The following comments have been submitted:
Comment #1Page Number: 7Comment Intent: Not an ObjectionComment Type: TechnicalComment: Proposed Change:
Comment #2Page Number: 13 to 17Paragraph / Figure / Table / Note: 4.3.3 and 4.4 and 4.5Comment Intent: Not an ObjectionComment Type: EditorialComment: Guarded testing is an important part of our business practice and I want to make sure we are allowed a clear and manageable method to accomplish it that doesn't raise our cost of doing business or reduce the accuracy of infiltration measurements that we have been consistently providing for 10+ years using guarded testing. Section 4.3.3 seems to allow guarded testing (simultaneous multi-zone) if the Air Barrier Association of America Standard Method for Building Enclosure Airtightness Compliance Testing is followed. The ABAA standard method has it's own methodology for setting up and conducting the test and section 4.3.3 says the test shall be conducted according to this standard method. The ABAA standard method includes the three allowable test methods: multipoint regression (based on ASTM E779),repeated single point (based on ASTM E1827) and repeated two-point pressure testing (based on ASTM E1827). Section 4.4 details how to run single point and multi point testing. I think this section doesn't apply if 4.3.3 is being used, otherwise they are potentially in conflict. Section 4.5 gives guidance on how to adjust results for single point testing. I think this shoudl also not apply if 4.3.3 is being followed. I'm not sure I understand the rational for externalizing this methodology for guarded testing from the more explicit RESNET standard, but if that is in fact happening, then I think Sections 4.4 and 4.5 should be not applicable when Section 4.3.3 is followed. Guarded testing is an important part of our business practice and I want to make sure we are allowed a clear and manageable method to accomplish it that doesn't raise our cost of doing business or reduce the accuracy of infiltration limits that we have been consistantly providing for 10 years using guarde testing. Proposed Change: 4.4. Procedure to Conduct Airtightness Test. The leakage of the enclosure shall be measured using either the One-Point Airtightness Test in Section 4.4.1 or the Multi-Point Airtightness Test in Section 4.4.2. Alternatively, if test apparatus and prepration follow Section 4.3.3, the procedure of the Air Barrier Association of America Standard Method for Building Enclosure Airtightness Compliance Testing shall be followed 4.5. Procedure to Apply Results of Enclosure Air Leakage Test. 4.5.1. If the results of the building or Dwelling Unit enclosure air leakage test are to be used for conducting an energy rating or assessing compliance with a building or Dwelling Unit enclosure leakage limit27, 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 43.4.1.6 for a one-point air leakage test shall be adjusted using Equation 6. Adjusted ELA = 1.1 x ELA (6) Other applications of building or Dwelling Unit enclosure air leakage testing and the results of multi-point testing do not require the corrections in this section. Testing conducted with the Air Barrier Association of America Standard Method for Building Enclosure Airtightness Compliance Testing shall also not require this correction. 4.5.2. If the results of the building or Dwelling Unit enclosure leakage test are to be converted to Air Changes Per Hour at 50 Pa (0.2 in. H2O) (ACH50), Specific Leakage Area (SLA), or Normalized Leakage Area (NLA), or compartmentalization leakage ratio at 50 Pa (CFM50/ft2 ), then Equations 7 through 910 shall be used. Where adjusted or corrected CFM50, CMS50 or ELA values have been calculated in previous sections they shall be used in Equations 7 through 10. ACH50 = Adjusted CFM50 x 60 / Infiltration Volume in cubic feet (7a) ACH50 = Adjusted CMS50 x 3600 / Infiltration Volume in cubic meters (7b) SLA = 0.00694 x ELA in in2 / Conditioned Floor Area in square feet (8a) SLA = 10.764 x ELA in m2 / Conditioned Floor Area in square meters (8b)NLA = SLA x (S)0.4, where S is the number of stories above grade (9) CFM50/ft2 = CFM50 / Compartmentalization Boundary area in square feet (10) Testing conducted with the Air Barrier Association of America Standard Method for Building Enclosure Airtightness Compliance Testing shall also not require this correction.
