The following comments have been submitted:
Comment #1Page Number: 9Paragraph / Figure / Table / Note: 4.3Comment Intent: ObjectionComment Type: TechnicalComment: I do not believe that this section takes into account when the air handler is installed in an attic. When the air handler is located in an attic (as is the case in 95% of the homes in Texas) it creates an usafe environment when testing leakage to outside since the attic access door will have to be closed with the person in the attic. Most attics in Texas are only accessable by a scuttle hole or pull down stairs and closing those during a leakage to outside test creates a saftey hazard. I would also like to add that this would be a concern for a crawlspaces as well. Proposed Change: 4.3. Procedure to Install the Test Apparatus and Prepare for Airtightness Test One of two methods shall be used to attach the Duct Leakage Tester to the duct system. Method 1 is permitted to be used for all duct systems. Method 2 is only permitted to be used for duct systems with three or fewer return grilles, unless Exception 1, 2 or 3 applies. Method 1 Installation. The air handler blower access panel shall be removed and the Duct Leakage Tester attached to the blower compartment access. Method 2 Installation. The Duct Leakage Tester shall be attached to the return grille closest to the air handler. The remaining openings in the return grilles shall be temporarily sealed. Exception 1: Method 2 is permitted to be used for duct systems with more than three returns if local codes require licensing, in order to remove the blower access panel and the party conducting the test has not obtained such licensing. Exception 2: Method 2 is permitted to be used for duct systemswith more than three returns provided that the total duct leakage when measured with this method is less than 50 CFM (25 L/s) at 25 Pa Exception 3: Method 2 is permitted to be used for duct systems when the air handler is located in an attic or crawlspace.
I do not believe that this section takes into account when the air handler is installed in an attic. When the air handler is located in an attic (as is the case in 95% of the homes in Texas) it creates an usafe environment when testing leakage to outside since the attic access door will have to be closed with the person in the attic. Most attics in Texas are only accessable by a scuttle hole or pull down stairs and closing those during a leakage to outside test creates a saftey hazard. I would also like to add that this would be a concern for a crawlspaces as well.
4.3. Procedure to Install the Test Apparatus and Prepare for Airtightness Test
One of two methods shall be used to attach the Duct Leakage Tester to the duct system. Method 1 is permitted to be used for all duct systems. Method 2 is only permitted to be used for duct systems with three or fewer return grilles, unless Exception 1, 2 or 3 applies.
Exception 1: Method 2 is permitted to be used for duct systems with more than three returns if local codes require licensing, in order to remove the blower access panel and the party conducting the test has not obtained such licensing.
Exception 2: Method 2 is permitted to be used for duct systemswith more than three returns provided that the total duct leakage when measured with this method is less than 50 CFM (25 L/s) at 25 Pa
Exception 3: Method 2 is permitted to be used for duct systems when the air handler is located in an attic or crawlspace.
Comment #2Page Number: ?Comment Intent: Not an ObjectionComment Type: GeneralComment: I am not thinking that anything needs to be changed but adding some options for a safe crawlspace inspection by using a drone http://www.electric.coop/drone-makes-energy-audits-easier/ . I have been using this drone for about a year and it has made a crawlspace inspection much safer. Just an idea
I am not thinking that anything needs to be changed but adding some options for a safe crawlspace inspection by using a drone http://www.electric.coop/drone-makes-energy-audits-easier/ . I have been using this drone for about a year and it has made a crawlspace inspection much safer. Just an idea
Comment #3Page Number: 9Paragraph / Figure / Table / Note: 4.3Comment Intent: ObjectionComment Type: TechnicalComment: Section 4.3 is a concern with regard to air handling equipment that is located in attic spaces. This process requires a Rater to setup and implement a duct leakage test inside of a confined attic space which is extremely dangerous and difficult. Many attic spaces are scuttle holes that will require a Rater to utilize a 6’ to 8’ ladder to gain access. Hauling testing equipment up a ladder and through an access scuttle is arduous and with the temperatures in unconditioned attics in the desert southwest is extremely dangerous. Raters are technicians, not equipment grips, and safety should be a significant concern for RESNET. We should exempt testing in confined unconditioned attic spaces. Additionally, many of the current HVAC designs that builders utilize today have dedicated returns in each bedroom to help assure adequate pressure balancing. In several cases, we can have three to five bedrooms in a home with dedicated returns. Based on this standard, we would be required to have a measurement of 50 CFM or less. By attaching the duct tester to the air handler blower access panel we are removing leakage at the highest pressure point on the system. This makes no sense. By attaching the duct tester to the return register we are now including any leakage from the air handler and are expected to get a lower duct leakage result. We would like to suggest a second exemption regarding number of returns in a home. Builders should not be penalized on the Duct Leakage Test for having an HVAC System that provides better balancing of pressure. In many cases, a home with multiple returns on one system typically includes a main return with additional bedroom returns. Since the bedrooms tend to have smaller return ducts, we would like to recommend an exemption of return ducts that pull less than 150 CFM from the total return count. Section 4.3 would also make it virtually impossible to properly monitor the blower door CFM which is necessary for the leakage to outside test. Conducting this particular test for a home that has a vented attic would require the rater to exit the attic space and conduct the leakage to the outside test in a return register located in the in the main body of the home and close the attic access hatch which would result in additional time requirements for air tightness testing. Proposed Change: 4.3. Procedure to Install the Test Apparatus and Prepare for Airtightness Test One of two methods shall be used to attach the Duct Leakage Tester to the duct system. Method 1 is permitted to be used for all duct systems. Method 2 is only permitted to be used for duct systems with three or fewer return grilles, unless Exception 1, 2 or 3 applies. Method 1 Installation. The air handler blower access panel shall be removed and the Duct Leakage Tester attached to the blower compartment access. Method 2 Installation. The Duct Leakage Tester shall be attached to the return grille closest to the air handler. The remaining openings in the return grilles shall be temporarily sealed. Exception 1: Method 2 is permitted to be used for duct systems with more than three returns if local codes require licensing, in order to remove the blower access panel and the party conducting the test has not obtained such licensing. Exception 2: Method 2 is permitted to be used for duct systemswith more than three returns provided that the total duct leakage when measured with this method is less than 50 CFM (25 L/s) at 25 Pa Revision to Exception 2: Remove requirement of 50 CFM limit on systems with more than 3 return grills for systems located in unconditioned attic spaces. Exception 3: Add language that exempts returns of 150 CFM or less from the 50 CFM duct leakage requirement in exemption 2.
