Review of Substantive Changes to BSR/RESNET 301-2013 Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: 8; 14-15; 49-50; 54
Paragraph / Figure / Table / Note: 3.2; 4.1.2; 4.5.4; 5.1.1.4
Comment Type: Editorial

Comment:

As a result of the initial public review of the Standard, Comment #49 was accepted by the consensus committee as follows:

“Accepted. The definition and all references to the term “Reference Electricity Production Efficiency” will be struck and the requirements specified by the definition will be moved to Sections 4.1.2 and 4.5.4 of BSR/RESNET Standard 301-201x.”

The editorial modifications made to the Final Draft Standard as a result of accepting Comment #49 are not explicitly clear with respect to how the electrical conversion efficiency is to be applied in the Standard. Section 4.1.2, Sections 4.5.4.1 through 4.5.4.3 and Section 5.1.1.4 were directly impacted by removal of the definition of “Reference Electricity Production Efficiency” and should have been modified so as to be explicitly clear as to how calculations are to be performed. Additionally, the definition of On-Site Power Production (OPP) also requires clarification as a result of removal of the term “Reference Electricity Production Efficiency.”

Proposed Change:

3.2   Definitions

On-Site Power Production (OPP) – Electric power produced at the site of a Rated Home.  OPP shall be the net electrical power production, such that it equals the gross electrical power production minus any purchased fossil fuel energy used to produce the on-site power, converted to equivalent electricity energy use at a 40% conversion efficiency in accordance with Equation 4.1-3.

4.1.2  Calculating the HERS Index.  The HERS Index shall be determined in accordance with Equation 4.1-2:       

      HERS Index = PEfrac * (TnML / TRL) * 100                                            (Eq 4.1-2)

where:

TnML =   nMEUL_HEAT + nMEUL_COOL + nMEUL_HW + EUL_LA (MBtu/y).

   TRL =   REUL_HEAT + REUL_COOL + REUL_HW + REUL_LA (MBtu/y).

and where:

 EUL_LA =   The Rated Home end use loads for lighting, appliances and MELs as defined by Section 4.2.2.5.2, converted to MBtu/y, where MBtu/y = (kWh/y)/293 or (therms/y)/10, as appropriate.

REUL_LA = The Reference Home end use loads for lighting, appliances and MELs as defined by Section 4.2.2.5.1, converted to MBtu/y, where MBtu/y = (kWh/y)/293 or (therms/y)/10, as appropriate.

and where:

PEfrac =  (TEU - OPP) / TEU

TEU =   Total energy use of the Rated Home including all rated and non-rated energy features where all fossil fuel site energy uses (Btu_fossil) are multiplied by 40%converted to equivalent electric energy use (kWh_eq) in accordance with Equation 4.1-3.

OPP =  On-Site Power Production as defined by Section 5.1.1.4 of this Standard.

  kWh_eq = (Btu_fossil * 0.40) / 3412                                            (Eq 4.1-3)

 

4.5.4.1   Energy units used in the calculation of energy savings shall be the total whole-house energy use of all fuels (kWh_tot) calculated using in accordance with Equation 4.5-1.

 kWh_tot = kWh_elec + kWh_eq                                                             (Eq 4.5-1)

where

kWh_tot = total whole-house energy use of all fuels used by the home

kWh_elec = whole-house electric energy used by the home

kWh_eq = whole-house fossil fuel energy used by the home converted to equivalent electric energy use in accordance with Equation 4.1-3

4.5.4.2   Whole-house Eenergy savings (kWh_tot) shall be calculated as the difference between the total whole-house projected energy use (kWh_tot) of the Baseline Existing Home and the total whole-house projected energy use (kWh_tot) of the Improved Home.

4.5.4.3   The energy savings percentage of the retrofit shall be calculated as the whole-house total energy savings (kWh_tot) as determined by Section 4.5.4.2 divided by the whole-house total energy use (kWh_tot) of the Baseline Existing Home.

 

5.1.1.4   If the Rated Home includes On-site Power Production (OPP), then OPP shall be calculated as the gross electric power produced minus 40% of the equivalent electric energy use content of any purchased fossil fuels used to produce the electric power in accordance with Equation 4.1-3.[1]  The HERS Reference Home shall not include On-site Power Production.

 

Response:

Accepted. Improves clarity of Standard

Comment #2

Page Number: 12-13
Paragraph / Figure / Table / Note: Table 4.2.2(1)
Comment Type: Editorial

Comment:

Due to accepted change that requires blower door testing for all confirmed ratings, the reference to "residences that are not tested" should be removed from the Air Exchange Rate section of Table 4.2.2(1)

Proposed Change:

In the "Rated Home" column:

For residences that are not tested, the same as the HERS Reference Home

Response:

Accepted as Modified. Improves clarity of Standard. Modified to make the same alteration for Rated Home in Air Distribution System section of Table 4.2.2(1)

Comment #3

Page Number: Various
Paragraph / Figure / Table / Note: Various
Comment Type: Editorial

Comment:

ASHRAE Standard 62.2-2013 has been recently published by ASHRAE. The RESNET Standard references ASHRAE 62.2-2010, Addendum 'r' in numerous locations throughout the document. With the publication of 62.2-2013, which fully incorporates addendum 'r' from the 2010 version, these references should be edited to reference ASHRAE 62.2-2013 and the Normative Reference sectin of th standard should be updated accordingly.

Proposed Change:

Make the following editorial correction in various locations thorughout the Standard:

ASHRAE Standard 62.2-2010, Addendum 'r' ASHRAE Standard 62.2-2013

Modify Section 6, Normative References to add the following reference standard:

ANSI/ASHRAE 62.2-2013, “Ventilation and Acceptable Indoor Air Quality in Low Rise Buildings.” American Society of Heating, Refrigerating, and Air Conditioning Engineers, Atlanta, GA, 2013.

Response:

Accepted. Updates reference standard to most recent version

Comment #4

Page Number: 58
Paragraph / Figure / Table / Note: 5.1.4.1. Confirmed Rating
Comment Type: Technical

Comment:

I received an email from RESNET that my comment #22 (in the original comment period) had been accepted with the following change in the definition of a confirmed rating:

“Confirmed Rating – A Rating Type accomplished using the actual data gathered from an on-site audit inspection and, if required, performance testing of the physical building and its installed systems and equipment including, at a minimum, air distributions system testing and envelope leakage testing.”

 

Even though RESNET sent an email that this was accepted into the standard, it was not.  I think the issue is that the defintion of a confirmed rating was striken from the terms section and moved to Rating Type section 5.1.4.1.

 

Proposed Change:

 

 

Response:

Rejected. Proposed change is redundant and is fully covered by Sections 5.1.4.1.2 and Section 4.4

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #5

Page Number: 16
Paragraph / Figure / Table / Note: Table 4.2.2(1); Crawlspaces
Comment Type: Editorial

Comment:

The 2006 IRC, Section 408.3.1 is refereneced in this section. The 2006 is not the latest edition of the IRC and the Standard should be modified to reflect the latest edition of the IRC. Additionally the IRC is not lised as on of the normative references to this standard and it should be.

Proposed Change:

Building Component	HERS Reference Home	Rated Home
Crawlspaces:	Type:  vented with net free vent aperture = 1ft2 per 150 ft2 of crawlspace floor area.         U-factor:  from Table 4.2.2(2) for floors over unconditioned spaces.	Same as the Rated Home, but not less net free ventilation area than the Reference Home unless an approved ground cover in accordance with 20062012 IRC 408.3.1 is used, in which case, the same net free ventilation area as the Rated Home down to a minimum net free vent area of 1ft2 per 1,500 ft2 of crawlspace floor area. Same as Rated Home

Add the following to Section 6, Normative References:

ICC, 2012, “2012 International Residential Code.” International Code Council, 500 New Jersey Avenue, NW, Washington, DC.

Response:

Accepted. Updates reference standard to most recent version

Comment #6

Page Number: 1
Paragraph / Figure / Table / Note: Forward
Comment Type: Technical

Comment:

REASON:  If the local code in the 2003 IECC I don’t think it is correct to say that a HERS Index of 101 or 190 indicates compliance with the code.  Likewise, if the local code is the 2012 IECC it is not correct to say that a HERS Index of 99 is code equivalent.  As currently written the forward could be interpreted incorrectly.

Proposed Change:

The HERS Reference Home used for this comparative analysis has the energy attributes of the 2006 International Energy Conservation Code (IECC) Standard Reference Design. Thus, the HERS Index is relative to the minimum building energy efficiency requirements of the 2006 IECC. As a result, the HERS Reference Home performance will not comport with state or local building codes that differ in stringency from the 2006 IECC. Where local building energy codes are less stringent than the 2006 IECC, the HERS Index for the local standard will be equal to or less than some undetermined number greater than 100 and where local building energy codes that are more stringent than the 2006 IECC, the HERS Index for the local standard will be equal to or less than some undetermined number less than 100.

Response:

Rejected. Proposed language is less clear than original language (see also comment #32)

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #7

Page Number: 3
Paragraph / Figure / Table / Note: Definitions
Comment Type: Technical

Comment:

REASON:  The definition does not specify 70 square feet of what? wall?  The Standard needs to be more specific and specify floor area.

Proposed Change:

Bedroom – A room or space 70 square feet of floor area or greater, with egress window and closet, used or intended to be used for sleeping.  A "den", "library," "home office" with a closet, egress window, and 70 square feet of floor area or greater or other similar rooms shall count as a Bedroom, but living rooms and foyers shall not.

Response:

Accepted. Improves clarity of Standard

Comment #8

Page Number: 12
Paragraph / Figure / Table / Note: 3.3
Comment Type: Editorial

Comment:

REASON:  It is my understanding that ASHRAE is no longer an acronym and that the ASHRAE name now stands on its own.

Proposed Change:

ASHRAE – American Society of Heating, Refrigerating and Air Conditioning Engineers, Inc.

Response:

Rejected. Reduces clarity of the Standard

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #9

Page Number: 27
Paragraph / Figure / Table / Note: 4.2.2.2.2
Comment Type: Editorial

Comment:

REASON:  I can’t think of an application where loose fill is not placed within a cavity this is misleading.  Since this language is listed as in example it should be editorial to remove it.

Proposed Change:

(a) Insulation that does not cover framing members shall not be modeled as if it covers the framing. Insulated surfaces that have continuous insulation (i.e. rigid foam, fibrous batt, loose fill, sprayed insulation or insulated siding) covering the framing members shall be assessed and modeled according to Section 4.2.2.2 and combined with the cavity insulation, framing and other materials to determine the overall assembly R-value.

Response:

Rejected. Inaccurate proposal. Loose fill insulation can cover framing members, specifically in ceiling insulation applications where it covers the bottom chord of attic trusses.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #10

Page Number: 28
Paragraph / Figure / Table / Note: 4.2.2.2.2
Comment Type: Technical

Comment:

REASON:  These methods are the most appropriate and will not allow the potential gaming that the other methods listed would allow.  For example, if test results can be altered where will the altering end?  Is it ok to add insulation even if there is an inch of open air space between layers?  The answer is no it is not appropriate and should not be allowed.

Proposed Change:

 (d) The overall thermal properties of steel-framed walls, ceilings and floors shall be basedcalculated in accordance with the modified zone method specified by Chapter 27, 2009 ASHRAE Handbook of Fundamentals or tested in accordance with ASTM Standard C-1363-11.

 one of the following calculation methods:

1) A series path calculation in accordance with Section 5.5, ASHRAE Standard 90.2-2007.

2) Testing in accordance with ASTM Standard C-1363-11. Test results may be modified to add or subtract R-values to the tested assembly to reflect differences between the tested assembly and proposed assemblies when such differences occur outside of the cavity.

4.2.2.2.6.3) For clear wall assemblies (without door or window headers and jack or king studs), in accordance with the modified zone method specified by Chapter 27, 2009 ASHRAE Handbook of Fundamentals

Response:

Accepted as Modified. Improves clarity of Standard and reduces potential for gaming. Modified to strike all sub paragraphs, update ASHRAE Standard reference to current year and include editorial provisions from Comment #55 into same section, as follows:

“(d) The overall thermal properties of steel-framed walls, ceilings and floors shall be based calculated in accordance with the modified zone method specified by Chapter 27, 2013 ASHRAE Handbook of Fundamentals or tested in accordance with ASTM Standard C-1363-11. Test results may be modified to add or subtract R-values to the tested assembly to that reflect differences between the tested assembly and proposed assemblies when such differences are continuous and occur outside of the cavity.

Comment #11

Page Number: 9
Paragraph / Figure / Table / Note: 3.2 Definitions
Comment Type: Editorial

Comment:

REASON:  This revised definition is more consistent with the definition found in the IgCC.  The credit for renewable energy production should be limited to that which is produced on-site as seems to be the intention of the standard.  This clarification should be made.

Proposed Change:

On-Site Renewable Energy System – Means of transforming solar thermal energy or producing electric power that rely on naturally-occurring, on-site resources that are not depleted as a result of their use. Renewable Energy Systems shall include, but are not limited to, solar energy systems, wind energy systems and geothermal energy systems.

A system located on the building or building site and that generates energy for use on the building site or to send back to the energy supply system.  The system derives its energy from solar radiation, wind, waves, tides, biogas, biomass, or geothermal energy. 

Response:

Rejected. Original definition specifies “on-site” resources and is more explicit. There is no reason that this Standard must “more consistent” with the IgCC.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #12

Page Number: All
Comment Type: General

Comment:

With all of the significant editorial and technical changes to this document, it should have been released as a 2nd Public Draft in its entirety.

Proposed Change:

Release the entire standard as a public draft so that all parties may provide input to the entire standard.

Response:

Rejected. There is no requirement to re-open sections of the document that did not result in substantive changes as a result of the 1^st round of public comments. This would likely result in endless review.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #13

Page Number: i
Paragraph / Figure / Table / Note: Table of Contents
Comment Type: Editorial

Comment:

Change "4.3.5 Ground Source Heat Pumps" to
"4.3.5 Ground Source or Geothermal Heat Pumps"

Proposed Change:

This will add clarity to the standard, as these units are often call "geothermal" systems.