Guarded testing is an important part of our business practice and I want to make sure we are allowed a clear and manageable method to accomplish it that doesn't raise our cost of doing business or reduce the accuracy of infiltration measurements that we have been consistently providing for 10+ years using guarded testing.
Section 4.3.3 seems to allow guarded testing (simultaneous multi-zone) if the Air Barrier Association of America Standard Method for Building Enclosure Airtightness Compliance Testing is followed.
The ABAA standard method has it's own methodology for setting up and conducting the test and section 4.3.3 says the test shall be conducted according to this standard method.
The ABAA standard method includes the three allowable test methods: multipoint regression (based on ASTM E779),repeated single point (based on ASTM E1827) and repeated two-point pressure testing (based on ASTM E1827).
Section 4.4 details how to run single point and multi point testing. I think this section doesn't apply if 4.3.3 is being used, otherwise they are potentially in conflict.
Section 4.5 gives guidance on how to adjust results for single point testing. I think this shoudl also not apply if 4.3.3 is being followed.
I'm not sure I understand the rational for externalizing this methodology for guarded testing from the more explicit RESNET standard, but if that is in fact happening, then I think Sections 4.4 and 4.5 should be not applicable when Section 4.3.3 is followed.
Guarded testing is an important part of our business practice and I want to make sure we are allowed a clear and manageable method to accomplish it that doesn't raise our cost of doing business or reduce the accuracy of infiltration limits that we have been consistantly providing for 10 years using guarde testing.
4.4. Procedure to Conduct Airtightness Test. The leakage of the enclosure shall be measured using either the One-Point Airtightness Test in Section 4.4.1 or the Multi-Point Airtightness Test in Section 4.4.2. Alternatively, if test apparatus and prepration follow Section 4.3.3, the procedure of the Air Barrier Association of America Standard Method for Building Enclosure Airtightness Compliance Testing shall be followed
4.5. Procedure to Apply Results of Enclosure Air Leakage Test.
4.5.1. If the results of the building or Dwelling Unit enclosure air leakage test are to be used for conducting an energy rating or assessing compliance with a building or Dwelling Unit enclosure leakage limit27, 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 43.4.1.6 for a one-point air leakage test shall be adjusted using Equation 6. Adjusted ELA = 1.1 x ELA (6) Other applications of building or Dwelling Unit enclosure air leakage testing and the results of multi-point testing do not require the corrections in this section.
Testing conducted with the Air Barrier Association of America Standard Method for Building Enclosure Airtightness Compliance Testing shall also not require this correction.
4.5.2. If the results of the building or Dwelling Unit enclosure leakage test are to be converted to Air Changes Per Hour at 50 Pa (0.2 in. H2O) (ACH50), Specific Leakage Area (SLA), or Normalized Leakage Area (NLA), or compartmentalization leakage ratio at 50 Pa (CFM50/ft2 ), then Equations 7 through 910 shall be used. Where adjusted or corrected CFM50, CMS50 or ELA values have been calculated in previous sections they shall be used in Equations 7 through 10. ACH50 = Adjusted CFM50 x 60 / Infiltration Volume in cubic feet (7a) ACH50 = Adjusted CMS50 x 3600 / Infiltration Volume in cubic meters (7b) SLA = 0.00694 x ELA in in2 / Conditioned Floor Area in square feet (8a) SLA = 10.764 x ELA in m2 / Conditioned Floor Area in square meters (8b)NLA = SLA x (S)0.4, where S is the number of stories above grade (9) CFM50/ft2 = CFM50 / Compartmentalization Boundary area in square feet (10)
Comment #3Page Number: 8Paragraph / Figure / Table / Note: Section 3 - DefinitionsComment Intent: Not an ObjectionComment Type: TechnicalComment: Proposed Change: New definition of "compartmentalization boundary" proposed: - The surface that bounds the Infiltration Volume of the dwelling unit.