Section 4.3 is a concern with regard to air handling equipment that is located in attic spaces. This process requires a Rater to setup and implement a duct leakage test inside of a confined attic space which is extremely dangerous and difficult. Many attic spaces are scuttle holes that will require a Rater to utilize a 6’ to 8’ ladder to gain access. Hauling testing equipment up a ladder and through an access scuttle is arduous and with the temperatures in unconditioned attics in the desert southwest is extremely dangerous. Raters are technicians, not equipment grips, and safety should be a significant concern for RESNET. We should exempt testing in confined unconditioned attic spaces. Additionally, many of the current HVAC designs that builders utilize today have dedicated returns in each bedroom to help assure adequate pressure balancing. In several cases, we can have three to five bedrooms in a home with dedicated returns. Based on this standard, we would be required to have a measurement of 50 CFM or less. By attaching the duct tester to the air handler blower access panel we are removing leakage at the highest pressure point on the system. This makes no sense. By attaching the duct tester to the return register we are now including any leakage from the air handler and are expected to get a lower duct leakage result. We would like to suggest a second exemption regarding number of returns in a home. Builders should not be penalized on the Duct Leakage Test for having an HVAC System that provides better balancing of pressure. In many cases, a home with multiple returns on one system typically includes a main return with additional bedroom returns. Since the bedrooms tend to have smaller return ducts, we would like to recommend an exemption of return ducts that pull less than 150 CFM from the total return count. Section 4.3 would also make it virtually impossible to properly monitor the blower door CFM which is necessary for the leakage to outside test. Conducting this particular test for a home that has a vented attic would require the rater to exit the attic space and conduct the leakage to the outside test in a return register located in the in the main body of the home and close the attic access hatch which would result in additional time requirements for air tightness testing.
Revision to Exception 2: Remove requirement of 50 CFM limit on systems with more than 3 return grills for systems located in unconditioned attic spaces.
Exception 3: Add language that exempts returns of 150 CFM or less from the 50 CFM duct leakage requirement in exemption 2.
Comment #4Page Number: allComment Intent: ObjectionComment Type: GeneralComment: The upcoming 2018 IECC can only reference the version of BSR/RESNET/ICC 380-2016 that was submitted for approval in the ICC development process. This new version of 380 will be different than that referenced in the IECC. If approved, RESNET should not claim that the new version is referenced in the IECC. Do not create a new version of 380. Accumulate any desired changes to 380 and make them all before the next round of IECC changes then submit the changed 380 into the ICC development process for reference in the IECC. If RESNET does not take the suggestion above, then insert a note or send a flyer with every 380 document sold with the information that this is not the version referenced in the referenced in the 2018 IECC. Also make sure that the IECC referenced version is still available. Proposed Change: Hold this change until ICC Group B code cycle (includes IECC). Make this and any other changes to 380 such that the new 380 can be submitted into the ICC code development cycle for the IECC.
The upcoming 2018 IECC can only reference the version of BSR/RESNET/ICC 380-2016 that was submitted for approval in the ICC development process. This new version of 380 will be different than that referenced in the IECC. If approved, RESNET should not claim that the new version is referenced in the IECC.
Do not create a new version of 380. Accumulate any desired changes to 380 and make them all before the next round of IECC changes then submit the changed 380 into the ICC development process for reference in the IECC.
If RESNET does not take the suggestion above, then insert a note or send a flyer with every 380 document sold with the information that this is not the version referenced in the referenced in the 2018 IECC. Also make sure that the IECC referenced version is still available.
Hold this change until ICC Group B code cycle (includes IECC). Make this and any other changes to 380 such that the new 380 can be submitted into the ICC code development cycle for the IECC.