Response:

Rejected. A “geothermal” heat pump can be considered a ground source heat pump but most true geothermal energy systems are not heat pumps but rather are energy systems that are used directly for their heat content, either as district heating or for steam turbine electrical generation.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #14

Page Number: 1
Comment Type: Technical

Comment:

This Standard provides a consistent, uniform methodology for evaluating and labeling the energy performance of residences

Proposed Change:

There is no information in the standard about how to create a HERS label, what the label should look like, how it should be used.

Response:

Accept as Modified. A new Section 5.3 on minimum labeling standards will be added to the Standard to resolve this comment (see also comment #62). Section 5.3 is proposed as follows:

“5.3  Labeling. Home energy rating labels shall, at a minimum, contain the information specified by Sections 5.3.1 through 5.3.6

5.3.1  Real property physical address of the home, including city and state or territory

5.3.2  HERS Index Score of the home

5.3.3  Projected energy use of the home by fuel type

5.3.4  Projected energy cost of the home, calculated in accordance with energy price rate provisions of Section 5.1.2.1.2.

5.3.5  Name and address of the Approved Rating Provider

5.3.6  Date of the home energy rating.”

Comment #15

Page Number: 2
Paragraph / Figure / Table / Note: 3.2
Comment Type: Technical

Comment:

Revise the following definition:

Annual Fuel Utilization Efficiency; (AFUE) –a measure of the efficiency of gas or oil  fired furnaces and boilers calculated as the furnace heating energy output divided by fuel energy input. AFUE does not include electrical energy for fans, pilot lights, or electronic ignition systems (see also Electric Auxiliary Energy).

Proposed Change:

Residential boilers and non-gas heating systems are also rated with AFUE.  Also, no electric energy is used for gas pilot lights.

Response:

Accepted. Improves clarity of Standard.

Comment #16

Page Number: 3
Paragraph / Figure / Table / Note: 3.2
Comment Type: Editorial

Comment:

Modify the following definition:

 

Bedroom – A room or space 70 square feet or greater, with at least 1 egress window and closet, used or intended to be used for sleeping

Proposed Change:

This will add clarity to the standard.

Response:

Rejected. Does not improve clarity. Requirement for egress window already included is provision.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #17

Page Number: 3
Paragraph / Figure / Table / Note: 3.2 Definitions
Comment Type: Technical

Comment:

This will make the definition more inclusive and reflect the different types of biomass systems (e.g., anaerobic digesters) that can be used.

 

 

Proposed Change:

Revise the following definition:

 

Biomass Fuel – Plant or animal waste materials that have been processed to be capable of providing useful heat through combustion.

Response:

Accepted. Improves clarity of Standard.

Comment #18

Page Number: 7
Paragraph / Figure / Table / Note: 3.2 Definitions
Comment Type: Technical

Comment:

Please revise the definition as shown.  There are miscellaneous energy loads in homes that use fossil fuels and other loads that use electricity.  Both can be in homes.  This definition will be all inclusive of all miscellaneous loads and will make the standard more technically accurate.

Proposed Change:

 

 

Miscellaneous Electric Energy Loads (MELs) – Electrical energy uses that are not attributable to space heating, space cooling, hot water heating or well-defined energy uses of specific appliances that have a large saturation in homes, such as refrigerators and gas fireplaces.

 

Response:

Accept as Modified. Strike “and gas fireplaces” as they do not have large saturation in homes as other major appliances do.

Comment #19

Page Number: 7-8
Paragraph / Figure / Table / Note: 3.2 Definitions
Comment Type: Editorial

Comment:

Please revise the definition to more accurately reflect all of the federal legislation on appliance energy efficiency standards, especially with the standards or rulemakings set by the Energy Independence and Security Act of 2007.

Proposed Change:

National Appliance Energy Conservation Act (NAECA) – Legislation by the United States Congress that regulates energy consumption of specific household appliances in the United States, first passed as the Energy Policy and Conservation Act in 1975 (Public Law 100-12 94-163) and amended in 1987 and 1988 (Public Laws 100-12 and 100-357), 1992 (Public Law 102-486) and 2005 (Public Law 109-58) and 2007 (Public Law 110-140).

Response:

Accepted. Improves clarity of Standard.

Comment #20

Page Number: 9
Paragraph / Figure / Table / Note: 3.2 Definitions
Comment Type: Technical

Comment:

Please revise the definition as shown below.  This revision will make the definition more technically complete and more inclusive of other renewable technologies.

Proposed Change:

Renewable Energy System – Means of transforming solar thermal energy producing thermal energy or producing electric power that rely on naturally-occurring, on-site resources that are not depleted as a result of their use. Renewable Energy Systems shall include, but are not limited to, solar energy systems, wind energy systems, biomass energy systems, and geothermal energy systems.

Response:

Accepted as Modified. Improves clarity of Standard. However, the term “on-site” will not be stricken as recommend by the comment.

Comment #21

Page Number: 13
Paragraph / Figure / Table / Note: 3.3 Acronyms
Comment Type: Editorial

Comment:

Please revise this acronym to be consistent with the proposed definition change in Section 3.2.

 

This will make the standard more technically accurate.

Proposed Change:

 

MELs – Miscellaneous Electric Energy Loads.

Response:

Accepted. Based on acceptance as modified of comment #18.

Comment #22

Page Number: 13
Paragraph / Figure / Table / Note: 4.1.1
Comment Type: Technical

Comment:

Normalized loads should not be used to estimate energy use or energy savings, as they lead to distorted and inaccurate values.

 

Strike this section and publish a full standard for a full public review.

Proposed Change:

 

 

 

4.1.1. Calculating End Use Loads. Calculate the individualThe normalized Modified End Use Loads (nMEUL) for space heating, and cooling, and domestic hot water usinguse shall each be determined in accordance with eEquation 4.1-1:

nMEUL = REUL * (nEC_x / EC_r) (Eq 4.1-1)

where:

nMEUL = normalized Modified

Response:

Rejected. The subject matter of the proposed change was previously deliberated by the consensus committee during the first round of public comments where definitive decisions were reached by the consensus committee. The proposed change is also not relative to a substantive change to the provisions implemented as a result of the first round of public comments.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #23

Page Number: 14
Paragraph / Figure / Table / Note: 4.1.2
Comment Type: Technical

Comment:

The equations in 4.1.2 are not correct and should be changed and subject to a full public review of this document.  Information on the problems with these equations were provided during the first full public review.

Proposed Change:

 

 

 

4.1.2. Calculating the HERS Index. Determine theThe HERS Index usingshall be determined in accordance with eEquation 4.1-2:

HERS Index = PEfrac * (TnML / TRL) * 100 (Eq 4.1-2)

where:

TnML = nMEULHEAT + nMEULCOOL + nMEULHW + EULLA (MBtu/yry).

TRL = REULHEAT + REULCOOL + REULHW + REULLA (MBtu/yry).

Response:

Rejected. The subject matter of the proposed change was previously deliberated by the consensus committee during the first round of public comments where definitive decisions were reached by the consensus committee. The proposed change is also not relative to a substantive change to the provisions implemented as a result of the first round of public comments.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #24

Page Number: 15
Paragraph / Figure / Table / Note: Section 4.1.2
Comment Type: Technical

Comment:

The current standard is technically incorrect and needs to be corrected.  The 40% value is arbitrary and does not account for the increasing usage of renewable forms of electric generation and the increased use of high-efficiency combined cycle gas turbines (58%+ efficient). 

 

This arbitrary value will lead to fuel switching of end-uses to non-renewable fossil fuels, including imported oil. 

 

It also does not account for upstream energy losses in the fossil fuel supply chain.

Proposed Change:

 

 

TEU = Total energy use of the Rated Home including all rated and non-rated energy features where all fossil fuel site energy uses are converted to Equivalent Electric Energy by multiplying them by the Reference Electricity Production Efficiency of multiplied by 40% then multiplied by 2.5 

Response:

Rejected. The subject matter of the proposed change was previously deliberated by the consensus committee during the first round of public comments where definitive decisions were reached by the consensus committee. The proposed change is also not relative to a substantive change to the provisions implemented as a result of the first round of public comments.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #25

Page Number: 22
Paragraph / Figure / Table / Note: 4.2.2 (1a)
Comment Type: Technical

Comment:

This 0.92 factor, while possibly consistent with certain field studies, seems arbitrary, as there is not a factor used for storage water heaters.

All residential water heaters with federal efficiency standards have the same test procedure, and if there are flaws with the test procedure in predicting efficiency, this standard is not the place to fix this issue.

 

Proposed Change:

Delete the following sentence.

 

For tankless water heaters, the Energy Factor (EF) shall be multiplied by 0.92 for Rated Home calculations.

 

 

Response:

Rejected. The subject matter of the proposed change was previously deliberated by the consensus committee during the first round of public comments where definitive decisions were reached by the consensus committee. The proposed change is also not relative to a substantive change to the provisions implemented as a result of the first round of public comments.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #26

Page Number: 30
Paragraph / Figure / Table / Note: 4.2.2.5.2
Comment Type: Technical

Comment:

The coefficient value of 455 should be lowered in this equation for the following reasons:

 

-DOE rulemakings and EISA 2007 requirements on general service incandescent lamps, incandescent reflector lamps, general fluorescent lamps, and fluorescent lamp ballasts.  All of the increased standards went into effect in 2012, or will go into effect in 2013 and/or 2014, depending on the product.

 

-IECC revisions in 2009 and 2012 that require that at least 50% of fixtures have high efficiency lighting (at least 40 lumens/Watt).

 

Combined, this will significantly reduce residential lighting usage.  I reduced the value by 30% to reflect a conservative result of the appliance efficiency standards, federal law, and code updates.

Proposed Change:

Revise the equation as follows:

 

 

4.2.2.5.2.2. Interior Lighting. Interior lighting annual energy use in the Rated home is calculated usingshall be determined in accordance with eEquation 4.2-2:

kWh/yry = 0.8*[(4 - 3*qFFIL)/3.7]*(445 318 + 0.8*CFA) + 0.2*(455 318 + 0.8*CFA) (Eq 4.2-2)

where:

CFA = Conditioned fFloor aArea

qFFIL = the ratio of the interior Qualifying interior Light Fixtures to all interior light fixtures in Qualifying interior Light Fixture Locations.

Response:

Rejected. The proposed Standard is purposefully based on standards for energy use energy consumption that were in place in 2006.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #27

Page Number: 31
Paragraph / Figure / Table / Note: 4.2.2.5.2
Comment Type: Technical

Comment:

The coefficient values of 100 and 25 should be lowered in this equation for the following reasons:

 -DOE rulemakings and EISA 2007 requirements on general service incandescent lamps, incandescent reflector lamps, general fluorescent lamps, and fluorescent lamp ballasts.  All of the increased standards went into effect in 2012, or will go into effect in 2013 and/or 2014, depending on the product.

 -IECC revisions in 2009 and 2012 that require that at least 50% of fixtures have high efficiency lighting (at least 40 lumens/Watt).

 Combined, this will significantly reduce residential lighting usage.  I reduced the value by 30% to reflect a conservative result of the appliance efficiency standards, federal law, and code updates.

Proposed Change:

 

4.2.2.5.2.3. Exterior Lighting. Exterior lighting annual energy use in the Rated home shall be determined usingin accordance with eEquation 4.2-3:

kWh/yry = (100 70 + 0.05*CFA)*(1-FFEL) + 0.25*(100 70 + 0 .05*CFA)*FFEL

 

 

 

4.2.2.5.2.4. Garage Lighting. For Rated homes with garages, garage annual lighting energy use in the Rated home shall be determined usingin accordance with eEquation 4.2-4:

kWh = 100 70*(1-FFGL) + 25 17*FFGL

 

 

Response:

Rejected. The proposed Standard is purposefully based on standards for end use energy consumption that were in place in 2006.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #28

Page Number: 49-50
Paragraph / Figure / Table / Note: 4.5.4
Comment Type: Technical

Comment:

The equation is flawed as it discounts the use of gas or other fossil fuels by 60%.  Ironically, it also hurts energy efficiency, as the impact of fossil fuel savings are also reduced by 60% using this formula.

 

For example, if a product uses 100 MMBtu and the high efficiency product uses 50 MMBtu, the savings are 50 MMBtu (1000 therms - 500 therms = 500 therms).

With the distorted formula, the "savings" would be estimated to be 20 MMBtu (200 therms), as it would be:

(100 * 0.40) - (50 * 0.40) = 40 - 20 = 20

 

So it has the impact of leading some to fuel switch from electricity to fossil fuels, and then reduces the impact from gas or other fossil fuel efficiency measures.

 

 

Proposed Change:

 

 

 

4.5.4.1. Energy units used in the calculation of energy savings shall be units of Equivalent Electric Energy using the Reference Electricity Production Efficiency for fossil fuels. Equivalent electric energy use shall be calculated using Equation 4.5-1.

 

kWheq= kWhelec+ (Btufossil*0.40 * 2.5/ 3412)

 

Response:

Rejected. The subject matter of the proposed change was previously deliberated by the consensus committee during the first round of public comments where definitive decisions were reached by the consensus committee. The proposed change is also not relative to a substantive change to the provisions implemented as a result of the first round of public comments.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #29

Page Number: 54
Paragraph / Figure / Table / Note: 5.1.1.4
Comment Type: Technical

Comment:

The note needs to be modified and expanded to be more technically accurate and to show more realistic examples.

Proposed Change:

 

 

20 (informative Note) For example, assume 1000 kWh (3413 kBtu or 3.413 MBtu) of gross electrical power is produced using 60 therms (6 MBtu) of natural gas to operate a high-efficiency fuel cell system. Using these assumptions, OPP = 3.413 MBtu - (6 MBtu * 0.4) = 1.0 MBtu.  As another example, if 1000 kWh was produced by a low efficiency fossil fuel system with no emission controls using 17 Mbtu of fuel, the OPP would be OPP = 3.413 - (17 * 0.4) =    -3.387 MBtu

Response:

Accepted as Modified. Leave “high-efficiency” as descriptor of fuel cell system and strike “with no emission controls” from low-efficiency fossil fuel system description.

