BSR/RESNET/ACCA 310-201x, draft PDS-01, Standard for Grading the Installation of HVAC Systems Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: 12
Paragraph / Figure / Table / Note: 4.2.5.3.21
Comment Intent: Not an Objection
Comment Type: General

Comment:

This section includes the terms natural draft, mechanically drafted, and direct vented. Definitions should be added for these terms for clarity, and similar terms and associated definitions are already available in the 2018 International Mechanical Code.

 

Proposed Change:

If the equipment type is a Boiler or Furnace, then the venting type, either Nnatural Ddraft System, Mmechanically Ddrafted System, or Ddirect-Vvented Appliance.

Definitions:

Direct-Vent Appliance – Appliances that are constructed and installed so that all air for combustion is derived from the outdoor atmosphere and all flue gases are discharged to the outdoor atmosphere.

Mechanical Draft System – A venting system designed to remove flue or vent gases by mechanical means, that consists of an induced-draft portion under nonpositive static pressure or a forced-draft portion under positive static pressure.

Natural Draft System – A venting system designed to remove flue or vent gases under nonpositive static vent pressure entirely by natural draft.

 

Comment #2

Page Number: 13-14
Paragraph / Figure / Table / Note: 4.3.2 and 4.3.3
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

Section 4.3.2 allows a Dwelling Unit or Sleeping Unit not within a Dwelling or Townhouse to have a more limited design review if the maximum total heat gain across orientations is ≤18 kBTUh. The intent behind this allowance is that if the ‘worst-case’ cooling load is smaller than the capacity of the smallest commonly available cooling systems, then the same design can be used in similar units with a smaller cooling load.

This concept should be extended to the heating load, by adding a clause that the Dwelling Unit or Sleeping Unit must also have a maximum total heat loss of ≤35 kBTUh for this more limited design review to be used.  

 

Proposed Change:

Section 4.3.2

If a Dwelling Unit or Sleeping Unit not within a Dwelling or Townhouse is to be rated, and the maximum total heat gain across orientations documented in Section 4.2.4.17 is ≤18 kBTUh and the total heat loss documented in Section 4.2.4.19 is ≤35 kBTUh, then the following criteria shall be met in addition to the criteria in Section 4.3.4:

Section 4.3.3

If a Dwelling Unit or Sleeping Unit not within a Dwelling or Townhouse is to be rated, and the maximum total heat gain across orientations documented in Section 4.2.4.17 is >18 kBTUh or the total heat loss documented in Section 4.2.4.19 is >35 kBTUh, then the following criteria shall be met in addition to the criteria in Section 4.3.4:

 

Comment #3

Page Number: 4
Paragraph / Figure / Table / Note: DTD Definition
Comment Intent: Objection
Comment Type: Technical

Comment:

The terms TD, DTD and Delta T are often confused and used to mean different things in different parts of the industry. The definition listed in this version states

"Design Temperature Difference (DTD) – A constant value that represents the difference between the evaporator coil refrigerant’s Saturation Temperature and the supply air temperature."

This definition is consistent with a definition often used in refrigerated cases but is not the defintion commonly if ever used in air conditioning. I propose a change to 

"Design Temperature Difference (DTD) – A constant value that represents the difference between the evaporator coil refrigerant’s Saturation Temperature and the return air dry bulb temperature within normal operating load conditions."

Proposed Change:

"Design Temperature Difference (DTD) – A constant value that represents the difference between the evaporator coil refrigerant’s Saturation Temperature and the supply return air dry bulb temperature within normal operating load conditions."

Comment #4

Page Number: 39
Paragraph / Figure / Table / Note: Table 5
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

Table 5 shows various TD targets depending upon airflow CFM/ton. There are some challenges with this, especially in the less than 375 CFM/ton range which cause many if not most systems set to under 375 CFM/ton in humid climates to continue to operate more closely to the 35 degree TD than 40 

1. Systems are generally set lower than 400 CFM/Ton for the very reason that latent load is high to remove more moisture. An increase in latent removal "holds up" the coil saturation temperature in these conditions therefore keeping the DTD closer to 35 in many cases.  

2. Many systems that are set to under 375 CFM/Ton also have larger evaporator coils, this results in low air velocity over the coil and lower bypasss factor which also causes higher coil saturation temperatures and lower TD / DTD

In summary, while you will see a 40 degree TD on a system set to 350 CFM/ton in dry conditions with a standard sized coil this is actually quite uncommon in huimid climates where that setting would be more likely to encounter especially with a larger "high efficiency" evaporator coil.  

Comment #5

Page Number: 16
Paragraph / Figure / Table / Note: 5.2
Comment Intent: Objection
Comment Type: Technical

Comment:

Duct leakage may be evaluated for other reasons, even if the prerequisites for this section have not been met.  Clarify the intent that duct leakage isn't to be used for HVAC system grading.

Proposed Change:

 

Comment #6

Page Number: 21
Paragraph / Figure / Table / Note: 6.4.2
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

To clarify when the HVAC system must run (before or while the static pressure probe has been inserted), rearrange these sections.  It's likely that the fan would have been running already and not necessary that it run for 10 minutes while holding the static pressure probe in place.

Proposed Change:

Comment #7

Page Number: 9 (and 15)
Paragraph / Figure / Table / Note: 4.2.4.15 (and 4.3.11)
Comment Intent: Objection
Comment Type: Technical

Comment:

In order for 4.3.11 to be applied, the design value given in 4.2.4.15 must be in ACH50.  If each Manual J software is capable of using these units, then require them for this evaluation.

Proposed Change:

4.2.4.15. The infiltration rate of the zone, given in ACH50.

Comment #8

Page Number: 21 / 23 / 25 / 26 / 31 / 31 / 33 / 34 / 36 / 37 / 43
Paragraph / Figure / Table / Note: 6.4.1 / 6.5.1 / 6.6.1 / 6.7.1 / 7.4.1 / 7.5.1 / 7.6.1 / 7.7.1 / 8.3.1 / 8.4.2 / 8.5.1
Comment Intent: Objection
Comment Type: Technical

Comment:

Not all equipment listed in the Equipment Needed secitons can be calibrated.  Additionally, carefully consider if all equipment listed requires calibration for this standard.  Suggestions shown below.

Proposed Change:

 

Comment #9

Page Number: 7
Paragraph / Figure / Table / Note: Section 4 Task 1 Evaluation of the Design
Comment Intent: Not an Objection
Comment Type: General

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

The ENERGY STAR Rater Checklist or a universal checklist should be designed and made public to evaluate the design of the residential building.

Comment #10

Page Number: 16,18, 29, 35
Paragraph / Figure / Table / Note: Section 5.1, Section 6.1, Section 7.1, Section 8.1
Comment Intent: Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

We do not agree with allowing the use of an Independent Verification Report.  The language is quite vague about who would be producing such a report and what methods would be required to generate such a report.  Anyone could produce such a report and the approval authority might not have the ability to guage whether any such report is authentic.  We do not feel this report is necessary.

 

 

Proposed Change:

Remove the definition and any language allowing the use of the Independent Verification Report from Sections 5.1, 6.1, 7.1 and 8.1.

Comment #11

Page Number: 18
Paragraph / Figure / Table / Note: Section 6.1
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

In the second paragraph, the language mentions the on-board diagnostics systems reporting the volumetric airflow.  We feel that the on-baord system will not be giving any reports, but instead will be displaying the value.  We recommend a simple change from reporting to displaying. 

Proposed Change:

As an alternative to completing the procedures defined in Sections 6.4 6.3 through 6.7, if the installed equipment contains an on-board diagnostic system that is capable of reporting displaying the Blower Fan volumetric airflow and that is approved for use by an entity adopting and requiring the use of this Standard, then the reported value shall be permitted to be used. 

Comment #12

Page Number: 18
Paragraph / Figure / Table / Note: Section 6.1
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

Simple change to Section numbering in Section 6.1

Proposed Change:

As an alternative to completing the procedures defined in Sections 6.4 6.3 through 6.7

Comment #13

Page Number: 19-24
Paragraph / Figure / Table / Note: Section 6.2-6.5
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

Simple editorial changes

Proposed Change:

6.2.1. Eligibility- make sure Eligibility is bold

6.2.1.1. If the Forced-Air HVAC System has a total amount of supply ductwork or distribution building cavities that does not exceed 10 ft. in length and is entirely in Conditioned Space Volume, then measurement of the airflow shall not be required be exempted and the volumetric airflow grade shall be designated in accordance with Section 6.8.

6.2.2.1. HVAC equipment. The specified manufacturer(s) and model number(s) of the equipment in the Forced-Air HVAC System under test matches the installed equipment design review / overview section 4.2.5.3 or supplemental documentation has been collected as defined in Section 4.2.5 and verified in accordance with Section 4.3. If the installed equipment does not match the specified equipment in the original or supplemental documentation, then Blower Fan volumetric airflow shall not be evaluated. 

28 (Informative Note) Use of a new clean filter is recommended required to ensure maximum airflow. 

Comment #14

Page Number: Section 6.7 - 6.8
Paragraph / Figure / Table / Note: 26-28
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

Simple Editorial Edits

Proposed Change:

6.7.3.3. A test hole shall be located or created in the return-side of the Forced-Air HVAC system for the placement of the Static Pressure Probe. Moving in the direction of airflow, the return-side hole shall be located after the filter but before the Blower Fan. The hole shall not be in flexible ductwork. If the hole cannot be located or created in the return side, then one of the other airflow test procedures shall be used if airflow is to be measured. 