New definition of "compartmentalization boundary" proposed:
- The surface that bounds the Infiltration Volume of the dwelling unit.
Comment #4Page Number: 25Paragraph / Figure / Table / Note: 6.Comment Intent: ObjectionComment Type: TechnicalComment: The house setup for the blower door and duct testing are carefully detailed in those sections of this standard. How the house is setup has a major impact on ventilation device performance - open or closed windows and doors and the operation of other mechanical systems greatly change the measured flow performance of both dwelling unit and local exhaust fan products. Without that information, the detailed testing procedures are suspect at best. Proposed Change: Insert under the opening paragraph: Set up for mechanical ventilation testing by following section 4.2 Procedure to Prepare the Building or Dwelling Unit for Testing.
The house setup for the blower door and duct testing are carefully detailed in those sections of this standard. How the house is setup has a major impact on ventilation device performance - open or closed windows and doors and the operation of other mechanical systems greatly change the measured flow performance of both dwelling unit and local exhaust fan products. Without that information, the detailed testing procedures are suspect at best.
Insert under the opening paragraph:
Set up for mechanical ventilation testing by following section 4.2 Procedure to Prepare the Building or Dwelling Unit for Testing.
Comment #5Page Number: 20Paragraph / Figure / Table / Note: Procedures to Conduct Air Tightness TestComment Intent: Not an ObjectionComment Type: TechnicalComment: Proposed Change:
Comment #6Page Number: 20Paragraph / Figure / Table / Note: Procedures to Conduct Air Tightness TestComment Intent: Not an ObjectionComment Type: TechnicalComment: Proposed Change:
Comment #7Page Number: 0Paragraph / Figure / Table / Note: TitleComment Intent: ObjectionComment Type: EditorialComment: Change the title to better reflect a list inside of a list and improve clarity. Proposed Change: Standard for Testing Airtightness of Building, Dwelling Unit, and Sleeping Unit Enclosures,; Airtightness of Heating and Cooling Air Distribution Systems,; and Airflow of Mechanical Ventilation Systems
Change the title to better reflect a list inside of a list and improve clarity.
Comment #8Page Number: 2Paragraph / Figure / Table / Note: 2.1Comment Intent: ObjectionComment Type: EditorialComment: Change the phrasing of the first sentence to better reflect a list inside of a list and improve clarity. Proposed Change: This standard defines procedures for measuring the airtightness of building, Dwelling Unit, and Sleeping Unit Enclosures,; the airtightness of heating and cooling air distribution systems,; and the airflow of mechanical ventilation systems.
Change the phrasing of the first sentence to better reflect a list inside of a list and improve clarity.
This standard defines procedures for measuring the airtightness of building, Dwelling Unit, and Sleeping Unit Enclosures,; the airtightness of heating and cooling air distribution systems,; and the airflow of mechanical ventilation systems.
Comment #9Page Number: 6Paragraph / Figure / Table / Note: 4.1.1Comment Intent: ObjectionComment Type: EditorialComment: Replace "unit" with "Dwelling Unit." Proposed Change: A fan that is capable of moving air into or out of the building or Dwelling Uunit to achieve one or more target pressure differences between the building or Dwelling Unit and the exterior.
Replace "unit" with "Dwelling Unit."
A fan that is capable of moving air into or out of the building or Dwelling Uunit to achieve one or more target pressure differences between the building or Dwelling Unit and the exterior.
Comment #10Page Number: 8Paragraph / Figure / Table / Note: 4.2.9Comment Intent: ObjectionComment Type: EditorialComment: Only mention attic fans once in the list of fans that shall be turned off. Proposed Change: Any fan or appliance capable of inducing airflow across the building or Dwelling Unit enclosure shall be turned off including, but not limited to, clothes dryers, attic and crawlspace fans, kitchen and bathroom exhaust fans, air handlers,and ventilation fans used in a Dwelling-Unit Mechanical Ventilation system, and crawlspace and attic ventilation fans.
Only mention attic fans once in the list of fans that shall be turned off.