Comment #30

Page Number: 56
Paragraph / Figure / Table / Note: 5.1.2.2
Comment Type: Technical

Comment:

There are many technical problems with the ISC edits.  As edited, it would allow users to use any version of eGRID, from 2006 to 2007 to 2010 to 2012.  Values have changed significantly in each version, and it would actually be better to use future projections of emissions, rather than outdated and overstated values.  Also, it ignores the impacts of emissions caps at the national (SO2 and NOx) and regional/state levels (RGGI and CARB).

 

Also, by only using "upstream" estimates for electricity and "downstream" estimates for fossil fuels, there is critical information that is not being shown or accounted for.  It is a flawed and biased approach that needs to be changed.  Either use downstream estimates for all forms of energy, or use upstream + downstream estimates for all forms of energy.

Proposed Change:

 

 

5.1.2.2. Pollution Emission Savings. If Where determined, the pollution emission savings for the Rated Home are calculated, they shall be calculated using the following Proceduresin accordance with Sections 5.1.2.2.1 and 5.1.2.2.2.

5.1.2.2.1. Pollution Emissions. Pollution emissions for all homes shall be calculated using the following proceduresin accordance with Sections 5.1.2.2.1.1 and 5.1.2.2.1.2.

5.1.2.2.1.1. For electricity use, pollution emission shall be calculated using the statewide averagedata for the sub-region annual total output emission rates provided published by the Environmental Protection Agency’s most recent eGrid database22 for electricity generation. shall be used to calculate estimate upstream emissions, since the equipment does not produce emissions at the home..23

5.1.2.2.1.2. For fossil fuel use, pollution emissions at the home, but not upstream, shall be calculated using the emission factors given in Table 5.1.2(1) below.

 

 

Response:

Accepted as Modified. The date of the most recent eGrid database will be added as 2012 but the remainder of the proposed changes will not be made as they are informative only and do not add substance or clarity to this provision of the standard.

Comment #31

Page Number: 2
Paragraph / Figure / Table / Note: 3.2. Definitions
Comment Type: Technical

Comment:

The following definition should be modified: because embedded in it is the Building Performance Institute's (BPI) requirement for ill-defined CAZ testing through the reference to Mortgage Industry National Home Energy Rating Systems Standards..

Approved Tester – An individual who, by virtue of training and examination, has demonstrated competence in the performance of on-site testing in accordance with Section 800 of the Mortgage Industry National Home Energy Rating Systems Standards and who has been approved by an Approved Rating Provider to conduct such tests.

Section 800 of the Mortgage Industry National Home Energy Rating Systems Standards reads as follows:

805 Work Scope and Combustion Safety Procedures

805.1 These protocols shall be followed by RESNET-accredited Raters and Auditors (hereinafter referred to collectively as “Auditors”) performing combustion appliance testing or writing work scopes for repairs.

805.2 If the Auditor has been trained and certified in accordance with a RESNET approved “equivalent home performance certification program” or the Building Performance Institute Chapter Eight RESNET Standards 8-20  (BPI) Standards, the Auditor may follow protocols in accordance with those equivalent standards.

CAZ testing is ill-defined because it is open to interpretation which may be unreasonable.  Additionally, in order for RESNET to receive ANSI approval, any external standard incorporated by reference (such as BPI) into a RESNET standard should be ANSI approved.

Furthermore, it appears that RESNET is supposed to be cooperatively developing ACCA Standard 12 (http://www.acca.org/Files/?id=824).

ACCA Standard 12 is adopting National Fuel Gas Code's Annex G; Consequently, it appears that the whole process is (at the least) systematically inconsistent.

 Moreover, because RESNET’s Preliminary Draft Standard BSR/RESNET 301-2013 references the Mortgage Industry National Home Energy Rating Systems Standards so many times, and the latter document is not open for revisions, it would appear that a systematic solution must be developed.

Proposed Change:

 

Annex G
Recommended Procedure for Safety
Inspection of an Existing Appliance
Installation

This annex is not a part of the requirements of this code but is included for informational purposes only.

G.1 General. The following procedure is intended as a guide to aid in determining that an appliance is properly installed and is in a safe condition for continued use. Where a gas supplier performs an inspection their written procedures should be followed.

G.1.1 Application. This procedure is intended for existing residential installations of a furnace, boiler, room heater, water heater, cooking appliance, fireplace appliance and clothes dryer. This procedure should be performed prior to any attempt to modify the appliance, the installation, and building envelope.

G.1.2 Weatherization Programs.  Before a building envelope is to be modified as part of a weatherization program, the existing appliance installation should be inspected in accordance with these procedures. After all unsafe conditions are repaired, and immediately after the weatherization is complete, the appliance inspections in G.5.2 are to be repeated.

G.1.3 Inspection Procedure. The safety of the building occupant and inspector are to be determine as the first step as described in G.2.  Only after the ambient environment is found to be safe should inspections of gas piping and appliances be undertaken. It is recommend that all inspections described in G.3, G.4, and G.6, where the appliance is in the off mode, be completed and any unsafe conditions repaired or corrected before proceeding with inspections of an operating appliance described in G.5 and G.6. 

G.1.4 Manufacturer Instructions. Where available, the manufacturer’s installation and operating instructions for the installed appliances should be use as part of these inspection procedures to determine if it is installed correctly and is operating properly.

G.1.5 Detectors Instruments. The inspection procedures include measuring for fuel gas and carbon monoxide (CO) and will require the use of combustible gas detector (CGD) and CO detector. It is recommended that both types of detectors be listed.  Prior to any inspection the detectors should be calibrated or tested in accordance with the manufacturer’s instructions.  In addition, it is recommended that the detectors have the following minimum specifications.

a. Gas Detector: The CGD should be capable of indicating the presence of the type of fuel gas for which it is to be used (e.g. natural gas or propane).  The combustible gas detector should be capable of the following:

     PPM: Numeric display with a parts per million (ppm) scale from 1 percent to 900 ppm in 1 ppm increments.           LEL: Numeric display with a percent lower explosible limit (% LEL) scale from 0 percent to 100 percent in 1 percent increments.  

     Audio: An audio sound feature to locate leaks. 

b. CO Detector: The CO detector should be capable of the following functions and have a numeric display scale as follows:

     PPM:  For measuring ambient room and appliance emissions a display scale in parts per million (ppm) from 0 to 1,000 ppm in 1 ppm increments.

     Alarm:  A sound alarm function where hazardous levels of ambient CO is found (see G.2 for alarm levels)

     Air Free: Capable of converting CO measurements to an air free level in ppm.

G.2 Occupant and Inspector Safety. The inspector prior to entering a building should have both a combustible gas detector (CGD) and CO detector turned on, calibrated, and operating.  Immediately upon entering the building, a sample of the ambient atmosphere should be taken.   Based on CGD and CO detector readings the inspector should take the following actions:

(1)   The CO detector indicates a carbon monoxide level of 70 ppm or greater[1]. The inspector should immediately notify the occupant of the need for themselves and any building occupant to evacuate; the inspector shall immediately evacuate and call 911.

(2)   Where the CO detector indicates a reading between 30 ppm and 70 ppm¹. The inspector should advise the occupant that high CO levels have been found and recommend that all possible sources of CO should be turned off immediately and windows and doors opened.  Where it appears that the source of CO is a permanently installed appliance, advise the occupant to keep the appliance off and have the appliance serviced by a qualified servicing agent.

(3)   Where CO detector indicates CO below 30 ppm¹ the inspection can proceed.

(4)   The CGD indicates a combustible gas level of 20% % LEL or greater. The inspector should immediately notify the occupant of the need for themselves and any building occupant to evacuate; the inspector shall immediately evacuate and call 911.

(5)   The CGD indicates a combustible gas level below 20% LEL the inspection can proceed.

If during the inspection process it is determined a condition exists that could result in unsafe appliance operation, shut off the appliance and advise the owner of the unsafe condition. Where a gas leak is found that may result in an unsafe condition, advise the owner of the unsafe condition and call the gas supplier to turn off the gas supply.  The inspector should not continue a safety inspection on an operating appliance, venting system, and piping system until repairs have been made.

G.3 Gas Piping and Connection Inspections

(1)   Leak Checks. Conduct a test for gas leakage using either a non-corrosive leak detection solution or a CGD confirmed with a leak detection solution. 

                The preferred method for leak checking is by use of gas leak detection solution applied to all joints.  This method provides a reliable visual indication of significant leaks.

                The use of a CGD in its audio sensing mode can quickly locate suspect leaks but may be overly sensitive indicating insignificant and false leaks. All suspect leaks found through the use of a CGD should be confirmed using a leak detection solution.

                Where gas leakage is confirmed, the owner should be notified that repairs must be made. The inspection should include the following components:

a.  All gas piping fittings located within the appliance space.

b. Appliance connector fittings.

c.  Appliance gas valve/regulator housing and connections.

(2) Appliance Connector. Verify that the appliance connection type is compliant with Section 9.6 of the National Fuel Gas Code. Inspect flexible appliance connections to determine if they are free of cracks, corrosion and signs of damage. Verify that there are no uncoated brass connectors.  Where connectors are determined to be unsafe or where an uncoated brass connector is found, the appliance shutoff valve should be placed in the off position and the owner notified that the connector must be replaced.

(3)   Piping Suport. Inspect piping to determine that it is adequately supported, that there is no undue stress on the piping, and if there are any improperly capped pipe openings. 

(4)   Bonding. Verify that the electrical bonding of gas piping is compliant with Section 7.13 of the National Fuel Gas Code.

G.4 Inspections to be preformed with the Appliance Not Operating. The following safety inspection procedures are performed on appliances that are not operating.  These inspections are applicable to all appliance installations.  

(1)   Preparing for Inspection. Shut off all gas and electrical power to the appliances located in the same room being inspected.  For gas supply use the shutoff valve in the supply line or at the manifold serving each appliance. For electrical power place the circuit breaker in the off position or remove the fuse that serves each appliance. A lock type device or tag should be installed on each gas shutoff valve and at the electrical panel to indicate that the service has been shut off for inspection purposes.  

(2)   Vent System Size and Installation. Verify that the existing venting system size and installation is compliant with Chapters 11-12 of the National Fuel Gas Code. The size and installation of venting systems for other than natural draft and category I appliances should be in compliance with the manufacturer’s installation instructions. Inspect the venting system to determine that is free of blockage, restriction, leakage, corrosion, and other deficiencies that could cause an unsafe condition. Inspect masonry chimneys to determine if they lined.  Inspect plastic venting systems to determine that it free of sagging and it is sloped in a upward direction to the outdoor vent termination.  

(3)   Combustion Air Supply. Inspect provisions for combustion air as follows:

        a.     Non-Direct Vent Appliances.  Determine that non-direct vent appliance installations are compliant with the combustion air requirements in Section 9.3 of the National Fuel Gas Code. Inspect any interior and exterior combustion air openings and any connected combustion air ducts to determine that there is no blockage, restriction, corrosion or damage. Inspect to determine if horizontal combustion air ducts are sloped in an upward direction towards the air supply source.

        b.     Direct Vent Appliances.  Verify that the combustion air supply ducts and pipes are securely fastened to direct vent appliance and determine that there is no separations, blockage, restriction, corrosion or other damage.  Determine that the combustion air source is located in the outdoors or to areas that freely communicate to the outdoors.

        c.     Unvented Appliances. Verify that the total input of all unvented room heaters and gas-fired refrigerators installed in the same room or rooms that freely communicate with each other does not exceed 20 Btu/hr/ft3.

(4)   Flooded Appliances. Inspect the appliance for signs that the appliance may have been damaged by flooding.  Signs of flooding include a visible water submerge line on the appliance housing, excessive surface or component rust, deposited debris on internal components, and mildew-like odor. Inform the owner that all flood-damaged plumbing, heating, cooling and electrical appliances and related systems should be replaced.

(5)   Flammable Vapors. Inspect the room/space where the appliance is installed to determine if the area is free of the storage of gasoline or any flammable products such as oil-based solvents, varnishes or adhesives. Where the appliance is installed where flammable products will be stored or used, such as a garage, verify that the appliances burner is a minimum of 18” above the floor unless the appliance is listed as flammable vapor ignition resistant.

(6)   Clearances to Combustibles. Inspect the immediate location where the appliance is installed to determine if the area is free of rags, paper or other combustibles. Verify that the appliance and venting system is compliant with clearances to combustible building components in Section 9.2.2 of the National Fuel Gas Code.

(7)   Appliance Components. Inspect internal components by removing access panels or other components for the following:

a.  Inspect burners and crossovers for blockage and corrosion. The presence of soot, debris, and signs of excessive heating may indicate incomplete combustion due to blockage or improper burner adjustments.

c.  Metallic and non-metallic hoses for signs of cracks, splitting, corrosion, and lose connections.

d.  Signs of improper or incomplete repairs

e. Modifications that override controls and safety systems

f.   Electrical wiring for loose connections; cracks, missing or worn electrical insulation; and indications of excessive heat or electrical shorting.   Appliances requiring an external electrical supply should be inspected for proper electrical connection in accordance with the National Electric Code.

(8)   Placing Appliances Back in Operation. Return all inspected appliances and systems to their preexisting state by reinstalling any removed access panels and components.  Turn on the gas supply and electricity to each appliance found in safe condition. Proceed to the operating inspections in G.5 through G.6.

G.5 Inspections to be performed with the Appliance Operating. The following safety inspection procedures are to be performed on appliances that are operating where there are no unsafe conditions or corrective repairs have been completed. 

G.5.1 General Appliance Operation.