6.7.3.4.  A test hole shall be located or created in the supply-side of the Forced-Air HVAC System for the placement of the Static Pressure Probe. For Furnaces, moving in the direction of airflow the supply-side hole shall be located after the Furnace but before the evaporator coil, if a coil is present. For Heat Pumps, moving in the direction of airflow the hole shall be located after the fan-coil but before the presence of any other components not accounted for in the OEM Static Pressure Table 42. The hole shall not be in flexible ductwork. If the hole cannot be located or created in the supply side, then one of the other airflow test procedures shall be used if airflow is to be measured. 

6.7.3.13. The supply side and return side holes shall be sealed per 6.7.1.3.

6.8.1. If Grade I total duct leakage has been designated and the Forced-Air HVAC System has a total amount of supply ductwork or distribution building cavities that does not exceed 10 ft. in length and is entirely in Conditioned Space Volume, then Qdev shall equal zero. Otherwise, Qdev, the deviation between the design-specified and field-measured Blower Fan volumetric airflow shall be calculated using Equation 10. 

Comment #15

Page Number: Section 7.3.1
Paragraph / Figure / Table / Note: 30
Comment Intent: Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine. 

Remove Section 7.3.1 in entirety and renumber sections.  The Independent Verification Report should not be allowed.

Proposed Change:

7.3.1. If an Independent Verification Report was used to determine the Blower Fan volumetric airflow, then the procedure to prepare the Dwelling and Forced-Air HVAC System for testing defined in Section 6.3 shall be completed. 

Comment #16

Page Number: 7.3.2
Paragraph / Figure / Table / Note: 30
Comment Intent: Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

We recommend the Ventilation Mode testing be removed as it cannot be used for grading purposes.

Proposed Change:

7.3.2. Settings for HVAC System. If the Forced-Air HVAC System contains an Air Conditioner, then the test shall be conducted in cooling mode. If the Forced-Air HVAC System contains a Heat Pump, then the test shall either be conducted in the mode with the higher design airflow, as reported in Section 4.2.5.5.1, or in both the heating and cooling mode. If the Blower Fan watt draw in Ventilation Mode is being verified, then Section 7.3.2.3 shall be followed. Blower Fan watt draw in Ventilation Mode shall not be used to designate the Blower Fan watt draw grade per Section 7.8.

Comment #17

Page Number: 7.3.2
Paragraph / Figure / Table / Note: 30
Comment Intent: Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

We recommend the Ventilation Mode testing be removed as it cannot be used for grading purposes.

Proposed Change:

7.3.2. Settings for HVAC System. If the Forced-Air HVAC System contains an Air Conditioner, then the test shall be conducted in cooling mode. If the Forced-Air HVAC System contains a Heat Pump, then the test shall either be conducted in the mode with the higher design airflow, as reported in Section 4.2.5.5.1, or in both the heating and cooling mode. If the Blower Fan watt draw in Ventilation Mode is being verified, then Section 7.3.2.3 shall be followed. Blower Fan watt draw in Ventilation Mode shall not be used to designate the Blower Fan watt draw grade per Section 7.8.

Comment #18

Page Number: 7.3.2.3
Paragraph / Figure / Table / Note: 30
Comment Intent: Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

Continuing changes from Comment #17

Ventilation mode should not be allowed here as it cannot be used for grading.

Proposed Change:

7.3.2.3. Ventilation Mode.  

7.3.2.3.1. The thermostat shall be set to Ventilation Mode 51.

51 (Informative Note) Ventilation Mode may be indicated on the thermostat as “Fan-On”. 

Comment #19

Page Number: 7.3.2.3
Paragraph / Figure / Table / Note: 30
Comment Intent: Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

Continuing changes from Comment #17

Ventilation mode should not be allowed here as it cannot be used for grading.

Proposed Change:

7.3.2.3. Ventilation Mode.  

7.3.2.3.1. The thermostat shall be set to Ventilation Mode 51.

51 (Informative Note) Ventilation Mode may be indicated on the thermostat as “Fan-On”. 

Comment #20

Page Number: 31
Paragraph / Figure / Table / Note: 7.4.1
Comment Intent: Not an Objection
Comment Type: General

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

Equipment calibration language should be removed or define procedure as manufacturers probably do not do this. 

Proposed Change:

7.4.1. Equipment Needed. The equipment listed in this section shall have its calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.

Comment #21

Page Number: Section 8.3.2
Paragraph / Figure / Table / Note: 36
Comment Intent: Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

The weigh-in method is reasonable and could be implemented with a good relationship between the rater and the HVAC contractor.  This appears to be the most practical, if the standard could be modified to allow this method to be used under all conditions, not just when the non-invasive method can’t be used.

Also removing the language on Independent Verification Report

Proposed Change:

8.3.2.1. The Weigh-In Method, per Section 8.5, is permitted to be used when the following conditions are met in all conditions

8.3.2.1.1. Outdoor air temperatures do not meet the requirements of the Non-Invasive method in Section 8.3.2.2; or,

8.3.2.1.2. The Forced-Air HVAC System is a Mini-Split Air Conditioner, Mini-Split Heat Pump, Multi-Split Air Conditioner, or a Multi-Split Heat Pump.

8.4.1.1. If an Independent Verification Report was used to determine the Blower Fan volumetric airflow, then the procedure to prepare the Dwelling and Forced-Air HVAC System for testing defined in Section 6.3 shall be completed. 

Comment #22

Page Number: Section 8.5
Paragraph / Figure / Table / Note: 43
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

We feel that a pipe caliper should also be allowed for measuring pipe diameter.

Proposed Change:

8.5.1.1. Measuring Tape. A device that can determine length with an accuracy of ± 1/16 inch (1.6 mm). 

 

8.5.1.2. Pipe Caliper. A measuring device for the purpose of measuring pipe diameter to an accuracy of +- 1/8", either directly or with a conversion scale printed on the device.

Comment #23

Page Number: 44
Paragraph / Figure / Table / Note: Section 8.5.3
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

Adding a new section for using pipe caliper for circumference of liquid line.

Proposed Change:

8.5.3.2. Using the Measuring Tape, the circumference of the liquid line shall be measured to the nearest 1/16th of an inch (1.6 mm) and divided by 3.14 to calculate the outer diameter, and recorded. 

 

8.5.3.3 Using the Pipe caliper, the diameter of the liquid line shall be measured to the nearest 1/8" and recorded.

Renumber sections 8.5.3.3 through 8.5.3.7

Comment #24

Page Number: 44
Paragraph / Figure / Table / Note: Section 8.5.3
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

Adding a new section for using pipe caliper for circumference of liquid line.

Proposed Change:

8.5.3.2. Using the Measuring Tape, the circumference of the liquid line shall be measured to the nearest 1/16th of an inch (1.6 mm) and divided by 3.14 to calculate the outer diameter, and recorded. 

 

8.5.3.3 Using the Pipe caliper, the diameter of the liquid line shall be measured to the nearest 1/8" and recorded.

Renumber sections 8.5.3.3 through 8.5.3.7

Comment #25

Page Number: 45
Paragraph / Figure / Table / Note: Section 8.6.1
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.

Referencing another standard for establishing the grade is logistically problematic.  The deviations from ACCA Standard 5 need to be listed here.

Proposed Change:

8.6.1. If the superheat or subcooling of the Forced-Air HVAC System under test was reported using an on-board diagnostic system or through an Independent Verification Report, then Grade I shall be designated if the superheat or subcooling deviation is within the limits specified within ANSI/ACCA QI 5 Section 4.3.1.+/- 3F for subcooling and +/- 5F for superheat.

Comment #26

Page Number: 1
Comment Intent: Not an Objection
Comment Type: General

Comment:

Consumers Energy works with Michigan residential builders to build energy efficient homes. 

This comment is in support of the proposed Standard BSR/RESNET/ACCA Standard 310-201x on behalf of the collective interests of the stakeholders identified below: 

• CLEAResult
• Consumers Energy New Home Construction Program
• Great Lakes Home Performance
• Habitat for Humanity of Michigan
• Mayberry Homes, LLC

Standard 310 is incorporated in the EPA ENERGY STAR Certified Homes program checklist. We understand that EPA is contemplating a revision to the ENERGY STAR checklist (Rev 10) which will allow an alternate path for meeting HVAC contractor requirements, upon approval of Standard 310-201x.  Proposed Standard BSR/RESNET/ACCA Standard 310-201x  would allow HVAC contractors who do not hold an ACCA or Advanced Energy certification to provide HVAC services for ENERGY STAR certified homes by the proposed methodology for evaluating the installation quality of HVAC systems (5 tasks).

Proposed Standard 310-201x is anticipated to provide an alternative path to meeting ENERGY STAR’s HVAC requirements and will lead to more ENERGY STAR homes in Michigan.   

Comment #27

Page Number: 27
Paragraph / Figure / Table / Note: 6.7.3.10
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

For improved clarity, consider replacing Equation 8 with a lookup table that shows padj at specified elevations.

 

Proposed Change:

For improved clarity, consider replacing Equation 8 with a lookup table that shows padj at specified elevations.

 

Comment #28

Page Number: 9, 21, 23, 26
Paragraph / Figure / Table / Note: 4.2.4.3, 6.4.1.4, 6.5.1.4, 6.7.1.3
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

The term Authority Having Jurisdiction, used four times in the standard, is capitalized but not defined. Consider adding a definition for this term, or substituting in an alternative term, such as Building Official, based upon the definition in the 2018 IRC: “Building Official. The officer or other designated authority charged with administration of this code, or a duly authorized representative. “

 

Comment #29

Page Number: 22
Paragraph / Figure / Table / Note: 6.4.2.5.1
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

Section 6.4.2.5.1, for measuring Blower Fan Volumetric Airflow with the Pressure Matching, states that “If the Fan Flowmeter is to be connected to the blower compartment outside the Conditioned Space Volume, then the door or access panel between the Conditioned Space Volume and the blower compartment location shall be opened.”

