5b.

Adjusted CFM50 = 1.1 x Corrected CFM50                          (5a)

Adjusted CMS50 = 1.1 x Corrected CMS50                         (5b)

The ELA determined in Section 3.4.1.6 for a one-point air leakage test shall be adjusted using Equation 6.

Adjusted ELA = 1.1 x ELA                    (6)

Other applications of building enclosure air leakage testing and the results of multi-point and long-term averaged single-point testing do not require the corrections in this section.

Response:

Reject

The comment is rejected on procedural grounds because it is not specific to a change to PDS-02, which the notice stated were the only requirements open for comment. The entire draft PDS-03 was not open for comment. The committee may consider this proposal in future revisions of the standard.