(1)   Initial Startup. Adjust the thermostat or other control device to start the appliance.  Verify that the appliance starts up normally and is operating properly.      Determine that the pilot(s), where provided, is burning properly and that the main burner ignition is satisfactory, by interrupting and re-establishing the electrical supply to the appliance in any convenient manner. If the appliance is equipped with a continuous pilot(s), test all pilot safety device(s) to determine whether it is operating properly by extinguishing the pilot(s) when the main burner(s) is off and determining, after 3 minutes, that the main burner gas does not flow upon a call for heat. If the appliance is not provided with a pilot(s), test for proper operation of the ignition system in accordance with the appliance manufacturer's lighting and operating instructions.

(2)   Flame Appearance. Visually inspect the flame appearance for proper color and appearance.  Visually determine that the main burner gas is burning properly (i.e., no floating, lifting, or flashback). Adjust the primary air shutter as required. If the appliance is equipped with high and low flame controlling or flame modulation, check for proper main burner operation at low flame.

(3)   Appliance Shutdown. Adjust the thermostat or other control device to shutdown the appliance. Verify that the appliance shuts off properly.  

G.5.2 Test for Combustion Air and Vent Drafting for Natural Draft and Category I Appliances. Combustion air and vent draft procedures are for natural draft and category I appliances equipped with a draft hood and connected to a natural draft venting system.

(1)   Preparing for Inspection. Close all building doors and windows and all doors between the space in which the appliance is located and other spaces of the building that can be closed. Turn on any clothes dryer. Turn on any exhaust fans, such as range hoods and bathroom exhausts, so they will operate at maximum speed. Do not operate a summer exhaust fan. Close fireplace dampers and any fireplace doors.

(2)   Placing the Appliance in Operation. Place the appliance being inspected in operation. Adjust the thermostat or control so the appliance will operate continuously.

(3)   Spillage Test. Verify that all appliances located within the same room are in their standby mode and ready for operation.  Follow lighting instructions for each appliance as necessary.  Test for spillage at the draft hood relief opening as follows:

a. After 5 minutes of main burner operation check for spillage using smoke.

b.  Immediately after the first check turn on all other fuel gas burning appliances within the same room so they will operate at their full inputs and repeat the spillage test.  

c.  Shut down all appliances to their standby mode and wait for 15 minutes.

d.  Repeat the spillage test steps a through c on each appliance being inspected.

(4)   Return doors, windows, exhaust fans, fireplace dampers, and any other fuel gas burning appliance to their previous conditions of use.

(5)   If, after completing the spillage test it is believed sufficient combustion air is not available, the owner should be notified that an alternative combustion air source is needed in accordance with Section 9.3 of the National Fuel Gas Code. Where it is believed that the venting system does not provide adequate natural draft, the owner should be notified that alternative vent sizing, design or configuration is needed in accordance with Chapter 11 and 12 of the National Fuel Gas Code. 

G.6 Appliance-Specific Inspections. The following appliance-specific inspections are to be performed as part of a complete inspection. These inspections are performed either with the appliance in the off or standby mode (indicated by “OFF”) or on an appliance that is operating (indicated by “ON”).  The CO measurements are to be undertaken only after the appliance is determined to be properly venting.   The CO detector should be capable of calculating CO emissions in ppm air free.

(1)   Forced Air Furnaces:

a.     OFF. Verify that an air filter is installed and that it is not excessively blocked with dust. 

b.     OFF. Inspect visible portions of the furnace combustion chamber for cracks, ruptures, holes, and corrosion. A heat exchanger leakage test should be conducted.

        c.     ON. Verify both the limit control and the fan control for proper operation. Limit control operation can be checked by blocking the circulating air inlet or temporarily disconnecting the electrical supply to the blower motor and determining that the limit control acts to shut off the main burner gas.

        d.     ON. Verify that the blower compartment door is properly installed and can be properly resecured if opened. Verify that the blower compartment door safety switch operates properly.

        e.     ON.  Check for flame disturbance before and after blower comes on which may indicate heat exchanger leaks.  

f.     ON.  Measure CO in the vent after 5 minutes of main burner operation. The CO should not exceed threshold in Table G.6.

(2)   Boilers:

a.     OFF and ON. Inspect for evidence of water leaks around boiler and connected piping.

b.     ON. Verify that the water pumps are in operating condition. Test low water cutoffs, automatic feed controls, pressure and temperature limit controls, and relief valves in accordance with the manufacturer's recommendations to determine that they are in operating condition.

c.     ON.  Measure CO in the vent after 5 minutes of main burner operation. The CO should not exceed threshold in Table G.6.  

(3)   Water Heaters:

a. OFF. Verify that the pressure temperature relief valve is in operating condition. Water in the heater should be at operating temperature.

b.  OFF. Verify that inspection covers, glass, and gaskets are intact and in place on a flammable vapor ignition resistant (FVIR) type water heater.

c.  ON. Verify that the thermostat is set in accordance with the manufacuturer’s operating instrucitons and measure the water temperature at the closest tub or sink that it is no greater than 120ºF.

d.  OFF. Where required by the local building code in earthquake prone locations, inspect that the water heater is secured to the wall studs in two locations (high and low) using appropriate metal strapping and bolts.

e.  ON. Measure CO in the vent after 5 minutes of main burner operation. The CO should not exceed threshold in Table G.6.  

(4) Cooking Appliances

a.  OFF.  Inspect oven cavity and range-top exhaust vent for blockage with aluminum foil or other materials.

b.  OFF. Inspect cook top is free from a build-up of grease.

c.  ON. Measure CO in above each burner and at the oven exhaust vents after 5 minutes of main burner operation. The CO should not exceed threshold in Table G.6.

(5) Vented Room Heaters

a.  OFF. For built-in wall heaters and furnaces inspect that the burner compartment is free of lint and debris.

b.  OFF. Inspect that furnishings and combustible building components are not blocking the heater.

a.  ON. Measure CO in the vent after 5 minutes of main burner operation. The CO should not exceed threshold in Table G.6.

(6)   Vent-Free Heaters

a.  OFF. Verify that the heater input is a maximum of 40,000 Btu input, but not more than 10,000 Btu where installed in a bedroom, and 6,000 Btu where installed in a bathroom.    

b.  OFF. Inspect the ceramic logs provided with gas log type vent free heaters that they are properly located and aligned.

c.  OFF. Inspect the heater that it is free of excess lint build-up and debris.

c. OFF. Verify that the oxygen depletion system has not been altered or bypassed.   

d.  ON. Verify that the main burner shutdowns within 3 minutes by extinguishing the pilot light. The test is meant to simulate the operation of the oxygen depletion system (ODS).

e.  ON. Measure CO after 5 minutes of main burner operation. The CO should not exceed threshold in Table G.6.

(7)   Gas Log Sets and Gas Fireplaces

a. OFF. For gas logs installed in wood burning fireplaces equipped with a damper verify that the fireplace damper is in a fixed open position.

b.  ON. Measure CO in the firebox (logs sets installed in wood burning fireplaces or in the vent (gas fireplace) after 5 minutes of main burner operation. The CO should not exceed threshold in Table G.6. 

(8)   Gas Clothes Dryer

a.  OFF. Where installed in a closet, verify that a source of make-up air is provided and inspect that any make-up air openings, louvers, and ducts are free of blockage.

b. OFF. Inspect for excess amounts of lint around the dryer and on dryer components.  Inspect that there is a lint trap properly installed and it does not have holes or tears.  Vertiy that it is clean condidtion.

c.  OFF. Inspect visible portions of the moisture exhaust duct and connections for loose fittings and connections, blockage, and signs of corrision. Vertify that the duct termination is not blocked and that it terminates in an outdoor location.  Verify that only approved metal vent ducting material is installed (plastic and vinyl materials are not approved for gas dryers).

d. ON. Verify mechanical components including drum and blower for proper operation.

e.  ON. Operate the clothes dryer and vertify that exhuast system is intact and exhaust is exiting the termination.

f.    ON. Measure CO in at the exhaust duct or termination after 5 minutes of main burner operation. The CO should not exceed threshold in Table G.6.

 

 

TABLE G.6
CO THRESHOLDS
Appliance	Threshold Limit
Central Furnace (all categories)	400 ppm1 air free2
Floor Furnace	400 ppm air free
Gravity Furnace	400 ppm air free
Wall Furnace (BIV)	200 ppm air free
Wall Furnace (Direct Vent)	400 ppm air free
Vented Room Heater	200 ppm air free
Vent-Free Room Heater	200 ppm air free
Water Heater	200 ppm air free
Oven / Boiler	225 ppm as measured
Top Burner	25 ppm as measured (per burner)
Refrigerator	25 ppm as measured
Gas Log (gas fireplace)	25 ppm as measured in vent
Gas Log (installed in wood burning fireplace)	400 ppm air free in firebox
1  Parts per million
2  Air free emission levels are based on a mathematical equation (involving carbon monoxide and oxygen or carbon dioxide readings) to convert an actual diluted flue gas carbon monoxide testing sample to an undiluted air free flue gas carbon monoxide level utilized in the appliance certification standards. For natural gas or propane, using as-measured CO ppm and O2 percentage:    Where: COAFppm = Carbon monoxide, air-free ppm COppm = As-measured combustion gas carbon monoxide ppm O2 = Percentage of oxygen in combustion gas, as a percentage

 

Response:

Accepted as Modified. Section 800 of the Mortgage Industry National Home Energy Rating Systems Standard is too broad for this provision. The section number will be changed to refer to Sections 802 and 803 of the Mortgage Industry National Home Energy Rating Standard such that Section 805, which is objectionable to the commenter, will be excluded from this provision.

Comment #32

Page Number: 1
Paragraph / Figure / Table / Note: paragraph 2 of Foreword
Comment Type: Editorial

Comment:

The second half of the second paragraph (As a result, ... less than 100) seems to me to be informative rather than normative.  Also, it may be misleading because to sowe readers it would imply that a home that gets 100 would "comport" (comply) with the 2006 IECC, which is not necessarily correct. Because the HERS index accounts for lighting and appliances, and adjusts for homes that have no cooling, there is not a 1-to-1 correspondence between code compliance (even 2006 IECC) and a HERS index of 100.

Proposed Change:

Either footnote these two sentences as an "informative note", or delete it.  If it is kept as an informative note, it would help to add the following clarification: Because the HERS index accounts for lighting and appliances, and adjusts for homes that have no cooling, there is never a 1-to-1 correspondence between code compliance (even the 2006 IECC) and a HERS index of 100.

Response:

Accepted. The Forward section of the standard will be modified to explicitly state that it is informative rather than normative and the proposed additional language will be added.

Comment #33

Page Number: 1
Paragraph / Figure / Table / Note: 2. Scope
Comment Type: Editorial

Comment:

For clarity, add "to" per proposed change.

Proposed Change:

...to all one- and two-family dwellings and to dwelling units in residenital buildings ...

Response:

Accepted. Improved the clarity of the Standard.

Comment #34

Page Number: 2
Paragraph / Figure / Table / Note: 3.1
Comment Type: Editorial

Comment:

"Plural" is spelled incorrectly

Proposed Change:

pleural plural

Response:

Accepted. The spelling error will be corrected.

Comment #35

Page Number: 2
Paragraph / Figure / Table / Note: definition - Approved Software Rating Tool
Comment Type: General

Comment:

I believe this should refer to the current RESNET software test specification, or to the specific list of approved Rating software, or both, rather than a vague reference to "approved".  

Proposed Change:

Approved Software Rating Tool – A computerized procedure that meets the requirements of RESNET Publication No. 13-002, March 15, 2013 and is approved for the purpose of conducting home energy ratings and calculating the annual energy consumption, annual energy costs and a HERS Index for a home.  A list of approved software rating tools may be found at http://www.resnet.us/professional/programs/energy_rating_software .

 

Response:

Rejected. The proposed language calls for inclusion of a proprietary reference and web site. This is not allowed in American National Standards except under the exceptional circumstances as outlined in ANSI Essential Requirements: Due process requirements for American National Standards. However, an informative footnote containing the proposed changes will be added to this provision as follows:

^{1(Informative Note) A list of RESNET approved software rating tools meeting the requirements of RESNET Publication No. 13-002 is online at http://www.resnet.us/professional/energy_rating_software.}

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #36

Page Number: 4
Paragraph / Figure / Table / Note: definition - Conditioned Floor Area
Comment Type: Technical

Comment:

The proposed definitions of Conditioned Floor Area and Conditioned Space are generally an improvement over the historical definitions, but they omit a few critical elements.  I will log separate comments for each definition for ease of consideration, but please understand these comments in the context of the group.    Beginning with CFA:

The proposed definition omits any guidance on spaces that may have explicit HVAC supply, but are clearly not intended for human habitation. Typical examples include unfinished insulated basements, crawlspaces, and attics.  Inclusion of these spaces in the CFA has a significant, and unrealistic, impact on assumed lighting, appliance, and MEL loads and ventilation requirements for both the reference and rated home, and on shell leakage for the reference home, all of which are directly proportional to CFA.  

The standard needs to make it clear that the added floor area of a 3' high insulated crawlspace, or an unvented, insulated ("cathedralized") attic (as well as an insulated but unfinished basement) most certainly does not correlate to uroportionally higher lighting and appliance use (etc) in an otherwise identical house, simply because these spaces are actually conditioned.  The IRC definition of habitable spaces are actually helpful, because there are consistent code requirements for electrical outlets at regular intervals in habitable spaces. So ratioanally, if ceiling height is too low for most adults (5' or less), or there are not electrical outlets every 12 feet along the space's walls, the floor area should not be included since it's not habitable space.  One awkward part of using the "habitable space" code definition is the exclusion of  bathrooms, toilet rooms, closets, halls, storage or utility spaces, and similar areas (those areas don't have the same requirements for electrical service that habitable spaces do); however, that can be handled by calling them out explicitly in the definition of CFA.    Note that although the proposed definition of conditioned floor area does not include the term "finished" as it previously did, the ANSI standard that is referenced does use the term "finished" (though poorly defined"--so simply omitting that term from the CFA definition does not eliminate that ambiguity, in only pushes it into more obscurity.  Adding the definition of habitable space and referring to it within the CFA definition make it more clear, brings it into line with code, provides a clearer way of inspectng (looking for the required electrical service within habitable space), and elimitates the over-counting of Lights, Appliances,MELs, ventialiton and shell leakage for spaces that are clearly not living spaces.