This language is unclear on how doors should be configured for a situation typical in a multifamily building where the mechanical closet serving one or more dwelling units is only accessible from the corridor. If the mechanical closet is small the fan flowmeter may have to be located outside of it (in the corridor) during the test and would also then be outside of the Conditioned Space Volume. This language should be modified to provide clear guidance on how doors should be configured for this situation.

Additionally Section 6.4.2.5.1 states “… and an air barrier inserted between the return duct system and the Blower Fan inlet to ensure that no air enters the blower compartment from the return duct system.” The phrase “no air enters” should be revised because it would be practical to seal so to minimize the amount of air that enters the blower compartment, but it may be impossible for “no” air to enter the blower compartment.

Proposed Change:

Section 6.4.2.5.1

Method 1 Installation: At the Blower Compartment. The Blower Fan shall be turned off, the blower access panel removed, and an air barrier temporarily inserted between the return duct system and the Blower Fan inlet to minimize the amount of air entering ensure that no air enters the blower compartment from the return duct system during the test. The Fan Flowmeter shall be attached to the blower compartment access, with the connection between the Fan Flowmeter and blower compartment temporarily sealed. If the Fan Flowmeter is to be connected to the blower compartment outside the Conditioned Space Volume, then the door or access panel between the Conditioned Space Volume and the blower compartment location will pull air from outside the Conditioned Space Volume during the test, then doors or access panels between the Conditioned Space Volume and the Fan Flowmeter inlet shall be opened. The Blower Fan shall then be turned back on.

Comment #30

Page Number: 1 – 111
Paragraph / Figure / Table / Note: Appendix A Table A-1
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

Currently, the design temperature limits in Appendix A reference the ASHRAE 2013 Handbook of Fundamentals and the Manual J Design Conditions 8^th Edition. ASHRAE has since updated its design temperature limits in the ASHRAE 2017 Handbook of Fundamentals with new weather stations and some temperature updates for existing weather stations. Table A-1 in Appendix A should be updated such that the limits are selected from the ASHRAE 2017 Handbook of Fundamentals and the Manual J Design Conditions 8^th Edition.

In addition, the logic used to select the design temperature limits should be updated to always account for weather stations that are adjacent to the county. For a home on the edge of a county, the closest weather station may be located in the next county over, rather than located within the county.

Table A-1’s values should be updated to select design temperature limits from the ASHRAE 2017 Handbook of Fundamentals and the Manual J Design Conditions 8^th Edition, using the following logic:

• If any weather stations are located within the county OR within a 40 mile radius from the county’s geographic center, the highest cooling and lowest heating design temperatures from the values of these weather stations will be assigned to the county.
• If no weather stations are located within the county OR within a 40 mile radius from the county’s geographic center, the cooling and heating design temperatures of the nearest three weather stations will be averaged and assigned to the county.

This logic more accurately considers the weather stations that can be reasonably be assigned to a county; furthermore, it provides more balanced values by averaging three stations whenever no station is nearby, rather than choosing the closest station as the current logic does.

Proposed Change:

Appendix A (Normative) -Design Temperature Limits by State and County, and U.S. Territory

The temperatures in this Appendix utilize the 1% cooling and 99% heating design temperatures in the ASHRAE 20132017 Handbook of Fundamentals and Manual J Design Conditions 8th Edition. In Table A-1, design values have been defined for individual counties and territories using the following logic:

• One or multiple weather stations within the county or territory, OR within a 40 mile radius from the county or territory’s geographic center. The highest cooling and lowest heating design temperatures from the values of these weather stations were assigned to the entire county or territory.
• No weather stations within the county or territory, OR within a 40 mile radius from the county or territory’s geographic center. The cooling and heating design temperatures of the nearest three weather stations were averaged and assigned to the entire county or territory.
• One weather station within the county or territory. If only one weather station was present within the county’s or territory’s boundaries, then the cooling and heating design temperatures for that weather station were assigned to the entire county or territory.
• Multiple weather stations within the county or territory. If more than one weather station was present within the county’s or territory’s boundary, then the highest cooling and lowest heating design temperatures among the weather stations in the county or territory were assigned to the entire county or territory.
• No weather stations within the county (This condition did not arise in territories). If no weather stations were present within the county’s boundary, then the cooling and heating design temperatures for the closest weather station were assigned to the entire county. To determine the closest weather station, only the weather stations assigned to other counties were considered. The closest station was determined by assessing the distance between the geographic center of the county and the location of the applicable weather stations.

Table A-1 should be updated to reflect new data according to the above logic.

Comment #31

Page Number: 15
Paragraph / Figure / Table / Note: 4.3.11
Comment Intent: Not an Objection
Comment Type: General

Comment:

This section requires that the infiltration rate of the Dwelling to be rated be within ± 2.0 ACH50 of the value used in the loads for each zone, as documented in Section 4.2.4.15. In instances where a designer has used a qualitative input for infiltration (i.e., Tight, Average, or Leaky per ACCA Manual J) guidance is needed on what infiltration range is acceptable for each qualitative input.

ACCA Manual J Table 5A provides a default air change value in natural air changes per hour for each qualitative input based on house size. One value is provided for cooling mode, which assumes a 20F difference between inside and outside conditions, and for heating mode, which assumes a 70F difference.

These default natural air change values equate to a range of infiltration values using the ACH50 metric, depending on the building’s height, shielding, leakiness, and location. See: https://escholarship.org/content/qt7n25v6kd/qt7n25v6kd.pdf. By evaluating the default natural air change values for homes between 1,500 and 3,000 square feet, in cooling mode, which is more representative of test conditions during HERS/ERI ratings, for 1 and 2-story homes in multiple geographic locations, and assuming a shielding and leakiness correction factor of 1.0, the following equivalent ACH50 ranges are found:

Qualitative Infiltration	Cooling nACH	ACH50 Eq. Min	ACH50 Eq. Max	Proposed Allowable Range (ACH50)
Tight	0.10	1.2	2.5	0-4.0
Semi-Tight	0.18-0.20	2.2	4.9	1.0-5.0
Average	0.25-0.30	3.1	7.4	3.0-7.0
Semi-Leaky	0.43-0.53	5.3	13.0	7.0-11.0
Leaky	0.60-0.75	7.4	18.4	>11.0

The proposed allowable ranges use the same ±2 ACH50 tolerance and create continuous ranges that roughly approximates the values equivalent to the natural air change values.

 

Proposed Change:

If the infiltration design value is quantitative, then tThe infiltration rate of the Dwelling to be rated is within ± 2.0 ACH50 of the value used in the loads for each zone, as documented in Section 4.2.4.15. If the infiltration design value is qualitative, then the infiltration rate of the Dwelling to be rated is within the tolerance specified in Table 1 for the qualitative cooling infiltration input used in the design.

Table 1 – Infiltration Tolerance of Dwelling to Be Rated

Qualitative Cooling  Infiltration Input  Used in Design	Infiltration Tolerance of Dwelling to be Rated  (ACH50)
Tight	0-4.0
Semi-Tight	1.0-5.0
Average	3.0-7.0
Semi-Leaky	7.0-11.0
Leaky	>11.0

 

Comment #32

Page Number: 5
Paragraph / Figure / Table / Note: Definitions
Comment Intent: Not an Objection
Comment Type: General

Comment:

The definitions for Mini-Split Air Conditioner, Mini-Split Heat Pump, Multi-Split Air Conditioner, and Multi-Split Heat Pump can be better aligned with the AHRI definition for Variable Refrigerant Flow (VRF) Multi-Split Air Conditioning and Heat Pump Equipment for improved clarity.

The definition is located here: http://www.ahrinet.org/Certification/AHRI-Certification-Programs/Variable-Refrigerant-Flow-VRF-Multi-Split-Air-Conditioning-and-Heat-Pump-Equipment

This will not change the overall intent of the definitions but reduce unnecessary differences in industry terms.

 

Proposed Change:

Mini-Split Air Conditioner (MNAC) – An Air Conditioner that has variable refrigerant flow and distributed refrigerant technology with a single outdoor section unit serving a single indoor section unit. The outdoor unit contains a single compressor or multiple compressors or a variable capacity compressor. The indoor section unit has a coil, an air movement device [1] intended for single zone air distribution, and a temperature sensing control is typically, but not exclusively, mounted on walls and designed to condition air either directly or through limited duct runs, though duct length is not a determinant for meeting this definition. The units are matched with a zone temperature control device.

Mini-Split Heat Pump (MNHP) – A Heat Pump that has variable refrigerant flow and distributed refrigerant technology with a single outdoor section unit serving a single indoor section unit. The outdoor unit contains a single compressor or multiple compressors or a variable capacity compressor.  The indoor section unit has a coil, an air movement device ¹intended for single zone air distribution, and a temperature sensing control is typically, but not exclusively, mounted on walls and designed to condition air either directly or through limited duct runs, though duct length is not a determinant for meeting this definition. The units are matched with a zone temperature control device.

Multi-Split Air Conditioner (MTAC) – An Air Conditioner that has variable refrigerant flow and distributed refrigerant technology with the capability of serving multiple indoor section units with a single outdoor section unit. The outdoor unit contains a single compressor or multiple compressors or a variable capacity compressor. The Each indoor section unit has a coil, an air movement device ¹intended for single zone air distribution, and a temperature sensing control are typically, but not exclusively, mounted on room walls and designed to condition air either directly or through limited duct runs, though duct length is not a determinant meeting this definition. The units are matched with a zone temperature control device.

Multi-Split Heat Pump (MTHP) – A Heat Pump that has variable refrigerant flow and distributed refrigerant technology with the capability of serving multiple indoor section units with a single outdoor section unit. The outdoor unit contains a single compressor or multiple compressors or a variable capacity compressor. The Each indoor section unit has a coil, an air movement device ¹intended for single zone air distribution, and a temperature sensing control are typically, but not exclusively, mounted on room walls and designed to condition air either directly or through limited duct runs, though duct length is not a determinant meeting this definition. The units are matched with a zone temperature control device.

