The following comments have been submitted:
Comment #1Page Number: 1Comment Intent: ObjectionComment Type: GeneralComment: Seems to me the cure is worse than the disease. If you are testing total leakage, then it's only maybe 3 minutes extra to test leakage to outside. It would probably take that long or longer to collect the documentation (photos I suppose) and do the calculations to see if you qualify for the exemption.
Seems to me the cure is worse than the disease. If you are testing total leakage, then it's only maybe 3 minutes extra to test leakage to outside. It would probably take that long or longer to collect the documentation (photos I suppose) and do the calculations to see if you qualify for the exemption.
Comment #2Page Number: 1Paragraph / Figure / Table / Note: Table 4.2.2(1) table note (m)Comment Intent: Not an ObjectionComment Type: EditorialComment: Clarification - the language should state what happens if the conditions for the Duct Leakage to Outside exemption are not met Is the Duct Leakage to Outside deemed to be the measured Total Duct Leakage or Duct Leakage to Outside testing required. Proposed Change: Exception: Duct leakage to outside testing is not required, and duct leakage to outside may be deemed to be half of the measured total leakage when all of the following conditions are documented. If all the following conditions are not met, then XXX is required: XXX - Duct Leakage to Outside is deemed to be the measured Total Duct Leakage or Duct Leakage to Outside testing is required.
Clarification - the language should state what happens if the conditions for the Duct Leakage to Outside exemption are not met
Is the Duct Leakage to Outside deemed to be the measured Total Duct Leakage
or Duct Leakage to Outside testing required.
Exception: Duct leakage to outside testing is not required, and duct leakage to outside may be deemed to be half of the measured total leakage when all of the following conditions are documented. If all the following conditions are not met, then XXX is required:
XXX - Duct Leakage to Outside is deemed to be the measured Total Duct Leakage or Duct Leakage to Outside testing is required.
Comment #3Page Number: 1Comment Intent: Not an ObjectionComment Type: GeneralComment: I think the benefit here is allowing a total leakage test at rough to serve as an allowable and complete duct leakage testing protocol. If: at rough, no building cavities used as ductwork is verified. and at rough, total leakage is <4CFM per 100 sf CFA, and at final, all ductwork and AHU are verifiably inside infiltration volume and at final, envelope tightness is <.15 CFM50 per surface area of infiltration volume You don't have to break out the duct testing equipment and mask off all the registers again at final. You've gotten the benefit of testing at rough which is more helpful in working towards lower leakage numbers in the long run by the installers and gotten the benefit of not requiring reset-up and retest at final for leakage to outside, (because leakage to outside can only (usually) be captured w/ the BD running at final.) Proposed Change: Should the following text change be made? ? Airtightness of the building enclosure shall be less than less than or equal to 0.15 CFM50 per square foot of enclosure area, when tested in accordance with requirements of Standard ANSI/RESNET/ICC 380-2016. The enclosure area is the sum of the areas of the surfaces that bound the Infiltration Volume.
I think the benefit here is allowing a total leakage test at rough to serve as an allowable and complete duct leakage testing protocol.
If:
You don't have to break out the duct testing equipment and mask off all the registers again at final. You've gotten the benefit of testing at rough which is more helpful in working towards lower leakage numbers in the long run by the installers and gotten the benefit of not requiring reset-up and retest at final for leakage to outside, (because leakage to outside can only (usually) be captured w/ the BD running at final.)
Should the following text change be made?
? Airtightness of the building enclosure shall be less than less than or equal to 0.15 CFM50 per square foot of enclosure area, when tested in accordance with requirements of Standard ANSI/RESNET/ICC 380-2016. The enclosure area is the sum of the areas of the surfaces that bound the Infiltration Volume.
Comment #4Page Number: Page 1Comment Intent: ObjectionComment Type: GeneralComment: This is a needed modification for homes having ducts entirely within conditioned space. However, the language is open-ended when the charging paragraph states that all these conditions must be "documented". Whether we like it or not, this language will end up in a code. It is certainly intended to be Normative and enforceable. But code language should be less open to interpretation. As such, I suggest that, if the charging paragraph language is not completely re-written and restructured more as code-intended language, then AT LEAST the charging paragraph should clarify that these conditions: "shall be met and documented."
This is a needed modification for homes having ducts entirely within conditioned space. However, the language is open-ended when the charging paragraph states that all these conditions must be "documented".
Whether we like it or not, this language will end up in a code. It is certainly intended to be Normative and enforceable. But code language should be less open to interpretation.
As such, I suggest that, if the charging paragraph language is not completely re-written and restructured more as code-intended language, then AT LEAST the charging paragraph should clarify that these conditions:
"shall be met and documented."
Comment #5Page Number: 1Paragraph / Figure / Table / Note: Draft PDS-01 BSR/RESNET/ICC 301-2014 Addendum L-20xxComment Intent: ObjectionComment Type: GeneralComment: The first three reqirements for the exception seem to make perfect sense....However, I see no advantage for the last requirement concerning the building's enclosure air tightness level when the other three requirements are all being met. Prove to me how that last requirement modifies the outcome of the leakage to the outside 50% "giveme" result any nore than the outcome of performing the leakage to outdoors test and getting those same results? Also......what if you get a 20cfm LTO result "doing it the hard way" by doing the testing - and get it in a house that is above this air tightness requirement.....how does that fly in the RESNET requirements world? The question is just how does this last requirement impact comfort and energy effiicency when considering the intent of this amendment exception? Proposed Change: Delete this last requirement of the amendment: Airtightness of the building enclosure shall be less than 0.15 CFM50 per square foot of enclosure area, when tested in accordance with requirements of Standard ANSI/RESNET/ICC 380-2016. The enclosure area is the sum of the areas of the surfaces that bound the Infiltration Volume.
The first three reqirements for the exception seem to make perfect sense....However, I see no advantage for the last requirement concerning the building's enclosure air tightness level when the other three requirements are all being met. Prove to me how that last requirement modifies the outcome of the leakage to the outside 50% "giveme" result any nore than the outcome of performing the leakage to outdoors test and getting those same results? Also......what if you get a 20cfm LTO result "doing it the hard way" by doing the testing - and get it in a house that is above this air tightness requirement.....how does that fly in the RESNET requirements world? The question is just how does this last requirement impact comfort and energy effiicency when considering the intent of this amendment exception?
Delete this last requirement of the amendment:
Airtightness of the building enclosure shall be less than 0.15 CFM50 per square foot of enclosure area, when tested in accordance with requirements of Standard ANSI/RESNET/ICC 380-2016. The enclosure area is the sum of the areas of the surfaces that bound the Infiltration Volume.