Note that the reference to the exceptions to ANSI Z765 in Appendix A are outdated, and confusing in that they are only referenced in the section on measuring foundations; and, in fact the explicict inclusion of spaces less than 5' (the exception in Appendix A) conflicts with the need to exclude floor area of spaces that people will never occupy with appliances and lighting, or live in, such as attics and crawspaces.  

Note also that the intent is not  to exclude such non-habitable spaces from the conditioned space boundary or the calculations of energy use related to space conditioning-- but only to exclude them from the definition of CFA which is used extensively in the standard to determine default chararteristics of the reference and rated home as mentioned above.

Proposed Change:

 

Response:

Rejected. The provisions of the proposed change are effectively covered by the current definition of Conditioned Floor Area because ANSI Z765 directs users to only include finished floor areas, which are defined as "an enclosed area in a house that is suitable for year-round use, embodying walls, floors, and ceilings that are similar to the rest of the house". Therefore a conditioned crawlspace would not likely meet this requirement. Similarly, a conditioned attic or a conditioned basement would not meet this requirement unless the builder specifically finished the space so as to be used throughout the year, in which case it should and would be included in the CFA.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #37

Page Number: 4
Paragraph / Figure / Table / Note: Definition - Conditioned space
Comment Type: Technical

Comment:

The proposed definiton is an improvement over the previous RESNET standard, but leaves out some imortant factors.  First, ASHRAE 55 is a highly detailed standard that is intended for design engineers, and is almost certainly unnecessary in order that rater  understand what is and is not conditioned space.  Further, the vast majority of homes have no equipment that is "designed" in accordance with ASHRAE 55--few residential HVAC designers pay any attention to ASHRAE 55.  If they do a design at all they just choose an indoor design temperature.   Moreover, many homes (both older, and new low-energy, or in regions with low heating loads) have 1 or more point-source heating systems that condition many rooms/ spaces indirectly.  The proposed definition really does not address that situation, and the earlier RESNET standard did.

What follows are two alternate suggestions--one that includes the reference to ASHRAE 55 and one that excludes it.  They are alternates, it is not indended for them both to be adopted.  Both address the concept of direct or indirect space conditioning, and both include more "rater-friendly" wording to address the concept, avoiding the reference to a "design" that complies with ASHRAE 55.

Proposed Change:

Conditioned Space – An area or room All areas or rooms within a building that are directly or indirectly serviced by a space heating or cooling system(s) designed tothat maintain year-round human comfort in accordance with ASHRAE Standard 55-2010.

[or]

Conditioned Space – An area or room All areas or rooms within a building that are directly or indirectly serviced by a space heating or cooling system(s) designed tothat maintain year-round human comfort in accordance with ASHRAE Standard 55-2010.

Response:

Accept as Modified: Direct and indirect conditioning of spaces is not material to simulation modeling, which this set of definitions (Conditioned Space, Conditioned Space Boundary, and Unconditioned Space) are designed to specify. The inclusion of ASHRAE Standard 55-2010 was not intended to specify how mechanical systems must be designed and to avoid such confusion the definition of Conditioned Space will be modified as follows and an informative footnote will be added to provide further clarification:

Conditioned Space ¹ – An area or room within a building serviced by a space heating or cooling system designed to maintain human comfort space conditions in accordance with ASHRAE Standard 55-2010Section 4.2 of this Standard.

¹   (Informative Note) Conditioned Space represents the simulation control volume that is mechanically controlled to specified conditions (e.g. 68 F for heating and 78 F for cooling) and on which an energy balance is performed by the simulation software.

Comment #38

Page Number: 4
Paragraph / Figure / Table / Note: Definition - Conditioned space boundary
Comment Type: Technical

Comment:

In many cases, the conditioned space boundary does NOT coincide with the primary "air containment plane(s)" of a house. The proposed definition also omits the outdoors (along with the attempt to include outdoors in the proposed definition of "unconditioned space", which is confusing and unnecessary).   The old definition of "conditioned space boundary" was one of the best definitions of its kind anywhere, and could easily be adapted to the current proposal by eliminating the separate definitions of directly and indirectly conditioned spaces.  A final sentence is proposed that adds clear guidance for raters in cases where the air boundary and thermal (insulation) boundary don't coincide.

Proposed Change:

Conditioned Space Boundary – The principal air containment planes of a building that separate the Conditioned Space within the building from Unconditioned Space.  The continuous planes of the building enclosure that comprise the primary thermal and air flow barrier between conditioned space and the outdoors, or between conditioned space and adjacent unconditioned space(s).  Where the primary thermal and air flow barrier do not coincide at the same surface, the Conditioned Space Boundary shall be considered to include those surface(s) that are closest to the boundary between habitable space and non-habitable space.

Response:

Accept as Modified: This definition is designed to specify the control volume that is to be modeled in energy simulations. Energy simulations require a control volume on which to perform an energy balance. This control volume is best defined by the air containment boundaries of the control volume rather than the thermal boundaries of the control volume. However, as proposed by the commenter, the definition will be modified to include the outdoor environment as follows:

Conditioned Space Boundary – The principal air containment planes of a building that separate the Conditioned Space within the building from the outdoor environment or from Unconditioned Space.

Comment #39

Page Number: 5 and 20
Paragraph / Figure / Table / Note: Definition - Glazing and Table 4.2.2(1) footnote (a)
Comment Type: Editorial

Comment:

The definition is really a definition of glazing area, not of glazing itself. 

Also, with this definition in place there is no need for Table 4.2.2(1) footnote (a)--they are identical and need not appear twice.

Proposed Change:

[p5]

Glazing Area – The area of Ssunlight-transmitting fenestration, inccluding ...

[p20]

[renumber accordingly]

Response:

Rejected. The proposed change does not improve the clarity of the Standard.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #40

Page Number: 7 and 12
Paragraph / Figure / Table / Note: Definition - kWh
Comment Type: Editorial

Comment:

kWh should be spelled out, consistent with the other definitions, and the abbreviation added to that section

Proposed Change:

[p7]

Kilowatt-hour (kWh) – One thousand ....

[p12, in alphabectial order]

kWh - Kilowatt-hour

Response:

Accepted. Improves clarity of the Standard.

Comment #41

Page Number: 9
Paragraph / Figure / Table / Note: Definiton - Renewable Energy System
Comment Type: Editorial

Comment:

There is a high likelihood that people will confuse"geothermal energy systems" with  ground source heat pumps, which are often called "geothermal systems".  Ground Source Heat Pumps are electric heat pumps, and are no more renewable energy systems than other types of heat pumps or air conditioners.  True geothermal energy systems are virtually non-existent in residential applications and can safely be deleted from the definition.

Proposed Change:

Renewable Energy System – Means of transforming solar thermal energy or producing electric power that rely on naturally-occurring, on-site resources that are not depleted as a result of their use. Renewable Energy Systems shall include, but are not limited to, solar energy systems, and wind energy systems and geothermal energy systems.

Response:

Accepted. Improves clarity of Standard and avoids misinterpretation.

Comment #42

Page Number: 11
Paragraph / Figure / Table / Note: definition - therms
Comment Type: Editorial

Comment:

"Therms" should be in the singular for the purpose of a definition.  This is not a change that was proposed in this round of comment, but it's also a non-substantive suggestion.

Proposed Change:

Therms

Response:

Accepted. Improves clarity of the Standard.

Comment #43

Page Number: 11
Paragraph / Figure / Table / Note: definition - Unconditioned space
Comment Type: Technical

Comment:

Uconditioned space is not outdoors--and the reason for including this (apparently to simplify the proposed definition of "conditioned space boundary) is unnecessary if the inclusion of "or outdoors" is added to that definition (see my previous suggestion).  I believe this will be considerably less confusing.

Proposed Change:

Unconditioned Space – The outdoor environment or an area or room within a building that is not Conditioned Space but which may contain heat sources or sinks that influence the temperature of the area or roomany space that is enclosed within a building but is not conditioned space.

Response:

Accepted as Modified. It is important that unconditioned spaces may contain heat sources and sinks that impact the temperature of the unconditioned space. Examples include water heaters, HVAC systems, etc. that can impact the temperature of unconditioned spaces but do not constitute grounds for classifying them a Conditioned Space under thermostatic control. However, the definition of Unconditioned Space will be altered to remove the “outdoor environment” and an informative footnote will be added for additional clarification as follows:

Unconditioned Space ¹ – The outdoor environment or a An area or room within a building that is not Conditioned Space but which may contain heat sources or sinks that influence the temperature of the area or room.

¹ (Informative Note) Unconditioned Space represents the simulation control volume that is not mechanically controlled to specified conditions but whose conditions depend on the Unconditioned Space boundary conditions and its heat sources and sinks and on which an energy balance is performed by the simulation software.

Comment #44

Page Number: 14
Paragraph / Figure / Table / Note: TEU definition
Comment Type: Editorial

Comment:

"multiplied by 40%" could be more clearly stated as "mulitpiled by 0.4"

Proposed Change:

...multiplied by 40%0.4

Response:

Accepted as Modified by the acceptance of comment #1.

Comment #45

Page Number: multiple
Paragraph / Figure / Table / Note: multiple
Comment Type: Editorial

Comment:

All references to ASHRAE 62.2-2010 Addendum "r" may be updated to ASHRAE 62.2-2013, which has been published since the RESNET 301 Draft was prepared.

Proposed Change:

ASHRAE Standard 62.2-20130, Addendum ‘r’

Response:

Accepted as Modified by the acceptance of comment #3.

Comment #46

Page Number: 17
Paragraph / Figure / Table / Note: Air Exchange Rate / Rated Home and related footnotes
Comment Type: Technical

Comment:

To correctly address the use of ASHRAE 62.2-2013 (which is now published and may be referenced directly), and also specify an air exchange rate for the purpose of calculating energy loads, these two air exchange rates must be treated separately. Though they are both derived from the same building enclosure leakage test, they are computed differently;  thus there is no single "air exchange rate" that can be calculated and appropriately applied both to energy loads and ventilation effectiveness requirements.  

ASHRAE 62.2-2013 handles measured shell leakage in the building explicitly, unlike 62.2-2010. According to 62.2-2013, the equivalent ventilation effectiveness of the measured shell leakage is directly added to the whole-house mechanical ventilaiton rate for the purpose of calculating the contribution of building enclosure air exchange to the total ventilation requirement.  (Though it is never added for multifamily dwellings}  Further, the mechanism for estimating the ventilation impact of the measured enclosure leakage in the building using the revised methodology (updated ASHRAE 136 approach now included in 62.2-2013) is intended only for calculating equivalent ventilation impact of that leakage; this method must not be confused with the LBNL model (or equivalent) that is appropriately intended for the calculation of effective energy loads due to natural infiltration in the building.    (This last point is related to a comment on sectiions 4.3.3.1.3 and 4.3.3.2.3 that I will make separately).  The proposed change handles these calculations separately, and arrives at the same intention: to ensure that the rated home shell leakage cannot be reduced below the level that would provide effective ventilation that meets the current edition of ASHRAE Standard 62.2

Proposed Change:

[Table 4.2.2(1), Air exchnge rate, Rated Home]

... For residences that are tested in accordance with Section 802 of the Mortgage Industry National Home energy Rating Systems Standards, without Whole-House Mechanical Ventilation Systems, the measured air exchange rate as determined from the Building Enclosure Airtightness Test(e) but not less than 0.30 ach

For residences tested in accordance with Section 802 of the Mortgage Industry National Home energy Rating Systems Standards, with Whole-House Mechanical Ventilation Systems, the measured air exchange rate as determined from the Building Enclosure Airtightness Test((e) combined with the mechanical ventilation rate,(f) for the purpose of heating and cooling load calculations.  The combined air exchange rate for the purpose of ventilation effectiveness calculations(g) which shall not be less than 0.03 x CFA + 7.5 x (Nbr+1) cfm. Any shortfall shall be made up by increasing the building enclosure leakage for the purpose of the heating and cooling load calculations by the same amount that it must be increased to meet the ventilation effectiveness requirement of 0.03 x CFA + 7.5 x (Nbr+1) cfm..

[footnotes]

(e) Tested envelope enclosure leakage shall be determined and documented using the on-site inspection protocol as specified in Section 802 of the Mortgage Industry National Home Energy Rating Systems Standards by an Approved Tester. Either hourly calculations using the procedures given in the 2009 ASHRAE Handbook of Fundamentals, Chapter 16, page 16.23, Equation 48 (Sherman-Grimsrud model) using Shelter Class 4 or calculations yielding equivalent results shall be used to determine the air exchange rate.

(f)  For the purpose of heating and cooling load calculations, tThe combined air exchange rate for infiltration and Whole-House Mechanical Ventilation Systems shall be determined in accordance with Equation 51 of 2009 ASHRAE Handbook of Fundamentals page 16.25 in combination with the Section 4 provisions of ASHRAE Standard 62.2-2010, Addendum ‘r’.

[new footnote "g" (renumber subsequent notes accordingly):]

(g) For the purpose of ventilation effectiveness calculations, the combined air exchange rate for infiltration and Whole-House Mechanical Ventilation Systems shall be determined in accordance with ASHRAE 62.2-2013 Section 4.1.2, by adding Qinf (as derived from ELA using Section 802 of the Mortgage Industry National Home Energy Rating Systems Standards) to the Whole-House Mechanical Ventilation System flow rate (in like units). For multifamily dwellings, Oinf shall be 0.