 

 

Comment #33

Page Number: Multiple
Paragraph / Figure / Table / Note: Multiple
Comment Intent: Objection
Comment Type: General

Comment:

It is proposed that the term “to be rated” be stricken.  Section  4.2. makes it clear that this information pertains to the dwelling to be rated (Required Design Information. The following design information shall be collected by the person completing the evaluation for the Dwelling to be rated.).  (Emphasis mine.) 

To repeat it incessantly is taxing.  

 

Proposed Change:

8

4.2.4.

Obj.

Gen.

Heat gain and heat loss loads for each heated or cooled zone in the Dwelling to be rated, consisting of the following:

 

Comment #34

Page Number: 9
Paragraph / Figure / Table / Note: 4.2.4.7.
Comment Intent: Objection
Comment Type: General

Comment:

The use of the term “in the zone” or “of the zone” should be stricken.  The fact that the requirements in Section 4.2.4.7 – 4.2.4.19 apply to “the zone” is clearly defined in Section  4.2.4. Heat gain and heat loss loads for each heated or cooled zone in the Dwelling to be rated, consisting of the following. (Emphasis mine.)  The repetition of these terms (in the zone, of the zone) does not add value. 

Proposed Change:

The number of occupants in the zone.

Comment #35

Page Number: Multiple
Paragraph / Figure / Table / Note: Multiple
Comment Intent: Objection
Comment Type: Editorial

Comment:

Pg	Section	Intent	Type	Edit
1	1	Obj.	Ed.	Purpose. This standard establishes the procedures, tolerances, and record keeping required to evaluate elements of an HVAC System’s design and installation to the ANSI/ACCA 5 – 2015 (HVAC Quality Installation Specification).
The NWI that was submitted for this project intended this standard to use elements from the ACCA QI 5 Standard as the basis to evaluate a system installation.  Throughout the standard, there are references to tolerances from the QI 5.  Therefore, the purpose statement needs a small revision to reference the QI standard.
7	4.2.2	Not Obj.	Ed.	HVAC design overview basis, consisting of the following:
In this section, the information required is the building plan(s), the two-dimensional model of the dwelling that is the basis for the heat loss/gain calculations, ventilation needs, and duct design.  It is not an overview.
8	4.2.3.2	Obj.	Ed.	The specified system type: supply, exhaust, balanced without recovery, ERV, or HRV, or ventilation dehumidifier.
Strengthens section with an additional equipment type that is used in dwellings.
8	4.2.3.4	Obj.	Ed.	For central ventilation systems serving Dwelling Units or Sleeping Units not within a that set outside the Dwelling or Townhouse:
Provides alternative verbiage that should improve clarity and comprehension.  Replaces the negative reference with a positive substitute.
9	4.2.4.17.	Obj.	Ed.	4.2.4.17. The calculated sensible, latent, and total heat gain at design conditions.  for one or more orientations for the zone. 4.2.4.18. For HVAC designs with heat gain loads for multiple orientations for the zone, Tthe difference between the maximum and minimum total heat gain at design conditions across the orientations specified in Section 4.2.4.17.
Section 4.2.4.18. needs to be called out as an additional requirement for special circumstances.  Many HVAC system designs are for one-off or custom homes therefore, they can stop at Section 4.2.4.17.  Only the HVAC system designers that serve developers who build the same home on multiple lots, with multiple orientations, need to be aware of this.  This edit seeks to provide clarity.
10	4.2.5.3.3.	Obj.	Ed.	The AHRI Reference Number of the equipment. Exception:  or iIf an AHRI Reference Number is not available, OEM-provided documentation shall be collected with the rated efficiency of the equipment. If the equipment contains multiple components, the rated efficiency shall reflect the specific combination of indoor and outdoor components, along with confirmation from the OEM that the two components are designed to be used together.
AHRI Reference numbers are common.  However, as sometimes happens they are not available, then an exception needs to be provided, as it is done here.  This edit seeks to retain the simplest most common solution (the AHRI Reference number)… and in the event there is not one, then the exception provides Plan B.
12	4.2.5.4.	Obj.	Ed.	The specified performance rating and metric 17 of the each filter, if one or more will to be installed.
Simplifies the language.
12	4.2.5.5.	Not Obj.	Ed.	A dDuct system design elements overview, if a duct system will be installed, consisting of provide the following:
Seeks to add clarity as this section requires elements of the duct design be documented.  Also, to ensure the required data is provided.
13	4.3.1.	Obj.	Ed.	If a Dwelling or Townhouse, or Dwelling Unit or Sleeping Unit within, is to be rated, then the following criteria data shall be met in addition to present, and verified to comply with the following criteria in Section 4.3.4:
Section 4.3.1 and 4.3.4 address different elements of the HVAC design review.  They should be merged for simplicity and consolidated into one section.  Sections 4.3.2 and 4.3.3 can then address the special multi-family cases and capacity tolerances.
13	4.3.1.7.	Obj.	Ed.	The heating and cooling loads have been calculated room-by-room, as documented in Section 4.2.4.2.3..4
If a previous comment was accepted regarding the revision of Section 4.2.4.4. was accepted, this aligns the reference in the standard.
13	4.3.1.7.	Obj.	Ed.	The heating and cooling loads have been calculated room-by-room for dwellings or townhouses, or as room-by-room or block load for Dwelling Unit or Sleeping Unit not within a Dwelling or Townhouse as documented in Section 4.2.4.4.
If previous comment was not accepted, this proposed alternative addresses the need for heat loss/gain calculations for dwellings… and for mult-family buildings.
16	4.3.15. - 4.3.17.	Obj.	Ed.	4.3.15. For Air Conditioner and Heat Pump equipment, the Cooling Sizing Percentage, calculated using Equation 2, matches the Cooling Sizing Percentage value reported in Section 4.2.5.3.12. 4.3.16. For Boiler and Furnace equipment, the Heating Sizing Percentage, calculated using Equation 4, matches the Heating Sizing Percentage value reported in Section 4.2.5.3.20. 4.3.17. For Heat Pump equipment, if Climate Condition B is reported in Section 4.2.5.3.13, then the Sensible Heat Ratio, calculated using Equation 3, is ≥ 95% and the HDD65/CDD50 Ratio, as determined using Appendix A for the county and state, or U.S. territory, reported in Section 4.2.4.6 is ≥ 2.0.
This standard should align with other RESNET, ACCA, ICC, and IAPMO standards.  A great deal of information about equipment capacity is collected for seemingly no purpose: §4.2.5.3.11, §4.2.5.3.15. - §4.2.5.3.21, and 4.3.15 – 4.3.17. If this standard does not adopt the previous edit, it needs to strike the sections that unnecessarily collect data.  It is recommended that the standard align with other RESNET, ACCA, and ICC codes.
19	6.2	Obj.	Ed.	6.2. Prerequisites. Prior to evaluating the Blower Fan volumetric airflow, all the following requirements shall have been met. 6.2.1. If the total duct leakage has been designated Grade III, then Blower Fan volumetric airflow shall not be evaluated. (Section 6.2.1.4. relocated here.) 6.2.2 1. The total duct leakage shall have be Grade I or Grade II per section 5.0. en evaluated in accordance with Section 5, including all prerequisites in Section 5.2. The test procedure used to evaluate the airflow shall be selected according to Sections 6.2.1.1 through 6.2.1.4. 6.2.3. The test procedure used to evaluate the airflow shall be selected according to Sections 6.2.1.1 through 6.2.1.3 4. 6.2.1.1. If the Forced-Air HVAC System has a total amount of supply ductwork or distribution building cavities that does not exceed 10 ft. in length and is entirely in Conditioned Space Volume, then measurement of the airflow shall not be required, and the volumetric airflow grade shall be designated in accordance with Section 6.8. 6.2.1.2. If the Forced-Air HVAC System does not meet the conditions in Section 6.2.1.1 and the total duct leakage has been designated Grade I, the airflow is permitted to be measured using the Pressure Matching Method (Section 6.4), a Flow Grid (Section 6.5), a Flow Hood (Section 6.6), or the OEM Static Pressure Table Method (Section 6.7) 26. 6.2.1.3. If the total duct leakage has been designated Grade II, the airflow is permitted to be measured using the Pressure Matching Method with Method 1 Installation (Section 6.4), a Flow Grid (Section 6.5), or the OEM Static Pressure Table Method (Section 6.7). 6.2.1.4. If the total duct leakage has been designated Grade III, then Blower Fan volumetric airflow shall not be evaluated.
If Section 5.0 is retained, this revision simplifies and improves comprehension.