Response:

Accepted as Modified. Inclusion of the additional term “Building Enclosure Airtightness Test” is rejected as unnecessary as this testing protocol is fully defined by the testing required by section 802 of the Mortgage Industry National Home Energy Rating Systems Standards. There is also no need to add the term “ventilation effectiveness” as it does not provide any increased clarity and the provisions of the standard are specific without adding this additional terminology. Table note (f) is not intended to define how heating and cooling load calculations are to be accomplished but rather to define how the combination of infiltration and whole-house mechanical ventilation is to be determined (additively as specified by Equation 4.6 of ASHRAE 62.2-2013). A new footnote (g) will be created to more clearly enunciate that energy loads are to be calculated using the Sherman-Grimsrud model for both the Rated and the Reference Homes. The revised Table 4.2.2(1) and related footnotes on air exchange and mechanical ventilation are as follows (see also response to Comments #2 and #69):

 

Air exchange rate	Specific Leakage Area (SLA) (d) = 0.00036 (assuming no energy recovery) and with energy loads calculated in quadrature (f), (g)	For residences that are not tested, the same as the HERS Reference Home For residences that are t Tested in accordance with Section 802 of the Mortgage Industry National Home energy Rating Systems Standards, For Residences without Whole-House Mechanical Ventilation Systems, the measured air exchange infiltration rate (e) but not less than 0.30 ach For residences tested in accordance with Section 802 of the Mortgage Industry National Home energy Rating Systems Standards, with Whole-House Mechanical Ventilation Systems, the measured air exchange infiltration rate (e) combined with the time-averaged Whole-House mMechanical vVentilation System rate,(f) which shall not be less than 0.03 x CFA + 7.5 x (Nbr+1) cfm and with energy loads calculated in quadrature (g)
Whole-House Mechanical ventilation:	None, except where a mechanical ventilation system is specified by the Rated Home, in which case: Where Rated Home has supply-only or exhaust-only Whole-House Ventilation System: 0.30*fanCFM*8.76 kWh/y Where Rated Home has balanced Whole-House Ventilation System without energy recovery: 0.60* fanCFM*8.76 kWh/y Where Rated Home has balanced Whole-House Ventilation System with energy recovery: 1.00*fanCFM*8.76 kWh/y And where fanCFM is calculated in accordance with Section 4.1.2 of ASHRAE Standard 62.2-2013 for a continuous Whole-House Ventilation System. Annual vent fan energy use: kWh/y =  0.5*(supVfan + exhVfan)*8.76 where:  supVfan = cfm of supply ventilation fan exhVfan = cfm of exhaust ventilation fan and where supVfan and exhVfan are calculated in accordance with ASHRAE Standard 62.2-2010, Addendum ‘r’	Same as Rated Home       Same as Rated Home

 

(d)  Where Effective Leakage Area (ELA) is defined in accordance with Section 4.1.2 Equation 4.4 of ASHRAE Standard 62.2-20102013, Addendum ‘r’ and where SLA = ELA / CFA (where ELA and CFA are in the same units). Either hourly calculations using the procedures given in the 2009 ASHRAE Handbook of Fundamentals, Chapter 16, page 16.23, Equation 48 (Sherman-Grimsrud model) using Shelter Class 4 or calculations yielding equivalent results shall be used to determine the energy loads resulting from air exchange.

 

(e)  Tested envelope leakage shall be determined and documented using the on-site inspection protocol as specified in Section 802 of the Mortgage Industry National Home Energy Rating Systems Standards by an Approved Tester.  Either hourly calculations using the procedures given in the 2009 ASHRAE Handbook of Fundamentals, Chapter 16, page 16.23, Equation 48 (Sherman-Grimsrud model) using Shelter Class 4 or calculations yielding equivalent results shall be used to determine the air exchange rate.

 

(f)  The combined air exchange rate for Infiltration and Whole-House Mechanical Ventilation Systems shall be determined in accordance with Equation 51 of 2009 ASHRAE Handbook of Fundamentals page 16.25 in combination with the Section 4 provisions Equation 4.6 of ASHRAE Standard 62.2-20102013, Addendum ‘r’.

 

(g)  Either hourly calculations using the procedures given in the 2013 ASHRAE Handbook of Fundamentals (IP version), Chapter 16, page 16.25, Equation 51 using Shelter Class 4 or calculations yielding equivalent results shall be used to determine the energy loads resulting from infiltration in combination with Whole-House Mechanical Ventilation systems.

Comment #47

Page Number: 18
Paragraph / Figure / Table / Note: Table 4.2.2(1),
Comment Type: Technical

Comment:

I believe that this is intended strictly an adjustment to the reference home for the purpose of comparison of rated home ventilation fan electric energy.  Thus, the "standardized" reference home ventilation fan energy should correspond to the rated home fan flows, and not simply to the reference home or rated home ventilation requirements in accordance with ASHRAE 62.2-2013.   In the previous section of Table 4.2.2(1) (Air ekchange rate) there is no requirement that any whole-house ventilation system in the rated home must actually meet the Section 4.1 air flow requirements of 62.2; only that it be present (and that if it falls short of the Section 4.1 requirements,  the rated home energy loads are increased as if it did not fall short).  If the "standardized" reference home ventilation fan energy is based on 62.2 requirements, rather than the actual flow rates in the rated home, it will provide undue "credit" for fan efficiency in the rated home whenever the rated home ventilation flow is less than the 62.2 requirement.  The proposed change allows for the 62.2-2013 infiltration credit but does not reduce the refernece home "standardized" fan energy below the minimum flow rate thus required.  (There is no need to cap the "standardized" fan energy when rated home fan flows are larger than the 62.2 requirements, because the space conditioning energy penalties of excess ventilation will far outweigh any HERS index benefit of an improve fan efficiency.)

Note it is also necessary to specify that the 62.2 fan rate must be calcuated for the rated home;  the infiltration credit sholud not and cannot be based on the shell leakage of the reference home. Finally it sholud be clear that the stardandized fan energy is not based on the "full-on" reference home fan flows, but the time-weighted flows if the rated home ventilation fan(s) run intermittently.

Proposed Change: Response:

Rejected. The commenter is not correct. There is a specific requirement that the Rated Home air exchange rate meet the requirements of ASHRAE Standard 62.2-2013. The air exchange rate specification for Rated Homes with mechanical ventilation quite specifically states that the combined air exchange rate (infiltration + mechanical ventilation) may not be less than 0.03*CFA + 7.5*(Nbr+1), which is the specific minimum requirement of Section 4, ASHRAE Standard 62.2. However, based on this comment, note (f) of Table 4.2.2(1) will be revised to make this specification more explicit. The combined air exchange rate in the Reference Home on which the fan energy is based also equals the minimum requirement of ASHRAE 62.2-2013 such that the combined air exchange rate for fan energy determination in the Reference Home is the same as the minimum combined air exchange rate in the Rated Home. The argument that the mechanical ventilation rate may be less in the Reference Home than in the Rated Home is accurate but with the revised SLA for the Reference Home, there will be very little difference unless the Rated home is very tight. If the Rated Home is very tight, the difference in mechanical vent rate is compensated somewhat by the fact that the fan energy use rates of the Reference Home (see comment #69) are consistent with IECC 2012 minimum standards, which (excepting ERVs) have roughly twice the energy use of the best available supply or exhaust ventilation fans. Further, this comment is rejected in favor of response to Comment #46, which resolves the issues raised in this comment and specifies the Reference Home ventilation fan energy use in terms of the mechanical ventilation system type installed in the Rated Home.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #48

Page Number: 19
Paragraph / Figure / Table / Note: Table 4.2.2(1), Thermal distribution systems (rated home)
Comment Type: Technical

Comment:

Section 4.5.3.2 of proposed standard 301 specifies an alternate un-tested duct leakage for the purpose of existing home retrofit savings calculations; that alternate must be recoginzed in Table 4.2.2(1) to avoid a conflict.

Proposed Change:

For forced air distribution systems: same as Reference Home, except where the air distribution system leakage is not measured in the original Baseline Existing Home for the purpose of calculating Existing Home Retrofit Savings, and then in accordance with Section 4.5.3.2.1 of this Standard;; or, when tested in accordance with Section 803 of the Mortgage Industry National Home Energy Rating Systems Standards (n), and then either calculated through hourly simulation or calculated in accordance with ASHRAE Standard 152-2004 with the ducts located and insulated as in the Rated Home.

Response:

Rejected. In favor of comment #2, which is accepted as modified. Further, all confirmed ratings now require forced air distribution system testing and Section 4.5.3.2 of the Standard is explicit as to how the original condition of air distribution systems in existing homes are to be treated for the purposes of calculating existing home retrofit savings rather than for the purposes of conducting a Rating.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #49

Page Number: 20
Paragraph / Figure / Table / Note: Table 4.2.2(1), footnote (b) definition of Thermal Boundary Wall
Comment Type: Technical

Comment:

The proposed definition of "Unconditioned Space" (to include outdoors) does not adequately address this situation; per my previous comment to remove "outdoors" from the defination of Unconditioned Space, and also to explicitly include soil contact for clarity, I submit the following proposed change.

Proposed Change:

Thermal boundary wall is any wall that separates Conditioned Space from Unconditioned Space, outdoors, and/or the surrounding soil

Response:

Accepted. Improves clarity of Standard.

Comment #50

Page Number: 20
Paragraph / Figure / Table / Note: Table 4.2.2(1), footnote (d)
Comment Type: Technical

Comment:

ASHRAE 62.2-2013 specifies ELA based on specific test procedures (ASTM E779 or CGSB 149.10, but also states that "The authority having jurisdiction may approve other means of calculating effective leakage area (ELA), such as the RESNET Mortgage Industry National Home Energy Systems Standard."  To ensure that both the test procedure and the calculation are done in accordance with RESNET standard Section 802, I suggest that this footnote simply refer directly to that section, which includes a calculation of ELA, and is also not confused with the 62.2 "infiltration credit," Section 4.1.2, in the context of which that version of the ELA is defined.

Proposed Change:

(d) Where Effective Leakage Area (ELA) is defined in accordance with Section 4.1.2 of ASHRAE Standard 62.2-2010, Addendum ‘r’Section 802.8 of the Mortgage Industry National Home Energy Rating Systems Standards and where SLA = ELA / CFA (where ELA and CFA are in the same units). 

Response:

Rejected. Table note (d) pertains only to the Reference Home. Thus, the reference to the testing methods and outcomes of Section 802.8 of the Mortgage Industry National Home energy Rating Systems Standards, which is applicable only to the Rated Home, has no bearing and is misapplied in this case (see also response to Comment #46).

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #51

Page Number: 22
Paragraph / Figure / Table / Note: Table 4.2.2(1), footnotes (i), (k), and (m)
Comment Type: Technical

Comment:

(all three) The term "proposed" is unnecessarily confusing, because it does not apply to ratings of existing homes that either do or do not have these systems.

(i) The premise of this footnote is that there is no heating system, so the second sentence referring to "electric heating systems" is illogical.  There is also a grammatical omission due to the published proposed change. 

(m) deletion of the word "predominant" leaves incomplete guidance in cases where there are heating systems using more than one fuel in the Rated Home.

Proposed Change:

(i) For a Rated Home without a proposed heating system, a gas heating system with the  efficiency provided in Table 4.2.2(1a) shall be assumed for both the HERS Reference Home and Rated Home. For electric heating systemsa Rated Home without a propsed heating system that has no natural gas or delivered fossil fuels, the efficiency an air-source heat pump shall be selected with the  efficiency provided in Table 4.2.2(1a) shall be assumed for both.

(k) For a Rated Home without a proposed cooling system, an electric air conditioner with the efficiency provided in Table 4.2.2(1a) shall be assumed for both the HERS Reference Home and the Rated Home.

[m] ... For a Rated Home without a proposed water heater, a 40-gallon storage-type water heater of the same fuel as the predominant heating fuel type used for the heating system(s) shall be assumed for both the Rated and HERS Reference Homes. In both cases the Energy Factor of the water heater shall be as prescribed for water heaters by CFR 430.32(d), published in the Federal Register/Volume 66, No. 11, Wednesday, January 17, 2001 for water heaters manufactured after January 20, 2004.

Response:

Accepted as Modified. Improves clarity of the standard. Editorial modifications were made to the original proposed change to improve clarity as follows:

(i)   For a Rated Home without a proposed heating system, a gas heating system with the efficiency provided in Table 4.2.2(1a) shall be assumed for both the HERS Reference Home and Rated Home.  For a Rated home that has no access to natural gas or fossil fuel delivery, an electric heating systems, the efficiency air-source heat pump with the efficiency provided in Table 4.2.2(1a) shall be selected assumed for both the HERS Reference Home and Rated Home.

(k)  For a Rated Home without a proposed cooling system, an electric air conditioner with the efficiency provided in Table 4.2.2(1a) shall be assumed for both the HERS Reference Home and the Rated Home.

(m) For a Rated Home with a non-storage type water heater, a 40-gallon storage-type water heater of the same fuel as the proposed water heater shall be assumed for the HERS Reference Home.  For tankless water heaters, the Energy Factor (EF) shall be multiplied by 0.92 for Rated Home calculations. For a Rated Home without a proposed water heater, a 40-gallon storage-type water heater of the same fuel as the predominant heating fuel type used for the heating system(s) shall be assumed for both the Rated and HERS Reference Homes. In both cases the Energy Factor of the water heater shall be as prescribed for water heaters by CFR 430.32(d), published in the Federal Register/Volume 66, No. 11, Wednesday, January 17, 2001 for water heaters manufactured after January 20, 2004.

Comment #52

Page Number: 27
Paragraph / Figure / Table / Note: 4.2.2.2.1
Comment Type: Technical

Comment:

The proposed changes introduce a gramattical error.   Also, it may be easy for users to miss the fact that in Appendix A of the RESNET standard (page A-11) it states: "When it is possible to inspect insulation as installed (i.e., new construction), inspectors shall rate the installation as “Grade I, II, or III” according to the following guidelines..."

The intention of the grading system was for new construction and new installations of insulation, and the defaulting of "uninspected" insulation as Grade III was intended for a compliance environment (assuming the worst unless it can be proven better).  This approach is often inappropriate for existing homes where cavity insulation is hidden from view; Grade III, representing 5% of cavity with no insulation, is far too punitive (for example) for most post 1970's construction with batt cavity insulation.  (While arguably many older homes with blown-in cavity insulation have much larger gaps due to incomplete fill and low-density settling, such a situation is much better assessed using a thermographic scan with the uninsulated areas modeled as separate areas in accordance with currently proposed Section 4.2.2.2.2(c), or original RESNET Standard 303.4.1.4.2.3.)  For more accurate savings predictions of existing homes, this distinction should be made clearer in Standard 301.

Proposed Change:

The insulation of the HERS Reference Home enclosure elements shall be modeled as Grade I. for tThe insulation of the Rated Home shall either be inspected according to the procedures of Appendix A of the Mortgage Industry National Home Energy Rating Systems Standard for new construction or new work; or, if for new construction or new work that is not inspected, shall be modeled as Grade III as given in Section 4.2.2.2.2 and shall be recorded as “not inspected” in the rating information. For pre-existing enclosed cavity insulation that cannot be inspected directly, batt insulation shall be modeled as Grade II; loose-fill insulation shall be modeled as Grade II unless a thermographic evaluation is done to estimate the total uninsulated area of the enclosure element(s).

Response:

Rejected.  The standard should not distinguish between new and existing construction, both of which may utilize thermographic inspection. However, the sentence structure should be changed as proposed to place a period following Grade I in the first sentence, starting a new second sentence with the word “The” as specified in the comment.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #53

Page Number: 27
Paragraph / Figure / Table / Note: 4.2.2.2.1 Exception (b)
Comment Type: Technical

Comment:

This proposed change is problematic as written, because many manufacturers of a wide range of products and systems regularly provide "scientific" or "laboratory test data" reports that often appear to raters as defensible and accurate.  These reports are often designed to confuse readers and promote the appearance of higher performance of a specific product.  That type of unsupported or improperly supported claim is exactly what the deleted text was supposed to address, but the proposed replacement does not adequately address the issue.

Proposed Change:

The R-values for non-stardard materials or for Structural Insulated Panels (SIP’s), Insulated Concrete Forms (ICF’s), and other pre-manufactured assemblies when accompanied by supporting test data consistent with ASTM C 177-85, ASTM C 518,-91 ASTM C 1114-95, ASTM C 236-89, or ASTM C 976-90.

Response:

Accepted. Improves clarity of Standard.

Comment #54

Page Number: 28
Paragraph / Figure / Table / Note: 4.2.2.2.2. (c)
Comment Type: Editorial

Comment:

Suggested changes for clarity.

Proposed Change:

(c) Areas of an assembly having different insulation types or R-values (including uninsulated areas in excess of 5% of any otherwise insulated building component) shall be modeled separately, with the applicable R-values and assembly areas associated with each different insulation situation.

Response:

Accepted. Improves clarity of Standard.

Comment #55

Page Number: 28
Paragraph / Figure / Table / Note: 4.2.2.2.2. (d)(2)
Comment Type: Editorial

Comment:

Suggested change for clarity and correctness.

Proposed Change:

2) Testing in accordance with ASTM Standard C-1363-11. Test results may be modified to add or subtract R-values to the tested assembly to that reflect differences between the tested assembly and proposed assemblies when such differences are continuous and occur outside of the cavity.

Response:

Accepted. Improves clarity of Standard.

Comment #56

Page Number: 30
Paragraph / Figure / Table / Note: 4.2.2.5.1.4.
Comment Type: Editorial

Comment:

I believe that this entire section is redundant and is already covered in Table 4.2.2(1), Mechanical Ventialation (HERS Reference Home).  It should be deleted from one or the other location in the standard.  If there is a compelling reason to include this requirement in both places, then 4.2.2.5.1.4. should be modified in accordance with my previous comment regarding this requirement in Table 4.2.2(1).

Proposed Change:

4.2.2.5.1.4. Whole-House Mechanical Ventilation Systems. Where a Whole-House Mechanical Ventilation System is provided in the Rated home, REULLA shall be modified for the Reference Home by adding [0.5*(supVfan cfm + exhVfan cfm)*8.76] kWh/y for ventilation fan operation, converted to MBtu/y, where MBtu/y = (kWh/y)/293.

[renumber subsequent accordingly]

Response:

Accepted. Improves clarity of Standard and reduces redundancy. Section 4.2.2.5.1.4 will be stricken in favor of Table 4.2.2(1)

Comment #57

Page Number: 38
Paragraph / Figure / Table / Note: 4.3.3.
Comment Type: Technical

Comment: Proposed Change:

To determine equipment mis-sizing, the baseline heating and cooling capacity shall be selected in accordance with ACCA Manual S based on building heating and cooling loads calculated in accordance with Manual J, Eighth Edition, ASHRAE 2009 Handbook of Fundamentals, or an equivalent computation procedure, using the following assumptions:

Response:

Rejected. Manual S is useful for certain aspect of automated HVAC sizing. For example, to prevent under sizing of air conditioning systems, it is necessary to account for dry coil conditions in climates where they occur in order to have the necessary capacity to meet the air conditioning load in those climates. Thus, there is good reason to leave Manual S in this provision.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #58

Page Number: 38
Paragraph / Figure / Table / Note: 4.3.3.1.3(a) and (b)
Comment Type: Editorial

Comment:

The change from W to wsf was omitted in this section (see 4.3.3.2.3)

Proposed Change: Response:

Accepted. Corrects and editing oversight and improves clarity of Standard.

Comment #59

Page Number: 40
Paragraph / Figure / Table / Note: 4.3.5
Comment Type: Editorial

Comment:

The equivalent section in the Mortgage Industry Home Energy Rating standard was amdended and published in 2011, and this version is included in the January 2013 version.  However, these accepted changes were omitted from the original draft of Standard 301, and should have been included.  The fan and pumping energy values prior to this change are punitive and were corrected in the 2011 amendment, which also provided defaults to be used in projected ratings when the actual pump is unknown.  See http://www.resnet.us/standards/Auxiliary_Electric_Energy_of_Ground_Source_Heat_Pumps_Amendment.pdf

Proposed Change:

http://www.resnet.us/standards/Auxiliary_Electric_Energy_of_Ground_Source_Heat_Pumps_Amendment.pdf  provides the detail with underline/strikeout formatting, with the only difference being the section number.

Response:

Accepted. Corrects and oversight of these revised provisions in the 1^st round of public comments.

Comment #60

Page Number: 48
Paragraph / Figure / Table / Note: 4.5.2.1.
Comment Type: Editorial

Comment:

delete the word "home"

Proposed Change:

... but the existing appliance is not removed from the home property,...

Response:

Accepted. Improves clarity of Standard.

Comment #61

Page Number: 65
Paragraph / Figure / Table / Note: 5.2.2
Comment Type: Editorial

Comment:

The RESNET standing Technical Committee no longer exists.  I'm not sure if the SDC is the right one to substitute, but it seems closest in terms of standing committees; presumably the task would be assigned by the SDC to an existing or ah-hoc working group.

Proposed Change:

5.2.2. Review. Upon review of an IDR, the RESNET Standing Technical Standards Development Committee shall request additional supporting documentation for further consideration or provide a recommendation with justification to the Board as follows: a) is approved, b) is denied, or c) is approved with modifications. The RESNET Board of Directors shall accept or reject the recommendation of Technical the Standards Development Committee or request further information from the Technical Committee.

Response:

Accepted as Modified to include modifications of Section 5.2.2 and 5.2.3 as follows (see also comment #63):

“5.2.2  Review. Upon review of an IDR, the RESNET Standing Technical Standards Development Committee 300 (SDC 300) shall either request additional supporting documentation for further consideration or provide a recommendation with justification to the Standards Management Board (SMB) as follows: a) is approved recommend approval, b) is denied recommend denial, or c) is approved recommend approval with modifications. The RESNET Board of Directors shall accept or reject the recommendation of Technical Committee or request further information from the Technical Committee.

5.2.3  Approval. IDRs shall be approved on a case by case basis. The SMB shall accept or reject the recommendation of SDC 300 or shall request further information from SDC 300. RESNET shall assign a unique identifier to each IDR and maintain a database of IDRs. If RESNET approves the IDR, the HERS provider may issue a supplemental report that adjusts the HERS Index as approved.”

Comment #62

Page Number: Cover page, page 1, page 54
Comment Type: General

Comment:

 

Remove “label” and “labeling”. The standard does not offer any guidance on what a label should look like, the details that should be on a label, where a label is placed, or the like.  The standard is about the calculation.  Remove “label” and “labeling”, except when the words reference a label on a product used in a house like the energy guide label on a clothes washer.

Proposed Change:

 

Cover page:

Standard for the Calculation and Labeling of the Energy Performance of Low-Rise Residential Buildings using the HERS Index

Page 1: Standard for the Calculation and Labeling of the Energy Performance of Low-Rise Residential Buildings using the HERS Index

 

Page 1:

Forward

This Standard provides a consistent, uniform methodology for evaluating and labeling the energy performance of residences.

 

Page 1:

1. Purpose. The provisions of this document establish residential energy rating and labeling Standards, consistent with the provisions of the Energy Policy Act of 1992, which provide for uniformity and consistency in the rating and labeling of such buildings.

 

Page 54:

5. Certification and Labeling. This section establishes minimum uniform standards for certifying and labeling home energy performance using the HERS Index. These include minimum requirements of the Home Energy Rating process, standard methods for estimating energy use, energy cost and pollution emission savings, minimum reporting requirements, and specification of the types of ratings that may be performed in accordance with this Standard. 

Response:

Rejected. A new Section 5.3 has been added to the Standard to specify the requirements for labeling. See response to comment #14.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #63

Page Number: 23, 63, 64
Comment Type: Technical

Comment:

 

Remove proprietary references.  Many proprietary references were removed in the first round of comments.  The rest need to be removed as well.

Proposed Change:

 

Page 23:

(o) Raters shall obtain Energy Factors (EF) for domestic hot water equipment from manufacturer’s literature or from AHRI directory for equipment being used, where available. For instances where a manufacturer provided or AHRI published EF is not available (e.g. commercial water heaters), the rater shall use the guidance provided here to determine the effective EF of the water heater. 

i. For residential oil, gas and electric water heaters or heat pump, default EF values provided in Table 4.4.2(3) for age-based efficiency or Table 4.4.2(4) for non-age-based efficiency shall be used.

ii. For commercial water heaters used in residential applications, one of the following approaches shall be followed to determine the EF for a particular piece of equipment.

a. Use the an approved commercial hot water system calculator posted on the RESNET web site. 5

b. Use Table C404.2 Minimum Performance of Water Heating Equipment in the 2012 IECC to find the minimum requirement for the type of water heater.

 

Page 63:

5.2.1. Petition. HERS providers can petition RESNET26  the adopting entity or the approved authority for adjustment to the HERS Index for a Rated Home with features or technologies not addressed by Approved Software Rating Tools and/or this Standard. Innovative Design Requests (IDRs) to RESNET shall include, at a minimum, the following:

 

Page 64:

5.2.2. Review. Upon review of an IDR, the adopting entity or the approved authority RESNET Standing Technical Committee shall request additional supporting documentation for further consideration or provide a recommendation with justification to the Board as follows: a) is approved, b) is denied, or c) is approved with modifications. The RESNET Board of Directors shall accept or reject the recommendation of Technical Committee or request further information from the Technical Committee.

 

5.2.3. Approval. IDRs shall be approved on a case by case basis. RESNET The adopting entity or the approved authority shall assign a unique identifier to each IDR and maintain a database of IDRs. If RESNET the adopting entity or the approved authority approves the IDR, the HERS provider may issue a supplemental report that adjusts the HERS Index as approved.

 

Response:

Accepted in Part. Proposed change to clause ‘a’ on page 23 is accepted. Proposed changes to Section 5.2.1, 5.2.2 and 5.2.3 on pages 63 and 64 are rejected. As the ANSI-Accredited Standards Developer (ASD) for this Standard, the RESNET standards development consensus committee (SDC 300) shall reserve the authority to interpret the Standard, including the authority to evaluate Innovative Design Requests. (See also comment #61.)

Comment #64

Page Number: 2, 4, 21, 22, 26, 58
Comment Type: General

Comment:

 

Remove all mandatory references to the Mortgage Industry National Home Energy Rating System Standards, as this document has not been out for an ANSI/RESNET review.  A normative reference to another RESNET document does not eliminate the need to have the content of that document subjected to an ANSI/RESNET review.

 

Alternately in some fashion initiate a public comment period on all of the content of the referenced, but not publicly commented on, Sections of the Mortgage Industry National Home Energy Rating System Standards.

Proposed Change:

 

Page 2:

Approved Rating Provider – An approved entity responsible for the certification of Home Energy Raters working under its auspices and who is responsible for the quality assurance of such certified Raters and for the quality assurance of Home Energy Ratings produced by such Home Energy Raters in accordance with Section 600 of the Mortgage Industry National Home Energy Rating System Standards.

 

Approved Tester – An individual who, by virtue of training and examination, has demonstrated competence in the performance of on-site testing in accordance with Section 800 of the Mortgage Industry National Home Energy Rating Systems Standards and who has been approved by an Approved Rating Provider to conduct such tests.

 

Page 4:

Conditioned Floor Area (CFA) – The projected floor area of the Conditioned Space within a building, measured in accordance with ANSI Standard Z765-2012 with exceptions as specified by the adopting entity or an approved authority in Appendix A of the Mortgage Industry National Home Energy Rating Systems Standards.

 

Table 4.2.2(1):

Remove 3 references to Sections 802 and 803 of the Mortgage Industry National Home energy Rating Systems Standards.