19	6.2.2.	Obj.	Ed.	Verification of HVAC Components. If tThe specified following components are included identified in the design of the Forced-Air HVAC System under test, they shall be verified to be present. If these components have not yet been installed, then the test shall not be conducted. The additional requirements defined in Section 6.2.2.1 shall also be met.
Streamlines the requirement and removes redundancy (last sentence).
20	6.3.1	Obj.	Ed.	6.3.1. Position of Dampers. Dampers within the duct system of the Forced-Air HVAC System under test shall be treated as follows: 6.3.1.1. Ventilation Dampers 6.3.1.1.1 Non-motorized dampers 29 that connect the Conditioned Space Volume 30 to the exterior or to Unconditioned Space Volume shall be left in their as-found positions. 6.3.1.1.2. Motorized dampers that connect the Conditioned Space Volume 30 to the exterior or to Unconditioned Space Volume shall be placed in their closed positions and shall not be further sealed. 6.3.1.2 3. Balancing dampers shall be left in their as-found position.
Proposed text seeks to add clarity and improve understanding.
20	6.3.3.	Obj.	Ed.	Ventilation Openings. Non-dampered Ventilation openings within the duct system of intermittently or continuously operating Dwelling-Unit Mechanical Ventilation Systems, including Ventilation systems that use the Blower Fan of the Forced-Air HVAC System, shall not be sealed.
Is there another type of ventilation operation?  It is either continuous or intermittent.  You are either pregnant, or you’re not, right?  This edit removes unnecessary words.
20	6.3.4.1.	Obj.	Ed.	Any Other than the forced-air HVAC system fan, all fans 31 that serve the dwelling could change the pressure in either the Conditioned Space Volume or, if present, an Unconditioned Space Volume containing the Forced-Air HVAC System under test, shall be turned off.
This is unnecessarily verbose.
21	6.3.5.1.3	Obj.	Ed.	6.3.5.1.3. If the Forced-Air HVAC System serves multiple zones, as reported in Section 4.2.5.2, then manufacturer instructions shall be followed to ensure that all zones in the Forced-Air HVAC System are set calling for the cooling required mode and set point for testing.
This section is headed “Cooling Mode”, added language to align terms.
21	6.3.5.2.2.	Obj.	Ed.	6.3.5.2.2. If the Forced-Air HVAC System serves multiple zones, as reported in Section 4.2.5.2, then manufacturer instructions shall be followed to ensure that all zones in the Forced-Air HVAC System are set calling for the heating required mode and set point for testing.
Ditto
23	6.4.2.10.	Obj.	Ed.	If the procedure to measure Blower Fan watt draw in Section 7 or to evaluate refrigerant charge in Section 8 will not be conducted, then power to the compressor shall be restored, if cut off for the test, and the thermostat(s) mode(s) and set point(s) shall be returned to their original setting.
Off and cut off are synonymous.
25	6.6.2.1.	Obj.	Ed.	The Forced-Air HVAC System shall run for 10 minutes continuously, after which the following procedure shall be completed for each return grille in the Forced-Air HVAC System:
To support duplicative test results, this requirement needs to be removed.  In humid climates, if the HVAC professional tests on a humid day, and the rater tests on an arid day, the test results could be marginally different.  In humid climates it is best to test in the cooling mode with a wet coil… but for a standardized procedure, that seeks to provide symmetrical results winter/summer, humid/arid… the 10 minute run time is unnecessary.
26	6.7.2.1.	Obj.	Ed.	The OEM Static Pressure Table shall be obtained and verified to match the manufacturer, model number(s), for the equipment tested and configuration of the installed equipment 40.
Edit seek to simplify the text and retain the intent.
28	6.8.1.	Obj.	Ed.	If Grade I total duct leakage has been designated and the Forced-Air HVAC Systems 10 ft has a total amount of supply ductwork or distribution building cavities that does not exceed 10 ft. in length and is entirely in Conditioned Space Volume, then Qdev shall equal zero. Otherwise, Qdev, the deviation between the design-specified and fieldmeasured Blower Fan volumetric airflow shall be calculated using Equation 10.   Exception: HVAC Systems that have supply ductwork or distribution building cavities ≤ 10 ft. in length and is entirely in Conditioned Space Volume, then Qdev shall equal zero.
Simplification of text.
31	7.4.2.5.	Obj.	Ed.	If the procedure to evaluate refrigerant charge in Section 8 will not be conducted, then power to the compressor shall be restored, if applicable cut off for the test, and the thermostat(s) mode(s) and set point(s) shall be returned to their original setting.
Adds professionalism to the text.
31	7.5.2.1.	Obj.	Gen.	This procedure shall be performed by parties with the proper training and using appropriate safety equipment. The Clamp-On Watt Meter manufacturer’s operating instructions and safety instructions shall be followed.
The advice to follow OEM instructions and safety instructions is good advice.  It should be repeated everywhere… or place in a general requirement (for simplicity).
32	7.5.2.2.	Obj.	Ed.	7.5.2.2. The Blower Fan watt draw shall be measured at one of the following locations.  If neither location is available, then a different procedure shall be selected. 7.5.2.2.1. At the Service Disconnect. If a service disconnect to the equipment with the Blower Fan is available, the service disconnect panel shall be opened. 7.5.2.2.2. At the Forced-Air HVAC System. This location is permitted to be used if an access panel(s) provides access to the electrical supply wiring, and the Blower Fan compartment remains closed. If this location is used, the access panel shall be removed 53. If the Blower Fan is not capable of operating with the access panels removed, then a different procedure shall be selected if Blower Fan watt draw is to be measured. 7.5.2.3. The Forced-Air HVAC System shall run for 10 minutes continuously before completing Section 7.5.2.4 and beyond. The 10-minute period is permitted to include the time the Forced-Air HVAC System was running while conducting the procedure for evaluating the Blower Fan volumetric airflow in Section 6. If the Blower Fan is not capable of operating with the access panels removed, then a different procedure shall be selected if Blower Fan watt draw is to be measured.
There are no instructions to remove the blower panel… why tell the user to remove the disconnect cover.  This level of instruction seems unnecessary. Language from 7.5.2.3. was relocated to 7.5.2.2.2., where it seems to be more apt.
32	7.5.2.4.2.1.	Obj.	Ed.	The clamp of the Clamp-On Watt Meter shall be placed around L1 or L2 the first of two wires 57 supplying power to the equipment with the Blower Fan.
Industry terms should be used, those not familiar should use another procedure or learn the correct terms.
35	8.2.1.	Obj.	Ed.	Prior to evaluating the refrigerant charge, the Blower Fan volumetric airflow shall have been designated Grade I or II, per Section 6.8 evaluated in accordance with Section 6, including all prerequisites in Section 6.2. In addition, the Blower Fan volumetric airflow shall have been designated Grade I or II, per Section 6.8. If the Blower Fan volumetric airflow has…
Edit seeks to simplify the requirement by relocated the statement “designated Grade I or II, per Section 6.8”.
38	8.4.3.	Obj.	Ed.	8.4.3. Procedure to Evaluate the Refrigerant Charge. 8.4.3.1. Before proceeding past Section 8.4.3.5, the Forced-Air HVAC System shall run for 15 minutes continuously 64. 8.4.3.2. The location for measuring the return air temperature shall be determined as follows: 8.4.3.2.1. If a The hole shall be located in the return side of the Forced-Air HVAC System and is out of line of sight of the evaporator coil 65, then the hole shall qualify for use in this procedure, or 8.4.3.2.2. If a hole does not qualify per Section 8.4.3.2.1, then tThe location shall be where the indoor air stream enters the return grille closest to the Forced-Air HVAC System. 8.4.3.3. Using the Digital Thermometer, Measure and record the average return air dry bulb temperature (T return air, db), and average return air wet-bulb temperature shall be measured over.  The lapsed time shall be at least a 10-seconds period at the location determined in Section 8.4.3.2 and recorded.  8.4.3.4. If the temperatures were measured using a hole, then the hole shall be sealed to prevent leakage after measurements have been completed.
Edits remove unnecessary language, adds a new section (8.4.3.4.) to improve clarity.
44	8.5.3.2.	Obj.	Ed.	8.5.3.4 2. Using the Measuring Tape, the circumference of the liquid line shall be measured to the nearest 1/16th of an inch (1.6 mm) and divided by 3.14 to calculate the outer diameter, and recorded.
This section interrupts the flow of measuring the line set length, and needs to be inserted after 8.5.3.3.