 

Page 21:

(e) Tested envelope leakage shall be determined and documented using the approved on-site inspection protocol as specified in Section 802 of the Mortgage Industry National Home Energy Rating Systems Standards by an Approved Tester. Either hourly calculations using the procedures given in the 2009 ASHRAE Handbook of Fundamentals, Chapter 16, page 16.23, Equation 48 (Sherman-Grimsrud model) using Shelter Class 4 or calculations yielding equivalent results shall be used to determine the air exchange rate.

 

Page 22:

(n) Tested duct leakage shall be determined and documented by an Approved Tester using the approved protocols specified in Section 803, Mortgage Industry National Home Energy Rating Systems Standards. 

 

Page 26:

4.2.2.2. Insulation Inspections: All enclosure elements for the Rated Home shall have their insulation assessed in accordance with this Standard. Installed cavity insulation shall be rated as Grade I, II, or III in accordance with the approved on-site inspection procedures of Appendix A, of the Mortgage Industry National Home Energy Rating Systems Standard.

 

4.2.2.2.1. The insulation of the HERS Reference Home enclosure elements shall be modeled as Grade I for the insulation of the Rated Home insulation shall either be inspected according to the procedures of Appendix A, of the Mortgage Industry National Home Energy Rating Systems Standards or, if not inspected, shall be modeled as Grade III and shall be recorded as “not inspected” in the rating information.

Exceptions:

(a) Modular and manufactured housing using IPIA inspections shall be considered as an acceptable alternative for the HERS inspection where the manufacturer of the home includes the approved on-site inspection procedures for of Appendix A of the Mortgage Industry National Home Energy Rating Systems Standard insulation details and requirements in their “DAPIA” packages which are used by IPIA’s for their factory inspections.

 

Page 58:

5.1.4.1.3. Confirmed Ratings shall be subjected to the approved Quality Assurance requirements of Section 900 of the Mortgage Industry National Home Energy Rating shall be certified in accordance with Section 5.2 of the Systems Standard.

 

5.1.4.2.1. For the set of Rated Homes, all Minimum Rated Features shall be field-verified through inspection and testing of a single home in the set, or distributed across multiple homes in the set, in accordance with Section 600 of the Mortgage Industry National Home Energy Rating Systems Standard.

 

5.1.4.2.1.5.1.4.2.3. Sampled Ratings shall be subjected to the approved Quality Assurance requirements of Section 900 of the RESNET Mortgage Industry National Home Energy Rating Systems Standard. 

Response:

Accepted in Part. Proposed change to Approved Rating Provider is accepted. Proposed change to Approved Tester is modified to specify Section 802 and 803 of Mortgage Industry National Home Energy Rating Systems Standards rather than Section 800 because no other standard exists that will allow single point measurement. Proposed change to Conditioned Floor Area (CFA) is accepted as modified to include the specification of exception in thee definition as follows:

Conditioned Floor Area (CFA) – The projected floor area of the Conditioned Space within a building, measured in accordance with ANSI Standard Z765-2012 except that, unlike the Ceiling Height Requirements of the ANSI Standard Z765, portions of the finished floor area that have a height of less than 5 feet shall be included in the Conditioned Floor Area with exceptions as specified in Appendix A of the Mortgage Industry National Home Energy Rating Systems Standards.

Proposed change to note (e) on page 21 is rejected. Proposed change to note (n) on page 22 is rejected. Proposed change to Section 4.2.2.2 on page 26 is accepted as modified to provide “such as …” or “equivalent to” language. Proposed change to Section 4.2.2.2.1 on page 26 does not include a proposed change; however, it will be modified to reflect change made to 4.2.2.2. Proposed change to the “Exception” on page 26 is accepted. Proposed change to Section 5.1.4.1.3 is accepted as modified to provide “such as …” or “equivalent to” language. Proposed changes to Sections 5.1.4.2.1 is accepted as modified to provide “such as …” or “equivalent to” language. Proposed changes to Sections 5.1.4.2.3 is accepted as modified to provide “such as …” or “equivalent to” language.

Comment #65

Page Number: 13
Comment Type: Technical

Comment:

 

The HERS Index (score) should represent energy use.  As RESNET documents state -- “Each integer … should represent a 1% change in the total energy use of the Rated Home relative to the total energy use of the Reference [2006 IECC] home.”  Makes sense.  Why take it out?  This goal of having an index seems to be understandable to most.  It could have multiple uses.  What is wrong with it?  It should be restored.

Proposed Change:

 

4. Home Energy Rating Calculation Procedures.

 

4.1. Determining the HERS Index. The HERS Index shall be a numerical integer value that is based on a linear scale constructed such that the HERS Reference Home has an Index value of 100 and a home that uses no net purchased energy has an Index value of 0 (zero). Each integer value on the scale shall represent a 1% change in the total energy use of the Rated Home relative to the total energy use of the Reference home. Except in states or territories whose laws or regulations require a specific alternative method, which shall control, equations 4.1-1 and 4.1-2 shall be used in a 2 step process to calculate the HERS Index for the Rated Home, as follows: 

Response:

Rejected. The proposed change is informative rather than normative, is not as precise as the mathematical procedures specified by Section 4.1 and does not contribute to the clarity of the Standard.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #66

Page Number: 13
Comment Type: Technical

Comment:

 

Remove the nMEUL (normalized Modified End Use Load).  The nMEUL is a complication that makes the HERS Index (score) less usable.  The energy use and energy cost, both already computed within RESNET procedures and by RESNET approved software, are more useful and more accurate. 

 

Although RESNET argues that the nMEUL is necessary, the simple fact that the nMEUL is used nowhere else is proof it is not really required. 

 

Both EPA’s Energy Star and DOE’s Builders Challenge Program have backed away from the absolute HERS Index.  Both have procedures for adjusting the HERS Index.   Both would be more likely to go back to using the HERS Index directly if it was based on energy use or energy cost.

 

In its analysis for Energy Star, EPA concluded that “Given a constant set of energy efficiency features, common design features can alter the HERS index up to several points for individual factors and greater than 15 points by combining several factors into configurations often encountered in the real world.”  See: http://www.energystar.gov/ia/partners/bldrs_lenders_raters/downloads/2011_Technical_Background.pdf?2478-6468 , page 4, “key feature #4” 

HERS scores that vary by 15 points for a set of common design features are inappropriate for an indicator of energy use or energy cost.  In order to compensate for the way the HERS Index is calculated, both Energy Star and Building America’s “Builders Challenge” now use a HERS score that is recomputed for each building design.  Previously, Energy Star used a single HERS score to indicate compliance with Energy Star, which was simpler to use and understand.

See the Energy Star adjustment at: http://www.energystar.gov/ia/partners/bldrs_lenders_raters/downloads/ES_HERS_Index_Target_Procedure_v23_clean_508.pdf

See the DOE adjustment at: http://www1.eere.energy.gov/buildings/residential/pdfs/challenge_home_hers_target_4-12.pdf

Solution: Keep the 2006 IECC as Standard Reference Design for the HERS Index.  Go back to a HERS Index that is based on energy use or energy cost.

Proposed Change:

 

Delete Sections 4.1.1 and 4.1.2. Replace with the equation described in 4.1.  Keep the adjustment for on-site power production as is now specified in 4.1.2.

Response:

Rejected. The proposed change is also not being made to a substantive change provision implemented as a result of the first round of public comments.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #67

Page Number: 4
Comment Type: Technical

Comment:

The proposed definition of conditioned space is too complicated to routinely apply.  The definition uses ASHRAE 55's definition of a human comfort, which at its simplest is a psychrometric chart.  Pity the poor person who has to decide based on inspection which parts of the house/HVAC system are going to reside in the area defined on the psychometric chart.  Presuming you had the time and information about the building and the climate to compute it, It could end up defining conditioned space such that the thermal envelop boundary and the conditioned space boundary would not necessarily align.  

The proposed definition of unconditioned space has "heat source or sink".  What space does not have a potential heat source or sink?  

Most would not clasify the whole outdoors as a "space".

We need simple and usable definitions of conditioned and unconditioned space.

Proposed Change:

 

Conditioned Space – An area or room within a building serviced by a space heating or cooling system designed to maintain human comfort in accordance with ASHRAE Standard 55-2010. 

 

 

Unconditioned Space – The outdoor environment or an area or room within a building that is not Conditioned Space but which may contain heat sources or sinks that influence the temperature of the area or room. 

 

Response:

Rejected. The proposed revisions reduce the clarity of the Standard.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #68

Page Number: many
Comment Type: General

Comment:

A marked improvement.  The public comment process inherently draws negative comments, but the positive deserves recognition.  This draft is a good deal better than the original.  Keep up the good work.

Response:

Accepted. This comment does not propose a change to the Standard.

Comment #69

Page Number: 17-18
Paragraph / Figure / Table / Note: Table 4.2.2(1); Mechanical Ventilation
Comment Type: Technical

Comment:

The original specification for annual mechanical ventilation fan energy use in the Reference Home approximates an energy recovery mechanical ventilation system. This tends to provide too large reference energy use for supply-only and exhaust-only ventilation systems, providing an unwarranted energy credit that is basically at the expense of balanced energy recovery mechanical ventilation systems, which have larger pressure drops and larger power requirements.

Proposed Change:

Building Component	HERS Reference Home	Rated Home
Mechanical ventilation:	None, except where a mechanical ventilation system is specified by the Rated Home, in which case: Annual vent fan energy use: Where the Rated Home has supply-only or exhaust-only ventilation system: 0.35*fanCFM*8.76 Where the Rated Home has balanced ventilation system without energy recovery: 0.70* fanCFM*8.76 Where the Rated Home has balanced ventilation system with energy recovery: 1.00*fanCFM*8.76 And where fanCFM is calculated in accordance with Section 4.1, ASHRAE Standard 62.2-2013 kWh/y =  0.5*(supVfan + exhVfan)*8.76 where:  supVfan = cfm of supply ventilation fan exhVfan = cfm of exhaust ventilation fan and where supVfan and exhVfan are calculated in accordance with ASHRAE Standard 62.2-2010, Addendum ‘r’	Same as Rated Home       Same as Rated Home

 

Response:

Accepted as Modified. Improves clarity of the Standard and removes a gaming mechanism that rewards certain types of mechanical ventilation systems in favor of others. The text of the provision have been modified for consistency and the cfm/watt values proposed for supply-only and exhaust-only and balanced ventilation systems have been revised slightly downward to be more consistent with ventilation systems on the market. Additional modifications have been made to Table footnotes (d), (e), (f) and a new footnote (g) has been added for additional clarity (see also response to Comments #2 and #46).

Comment #70

Page Number: 2/3
Comment Type: Technical

Comment:

Need to add definition of “Auxiliary Electric Consumption” to glossary.  This appears to have been inadvertantly dropped in creating the standard.  The term is used in Sections 4.1.1. and 4.3.5.

Proposed Change:

    Add to 3.2 Definitions:

 

 Auxiliary Electric Consumption – The annual auxiliary electrical energy consumption for a fossil fuel fired furnace, boiler or ground source heat pumps in kilowatt-hours per year.

 

 Add new section 4.3.6 and renumber as appropriate:

4.3.6. Fossil Fuel Fired Furnaces and Boilers. For for a fossil fuel fired furnace, or boiler, the Auxiliary Electric Consumption shall be determined as follows:

 

Auxiliary Electric Consumption (kWh/yr) = EAE * (HLH) / 2080) – where: HLH = annual heating load hours seen by the furnace/boiler. Note: If fan power is needed (kW), it is determined by Eae / 2080. 

Change Section 4.1.1 as follows:

nEC_x = normalized Energy Consumption for Rated Home’s end uses (for heating, including aAuxiliary eElectric cConsumption, cooling or hot water...

EC_r = estimated Energy Consumption for Reference Home’s end uses (for heating, including aAuxiliary eElectric cConsumption, cooling or hot water...

EC_x = estimated Energy Consumption for the Rated Home’s end uses (for heating, including aAuxiliary eElectric cConsumption, cooling or hot water...

  

Response:

Accepted. Improves clarity of Standard and explicitly defines how Eae is to be utilized to determine Auxiliary Energy Consumption, which the proposed change defines.

Comment #71

Page Number:
Paragraph / Figure / Table / Note: Section 4.3.3
Comment Type: Technical

Comment:

My comments on ResNet 301-2013 below.

4.3.3.1.7. Heat pump equipment capacity shall be sized to equal the larger of the building heating and cooling loads calculated season calculations in accordance with these procedures.

4.3.3.1.8. Systems shall be smaller than the size calculated using this procedure plus 100 Btu/hr.

Does 4.3.3.1.7 mean that a heat pump selection cannot have a higher heating or cooling capacity than the building load…in other words that the heat pump capacity must equal or be less than the building load (to prevent over sizing equipment)?

4.3.3.2.8. Heat pump equipment capacity shall be sized to equal the larger of the building heating and cooling loads calculated season calculations in accordance with these procedures.

4.3.3.2.9. To the degree that the installed equipment capacity for the Rated Home exceeds properly sized equipment in accordance with the above procedures, the manufacturer’s equipment performance rating shall be reduced accordingly.

Similar comments to 4.3.3.1.7 and 4.3.3.1.8.  What does the last phrase, “the manufacturer’s equipment performance rating shall be reduced accordingly. ” mean?  Is that to say if a 48,000 btu/h capacity heat pump is selected for a 43,000 btu/h heat loss/ heat gain that one simply considers the heat pump to be 43,000 btu/h?  Or would the heat pump performance (efficiency) be penalized in some way because it is oversized?

Response:

Accepted in Principle. The commenter does not propose a change to the Standard. However, the Committee has developed edits to Section 4.3.3.1.8 and 4.3.3.2.9 to further clarify these provisions as follows:

4.3.3.1.8  Systems shall not be smaller larger than the size calculated using this procedure plus 100 Btu/hr.                                        

4.3.3.2.9  To the degree that the installed equipment capacity for the Rated Home exceeds properly sized equipment in accordance with the above procedures, the manufacturer’s equipment performance rating shall be reduced impact of over-sizing on part-load performance shall be accounted accordingly.