 

Proposed Change:

See table above... page number and section are specified.

Comment #36

Page Number: 31
Paragraph / Figure / Table / Note: 7.5.2.1.
Comment Intent: Objection
Comment Type: General

Comment:

The advice to follow OEM instructions and safety instructions is good advice.  It should be repeated everywhere… or place in a general requirement (for simplicity).

Proposed Change:

This procedure shall be performed by parties with the proper training and using appropriate safety equipment. The Clamp-On Watt Meter manufacturer’s operating instructions and safety instructions shall be followed.

No change, provided for reference.

Comment #37

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

Comment:

Pg	Section	Intent	Type	Edit
8	4.2.4.	Obj.	Tech.	Heat gain and heat loss loads for each heated or cooled zone in the Dwelling11 to be rated, consisting of the following: New Normative Footnote (or requirement): Heat gain/loss loads for Dwelling/Townhouse shall be room-by-room.
9	4.2.4.4.	Obj.	Tech.	4.2.4.4  4.2.4.2.3  Whether the loads for the zone were calculated room-by-room or as a single block.
It is accepted that heat loss/gain load calculations for dwellings should be performed room-by-room.  For small dwellings or sleeping units (especially in multi-family buildings) it is understood that the unit with the largest heat loss/gain may serve as the basis for all other units in the building.  It is also understood that for some small sleeping units with one exposure that a block load is acceptable.   Therefore, this proposed edit seeks to acknowledge those allowances, but ensure there is clarity about the requirement for room-by-room calculations for “larger” dwellings/townhouses.  In addition to the new footnote (or additional requirement), it is advised that Section 4.2.4.4 be relocated and be made a sub-section to 4.2.4.2 (multifamily building) requirements.  This is so that it is clear that this option only applies to this building type.
9	4.2.4.6.	Obj.	Tech.	The outdoor heating design temperature and outdoor cooling design temperature used. If located in the United States, then also the Manual J location12 (city and state) county and state, or U.S. territory, that the design was completed for. New Informative Footnote: Or ASHRAE HOF location, or location per the AHJ.
The HVAC System Designer selects the Manual J (or other) location in the design software.  It is incumbent upon the Rater (or other) in Section 4.3 (Evaluation) to determine if the design conditions match Manual J (or other)… or if the conditions fall within the tolerances specified in the appendix.  To place this additional burden on the HVAC system designer is inappropriate.
11	4.2.5.3.10.	Obj.	Tech.	If the equipment type is an Air Conditioner or Heat Pump, then the equipment’s rated cooling efficiency 15.
It is not understood why this information is collected. It is understood that IF the refrigerant charge is verified and if Section 8.4.3.9 is invoked then this information would be necessary.  However, if this procedure is not used, why is this data collected?  If needed for that procedure, then relocate to Section 8.4.3.9. Is this information not already a minimum rated feature?  It is unclear why is this data required again?  This requirement needs to be deleted.
11	4.2.5.3.11.	Obj.	Tech.	4.2.5.3.11. If the equipment type is an Air Conditioner or Heat Pump, then the latent, sensible, and total cooling capacity of the equipment at design conditions, from OEM expanded performance data. 4.2.5.3.12. If the equipment type is an Air Conditioner or Heat Pump, then the Cooling Sizing Percentage, calculated using Equation 2: 5998".* :";".* 4$(7$./)*$ = !9/)8 5998".* 5)<)7"/6 !9/)8 =$)/ >)". (2) Where: Total Cooling Capacity = The total cooling capacity of the specified equipment at design conditions, as reported in Section 4.2.5.3.11. Total Heat Gain = The maximum total heat gain among the specified orientations reported in Section 4.2.4.17. 4.2.5.3.13. If the equipment type is a Heat Pump, then the Climate Condition, either A or B. 4.2.5.3.14. If a Condition B Climate is reported in Section 4.2.5.3.13, then the Sensible Heat Ratio shall be calculated and reported using Equation 3: :$.?"@8$ =$)/ 0)/"9 = :$.?"@8$ 5998".* A9)+ !9/)8 5998".* A9)+ (3) Where: Sensible Cooling Load = The sensible cooling load of the maximum total cooling load among the specified orientations reported in Section 4.2.4.17. Total Cooling Load = The maximum total cooling load among the specified orientations reported in Section 4.2.4.17. 4.2.5.3.15. If a Condition B Climate is reported in Section 4.2.5.3.13 and the Dwelling to be rated is located in the United States, then the HDD65/CDD50 Ratio, as determined using Appendix A for the county and state, or U.S. territory, reported in Section 4.2.4.6. 4.2.5.3.16. If the equipment type is a Boiler, Furnace, or Heat Pump, then the equipment’s rated heating efficiency. 4.2.5.3.17. If the equipment type is a Boiler or Furnace, then the heating capacity type: single-stage, two-stage, or modulating.
This standard should align with other RESNET standards, ACCA standards, and the model building code.  A great deal of information about equipment capacity is collected for seemingly no purpose: §4.2.5.3.11. - §4.2.5.3.21.  If this standard does not align with ACCA Manual S then strike the sections that unnecessarily collect related data.  It is recommended that the standard align with other RESNET, ACCA, ICC, and IAPMO codes.
13	4.3.	Obj.	Tech.	Evaluation of Design Information. The design documentation collected in Section 4.2 shall be reviewed to verify that all required information has been provided. In addition, the Dwelling to be rated21 shall be compared to verify the design documentation to verify that ensure the following criteria have been met.   As an alternative to design information evaluation per Section 4.3, an Independent Verification Report approved for use by an entity adopting and requiring the use of this Standard shall be accepted as compliance to this prerequisite.  The Independent Verification Report shall verify that criteria for the HVAC design are met.
Initially, this requirement was to compare elements of the heat loss/gain calculations (modeled in software) with those on the Architectural plan.  This evolved into a requirement to compare the constructed dwelling with the architectural plan.  This requirement to compare the constructed dwelling to the architectural plan needs to remain with the code official.  This requirement should be struck.   Section 4.0 is the only one that requires completion by a Rater.  This is a restrictive requirement that should be open to an independent review process that is approved by the entity that adopts the standard.
15	4.3.7.	Obj.	Tech.	The number of occupants in the Dwelling to be rated, which shall be calculated using Equation 5, are within ±1 2 of the sum of the occupants used in the loads across all zones, as documented in Section 4.2.4.7.
A tolerance of one extra body in the heat loss/gain calculations is too much, but may be acceptable.  It is feared that any tolerance will be used as the norm, and there will be attempts to push the boundary even further.  Additionally, this is not a complex mathematical formula, therefore a tighter tolerance is preferred.
16	4.3.14.	Obj.	Tech.	Each HVAC System in the Dwelling to be rated matches the equipment model type specified in Section 4.2.5.3.2 1.
To confirm only the equipment type proves almost useless. Because equipment capacity varies from model to model, it is the data point that must be verified.  This aligns with Section 6.2.2.1.
16	4.3.15. - 4.3.17.	Obj.	Tech.	4.3.15. Equipment capacity shall meet the sizing tolerances in ACCA Manual S or per Table X.     Table X: Equipment Sizing Limits Equipment Type Climate Condition Compressor Type Single-Speed Two-Speed Variable-Speed Cooling-Only A or B 90% – 115% 90% – 120% 90% – 130% Heat Pump A Heat Pump B 90% - 100%, plus 15 kBtuh 90% - 100%, plus 15 kBtuh 90% - 100%, plus 15 kBtuh Furnaces NA 100% - 200% 100% - 200% 100% - 200% Boilers NA 100% - 140% 100% - 140% 100% - 140%       Two Position Throttling HW Coils NA NA 100% - 125% 100% - 150%   For Air Conditioner and Heat Pump equipment, the Cooling Sizing Percentage, calculated using Equation 2, matches the Cooling Sizing Percentage value reported in Section 4.2.5.3.12. 4.3.16. For Boiler and Furnace equipment, the Heating Sizing Percentage, calculated using Equation 4, matches the Heating Sizing Percentage value reported in Section 4.2.5.3.20. 4.3.17. For Heat Pump equipment, if Climate Condition B is reported in Section 4.2.5.3.13, then the Sensible Heat Ratio, calculated using Equation 3, is ≥ 95% and the HDD65/CDD50 Ratio, as determined using Appendix A for the county and state, or U.S. territory, reported in Section 4.2.4.6 is ≥ 2.0.
It is recommended that the standard align with other RESNET, ACCA, and ICC codes. This standard needs to insert a requirement for capacity tolerances as specified in ACCA Manual S (as specified in RESNET/ICC 301, ACCA QI-5, and model codes), or strike the sections that unnecessarily collect data.
16	5.0	Obj.	Tech.	5. Task 2: Evaluation of the Total Duct Leakage. (Delete this section)
This test adds significant expense to an installation and will be an onerous burden to perform.  This expense will be a hurdle for the standard to overcome. Duct leakage to the unconditioned space is currently a test requirement because of its huge energy penalty.  Duct leakage to the conditioned space has no impact on the home’s energy use.  Since this is the Home Energy Rating System (HERS) score, there is no energy efficiency justification to support requirement. This requirement originated, in part, to support one airflow test procedure (flowhood procedure).  If total duct leakage is retained, it should be as a prerequisite for that procedure. In order to promote broader adoption of this standard’s requirements, and due to the lack of an energy-related justification it is recommended that the Total Duct Leakage requirement be removed or relocated to support airflow measurement with a flow hood.
18	6.1	Obj.	Tech.	… As an alternative to completing the procedures defined in Sections 6.4 through 6.7, the following are approved for use: 6.1.1  Section 4 from ANSI/ACCA 5 QI, (renumber following sections) 6.1.1. Section 8.6 from ASTM E1554-13, 6.1.2. Normative Appendix A from ANSI/ASHRAE Standard 152-2004, 6.1.3. Section RA3.3 from the 2016 Reference Appendices for the 2016 Building Energy Efficiency Standards of the California Energy Commission.
Adds an alternate set of industry accepted procedures.
19	6.2	Obj.	Tech.	6.2. Prerequisites. Prior to evaluating the Blower Fan volumetric airflow, all the following requirements shall have been met.  (Delete this section)
Aligns the standard if previous proposed edit was adopted.
21	6.4.2.3.	Obj.	Tech.	The Forced-Air HVAC System shall run for 10 minutes continuously.
To support duplicative test results, this requirement needs to be removed.  In humid climates, if the HVAC professional tests on a humid day, and the rater tests on an arid day, the test results could be marginally different.  In humid climates it is best to test in the cooling mode with a wet coil… but for a standardized procedure, that seeks to provide symmetrical results winter/summer, humid/arid… the 10 minute run time is unnecessary. This edit applies to 6.6.2.1 as well.
26	6.7.3.1.	Obj.	Tech.	If the Blower Fan motor type, as reported in Section 4.2.5.3.4, is ECM or Other Motor Type, then the elevation of the system shall be verified to be ≤ 2,500 ft. Otherwise, one of the other airflow test procedures shall be used if airflow is to be measured.   Per Section 4.2.5.3.4, if the Blower Fan motor type is ECM or Other, then the elevation of the system must be below 2,500 ft., or another procedure must be used. Exception: The OEM Static Pressure Table provides air density correction factors that correspond to the systems elevation. Exception: The OEM provides instructions to adjust the blower table to account for elevations above 2,500 ft.
This edit seeks to allow for wider adoption and inclusion of furnaces installed at elevations above 2,500 ft.
30	7.3.2	Obj.	Tech.	7.3.2. Settings for HVAC System. If the Forced-Air HVAC System contains an Air Conditioner, then the test shall be conducted in cooling mode. If the Forced-Air HVAC System contains a Heat Pump, then the test shall either be conducted in the mode with the higher design airflow, as reported in Section 4.2.5.5.1, or in both the heating and cooling mode. If the Blower Fan watt draw in Ventilation Mode is being verified, then Section 7.3.2.3 shall be followed. Blower Fan watt draw in Ventilation Mode shall not be used to designate the Blower Fan watt draw grade per Section 7.8. 7.3.2.1. Cooling Mode. 7.3.2.1.1. If the outdoor temperature is < 55 °F (13 °C), then power to the compressor shall be cut off 49 for the duration of the test. 7.3.2.1.2. The thermostat shall be set to cooling mode and the setpoint temperature adjusted as low as possible 50. 7.3.2.1.3. If the Forced-Air HVAC System serves multiple zones, as reported in Section 4.2.5.2, then manufacturer instructions shall be followed to ensure that all zones in the Forced-Air HVAC System are calling for the required mode for testing. 7.3.2.2. Heating Mode. 7.3.2.2.1. The thermostat shall be set to heating mode and the setpoint temperature adjusted as high as possible 50. 7.3.2.2.2. If the Forced-Air HVAC System serves multiple zones, as reported in Section 4.2.5.2, then manufacturer instructions shall be followed to ensure that all zones in the Forced-Air HVAC System are calling for the required mode for testing. 7.3.2.3. Ventilation Mode. 7.3.2.3.1. The thermostat shall be set to Ventilation Mode 51.
Blower fan watt draw in ventilation mode will provide a false indication of energy use.  It is not allowed to be used to determine a score.  This section is superfluous and must be deleted.
33	7.5.2.4.2.	Obj.	Tech.	7.5.2.4.2.4. The clamp of the Clamp-On Watt Meter shall be placed around the second of two wires 57 supplying power to the equipment with the Blower Fan. 7.5.2.4.2.5. The negative lead shall again be placed in contact with the connection between the first electrical power supply wire and the equipment’s power supply wire 57. The positive lead shall again be placed in contact with the connection between the second electrical power supply wire and the equipment’s power supply wire 57. 7.5.2.4.2.6. The average watt draw of the Blower Fan, WfanB, displayed on the Clamp-On Watt Meter shall be measured over at least a 10-second period. 7.5.2.4.2.7. Wfan shall be calculated by averaging WfanA and WfanB, and recorded.
Unless there is research to support a drastic difference in current between L1 and L2, it is recommended that the second measurement be removed.
33	7.6.1.2.	Obj.	Tech.	7.6.1.2. Stopwatch. A stopwatch that provides measurements in units of seconds.  The equipment listed in this section shall have its calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.
Aligns calibration requirements.
36	8.3.2.1.	Obj.	Tech.	8.3.2.1. The Weigh-In Method, per Section 8.5, is permitted to be used when the following conditions are met: 8.3.2.1.1. Outdoor air temperatures do not meet the requirements of the Non-Invasive method in Section 8.3.2.2; or, 8.3.2.1.2. The Forced-Air HVAC System is a Mini-Split Air Conditioner, Mini-Split Heat Pump, Multi-Split Air Conditioner, or a Multi-Split Heat Pump.
The restrictions in 8.3.2.1 are unnecessarily exclusive, what is the justification for limiting this procedure?  This language needs to be struck.
36	8.3.2.2.	Obj.	Tech.	8.3.2.2. The Non-Invasive Procedure, per Section 8.4, is permitted to be used when the procedures in Section 8.3.2.2.1 and 8.3.2.2.2 are completed and the conditions in Section 8.3.2.2.3 are met: 8.3.2.2.1 3. The outdoor air dry-bulb temperature shall meet the following conditions: 8.3.2.2.1 3.1. Outdoor air dry-bulb temperature is between 75 °F (24 °C) and 115 °F (46 °C) for equipment with a rated efficiency ≥ 17 SEER, or 8.3.2.2.1 3.2. Outdoor air dry-bulb temperature is between 70 °F (20 °C) and 115 °F (46 °C) for all other equipment. 8.3.2.2.1. The Digital Thermometer shall be shielded from direct sun and the average outdoor air dry-bulb-temperature shall be measured over at least a 10-second period where the outdoor air enters the condensing unit. 8.3.2.2.2. The rated system efficiency is known, per Section 4.2.5.3.10, of the Forced-Air HVAC System under test shall be determined.
Confirm the simple things first, ODT.  Shielding the thermometer is a procedure for a subsequent section. If the efficiency is known… it doesn’t have to come from earlier data.
46	8.6.4.	Obj.	Tech.	Add section that instructs Rater to restore the mode of operation and return setpoints to their original settings.
Provides compliance to earlier sections.
47	9.0	Obj.	Tech.	9. References. Add reference to: Manual D® - Residential Duct Systems [ANSI/ACCA 1 Manual D - 2016] Manual B - Balancing and Testing Air and Hydronic Systems
These documents were cited in the definition of CFA.

 

Proposed Change:

See edits embedded in table above.

Comment #38

Page Number: 21 / 23 / 25 / 26 / 31 / 31 / 33 / 34 / 36 / 37 / 43
Paragraph / Figure / Table / Note: 6.4.1 / 6.5.1 / 6.6.1 / 6.7.1 / 7.4.1 / 7.5.1 / 7.6.1 / 7.7.1 / 8.3.1 / 8.4.2 / 8.5.1
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

Several sections contain language requiring that equipment shall have its “calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.” Not every piece of equipment listed in these sections is capable of being calibrated. The language should be revised to require that all equipment be observed to be in usable condition. In addition, if some or all equipment within a section may be capable of being calibrated, then it should be recommended that such equipment be calibrated at the manufacturer’s recommended intervals, instead of specifying annual calibration.

Proposed Change:

Section 6.4.1

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition. The equipment listed in this section shall have its calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified. In addition, if the manufacturer recommends calibration, then the equipment listed in this section shall be calibrated at the manufacturer’s recommended interval.

Section 6.5.1

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition. The equipment listed in this section shall have its calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified. In addition, if the manufacturer recommends calibration, then the equipment listed in this section shall be calibrated at the manufacturer’s recommended interval.

Section 6.6.1

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition. The equipment listed in this section shall have its calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.  In addition, if the manufacturer recommends calibration, then the equipment listed in this section shall be calibrated at the manufacturer’s recommended interval.

Section 6.7.1

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition. The equipment listed in this section shall have its calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.  In addition, if the manufacturer recommends calibration, then the equipment listed in this section shall be calibrated at the manufacturer’s recommended interval.

Section 7.4.1

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition. The equipment listed in this section shall have its calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.

Section 7.5.1

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition. The equipment listed in this section shall have its calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.  In addition, if the manufacturer recommends calibration, then the equipment listed in this section shall be calibrated at the manufacturer’s recommended interval.

Section 7.6.1

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition.

Section 7.7.1

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition.

Section 8.3.1

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition. The equipment listed in this section shall have its calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.

Section 8.4.2

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition. The equipment listed in this section shall have its calibrations checked at the manufacturer's recommended interval, and at least annually if no time is specified.

Section 8.5.1

Equipment Needed. The equipment listed in this section shall be observed to be in usable condition.

Comment #39

Page Number: 24
Paragraph / Figure / Table / Note: 6.5.2.5
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

Section 6.5.2.5, for measuring Blower Fan Volumetric Airflow with a Flow Grid, states that “If there are multiple filters in the duct system, a Flow Grid shall be installed at each filter location so that simultaneous measurements are taken, representing total system airflow.”

For a situation where there are multiple filters located at return grilles, and an unused filter slot at the air handler, airflow can be measured with one Flow Grid at the unused filter slot. Additionally, in this scenario the multiple filters at the return grilles should be removed after measuring Psop in 6.5.2.4.

Proposed Change:

Section 6.5.2.5

The All filters shall be removed replaced with the appropriate flow plate of the Flow Grid. One or more flow plates shall be located so that all of the Blower Fan airflow will flow through them ³⁷. If multiple locations are required ³⁸, multiple flow plates shall be used so that simultaneous measurements are taken, representing total system airflow. The flow plate shall be in a location where all of the Blower Fan airflow will flow through the Flow Grid. In addition, the The flow plate(s) shall be temporarily sealed in place so that air must go through, rather than around, the plate(s). Flow Grid manufacturer instructions shall be followed to ensure proper setup. If there are multiple filters in the duct system, a Flow Grid shall be installed at each filter location so that simultaneous measurements are taken, representing total system airflow.

37 (Informative Note) For example, a single flow plate at a filter slot located at the air handler, a single flow plate at a return grille for a Forced-Air HVAC System with a single return, or a flow plate at each return grille for a Forced-Air HVAC System with multiple returns.

38 (Informative Note) For example, a system with multiple return grilles, with a filter at each grille.

Comment #40

Page Number: 20-21 / 30
Paragraph / Figure / Table / Note: 6.3.5 / 7.3.2
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

Section 6.3.5, Settings for HVAC system for the Evaluation of Blower Fan Volumetric Airflow, provides instructions on what mode (cooling or heating) to conduct the test in.

For testing in cooling mode, Section 6.3.5.1.1 states “If the outdoor temperature is < 55 °F (13 °C), then power to the compressor shall be cut off for the duration of the test.” For some equipment, it is not possible to cut off power to the compressor independent of the indoor unit. An example of this would be a mini-split with a multi-position air handler with a fully ducted system, where the indoor unit receives power from the outdoor unit. Unlike non-ducted mini-splits these systems would not achieve Grade I airflow by default because it’s likely they have > 10 ft. of ductwork. When the outdoor temperature is < 55 °F, and the power to the compressor is not able to be cut off, then the standard should direct to test in heating mode.

Additionally, Section 6.3.5.2 provides instructions for testing in heating mode. Unlike the cooling mode instructions there is no limit for the outdoor air temperature to conduct the test in heating mode. Heat pump manufacturers specify recommended limits for operating a heat pumps in heating mode and this section should be revised to include a maximum outdoor air temperature of 60 °F. With this addition, the logic in the paragraph above should also apply. Specifically, instruct that when testing in heating mode if the outdoor air temperature is > 60 °F power to the compressor shall be cut off, if the power to the compressor is not able to be cut off, then the standard should direct to test in cooling mode.

Nearly identical instructions are provided for Evaluation of the Blower Fan Watt Draw in Section 7.3.2 for what mode (cooling or heating) to conduct the test in. This section should be revised accordingly to match the edits made to Section 6.3.5 because the intent of the standard is that watt draw should be tested with the same equipment configurations as when testing airflow.

Proposed Change:

Section 6.3.5

Settings for HVAC System. If the Forced-Air HVAC System contains an Air Conditioner, then the test shall be conducted in according to Section 6.3.5.1 cooling mode. If the Forced-Air HVAC System contains a Heat Pump, then the test shall either be conducted according to Section 6.3.5.1 if cooling mode is the higher deign airflow as reported in Section 4.2.5.5.1, or the test shall be conducted according to Section 6.3.5.2 if heating mode is the higher design airflow as reported in Section 4.2.5.5.1. in the mode with the higher design airflow, as reported in Section 4.2.5.5.1, or in both the heating and cooling mode

6.3.5.1. Cooling Mode.

6.3.5.1.1. If the outdoor temperature is < 55 °F (13 °C), then power to the compressor shall be cut off for the duration of the test. If the Forced-Air HVAC System is capable of operating in heating mode and power to the compressor is not able to be cut off then the test shall be conducted according to Section 6.3.5.2.

6.3.5.1.2. The thermostat shall be set to cooling mode and the setpoint temperature adjusted as low as possible.

6.3.5.1.3. If the Forced-Air HVAC System serves multiple zones, as reported in Section 4.2.5.2, then manufacturer instructions shall be followed to ensure that all zones in the Forced-Air HVAC System are calling for the required mode for testing.

6.3.5.2. Heating Mode.

6.3.5.2.1. If the outdoor temperature is > 60 °F (16 °C), then power to the compressor shall be cut off for the duration of the test. If the Forced-Air HVAC System is capable of operating in cooling mode and power to the compressor is not able to be cut off then the test shall be conducted according to Section 6.3.5.1.

6.3.5.2.12. The thermostat shall be set to heating mode and the setpoint temperature adjusted as high as possible.

6.3.5.2.23. If the Forced-Air HVAC System serves multiple zones, as reported in Section4.2.5.2, then manufacturer instructions shall be followed to ensure that all zones in the Forced-Air HVAC System are calling for the required mode for testing.

Section 7.3.2

Settings for HVAC System. If the Forced-Air HVAC System contains an Air Conditioner, then the test shall be conducted in according to Section 7.3.2.1 cooling mode. If the Forced-Air HVAC System contains a Heat Pump, then the test shall either be conducted according to Section 7.3.2.1 if cooling mode is the higher deign airflow as reported in Section 4.2.5.5.1, or the test shall be conducted according to Section 7.3.2.2 if heating mode is the higher design airflow as reported in Section 4.2.5.5.1. in the mode with the higher design airflow, as reported in Section 4.2.5.5.1, or in both the heating and cooling mode. If the Blower Fan watt draw in Ventilation Mode is being verified, then Section 7.3.2.3 shall be followed. Blower Fan watt draw in Ventilation Mode shall not be used to designate the Blower Fan watt draw grade per Section 7.8.

7.3.2.1. Cooling Mode.

7.3.2.1.1. If the outdoor temperature is < 55 °F (13 °C), then power to the compressor shall be cut off for the duration of the test. If the Forced-Air HVAC System is capable of operating in heating mode and power to the compressor is not able to be cut off then the test shall be conducted according to Section 7.3.2.2.

7.3.2.1.2. The thermostat shall be set to cooling mode and the setpoint temperature adjusted as low as possible 50.

7.3.2.1.3. If the Forced-Air HVAC System serves multiple zones, as reported in Section 4.2.5.2, then manufacturer instructions shall be followed to ensure that all zones in the Forced-Air HVAC System are calling for the required mode for testing.

7.3.2.2. Heating Mode.

6.3.5.2.1. If the outdoor temperature is > 60 °F (16 °C), then power to the compressor shall be cut off for the duration of the test. If the Forced-Air HVAC System is capable of operating in cooling mode and power to the compressor is not able to be cut off then the test shall be conducted according to Section 7.3.2.1.

7.3.2.2.12. The thermostat shall be set to heating mode and the setpoint temperature adjusted as high as possible.

7.3.2.2.23. If the Forced-Air HVAC System serves multiple zones, as reported in Section 4.2.5.2, then manufacturer instructions shall be followed to ensure that all zones in the Forced-Air HVAC System are calling for the required mode for testing.

Comment #41

Page Number: 16 / 18 / 19 / 19 / 19 / 29 / 35-36 / 37 / 37 / 38 / 41 / 43
Paragraph / Figure / Table / Note: 5.2 / 5.4.3 /6.2.1.4 /6.2.2 / 6.2.2.1 / 7.2 / 8.2.1 / 8.4.1.3.1 / 8.4.1.4 / 8.4.3.4 / 8.4.3.8.4 / 8.4.3.9.5
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

The phrase “shall not be evaluated”, or similar phrases are used in several locations. The intent of sections that use this language is that something has not met a requirement of the standard, and therefore the relevant procedure for that section and subsequent sections shall not be conducted, and Grade III shall be assigned. Edits should be made to clearly reflect this intent.

Proposed Change:

Section 5.2

Prerequisites. The HVAC design of the Dwelling to be rated shall have been evaluated in accordance with Section 4: all the required design documentation defined in Section 4.2 shall have been collected, and shall have been reviewed and verified to be in accordance with Section 4.3. If the design has not been evaluated, then the total duct leakage shall not be evaluated the Forced-air HVAC System shall not be further evaluated using this standard, and Grade III shall be designated for total duct leakage, Blower Fan volumetric airflow, Blower Fan watt draw, and refrigerant charge.

Section 5.4.3

Unless the exception in Section 5.3has been met, Grade III shall be designated and recorded if the total duct leakage has not been measured or has been measured and exceeds the limits in Section 5.4.2.

Section 6.2.1.4

If the total duct leakage has been designated Grade III, then Blower Fan volumetric airflow shall not be evaluated the Forced-air HVAC System shall not be further evaluated using this standard, and Grade III shall be designated for Blower Fan volumetric airflow, Blower Fan watt draw, and refrigerant charge.

Section 6.2.2

Verification of HVAC Components. If the following components are included in the design of the Forced-Air HVAC System under test, they shall be verified to be present. If these components have not yet been installed, then the test shall not be conducted the Forced-air HVAC System shall not be further evaluated using this standard, and Grade III shall be designated for Blower Fan volumetric airflow, Blower Fan watt draw, and refrigerant charge. The additional requirements defined in Section 6.2.2.1 shall also be met.

Section 6.2.2.1

HVAC equipment. The specified manufacturer(s) and model number(s) of the equipment in the Forced-Air HVAC System under test matches the installed equipment or supplemental documentation has been collected as defined in Section 4.2.5 and verified in accordance with Section 4.3. If the installed equipment does not match the specified equipment in the original or supplemental documentation, then Blower Fan volumetric airflow shall not be evaluated the Forced-air HVAC System shall not be further evaluated using this standard, and Grade III shall be designated for Blower Fan volumetric airflow, Blower Fan watt draw, and refrigerant charge.

Section 7.2

Prerequisites. Prior to evaluating the Blower Fan watt draw, the Blower Fan volumetric airflow shall have been evaluated in accordance with Section 6, including all prerequisites in Section 6.2. In addition, the Blower Fan volumetric airflow shall have been designated Grade I or II, per Section 6.8. If the Blower Fan volumetric airflow has not been evaluated or has been designated Grade III, then Blower Fan watt draw shall not be evaluated Grade III shall be designated for Blower Fan watt draw.

Section 8.2.1

Prior to evaluating the refrigerant charge, the Blower Fan volumetric airflow shall have been evaluated in accordance with Section 6, including all prerequisites in Section 6.2. In addition, the Blower Fan volumetric airflow shall have been designated Grade I or II, per Section 6.8. If the Blower Fan volumetric airflow has not been evaluated or has been designated Grade III, then refrigerant charge shall not be evaluated the Forced-air HVAC System shall not be further evaluated using this standard, and Grade III shall be designated for refrigerant charge.

Section 8.4.1.3.1

Non-motorized dampers that connect the Conditioned Space Volume to the exterior or to Unconditioned Space Volume shall be placed in their closed position during the test and shall not be further sealed. If running the Forced-Air HVAC System causes the non-motorized dampers to open after being placed in their closed position, then the Ventilation openings shall be temporarily sealed. If the Ventilation openings are not accessible, or cannot be temporarily sealed, then refrigerant charge shall not be evaluated the Forced-air HVAC System shall not be further evaluated using this standard, and Grade III shall be designated for refrigerant charge.

Section 8.4.1.4

Ventilation Openings. Non-dampered Ventilation openings within the duct system of intermittently or continuously operating Dwelling-Unit Mechanical Ventilation Systems, including Ventilation systems that use the Blower Fan of the Forced-Air HVAC System, shall be temporarily sealed. If the non-dampered Ventilation openings are not accessible, or cannot be temporarily sealed, then refrigerant charge shall not be evaluated the Forced-air HVAC System shall not be further evaluated using this standard, and Grade III shall be designated for refrigerant charge.

Section 8.4.3.4

The return air temperatures measured in Section 8.4.3.3 shall be evaluated for compliance with the following conditions. The following two conditions shall be met, or the refrigerant charge shall not be evaluated using the non-invasive method the Forced-air HVAC System shall not be further evaluated using this standard, and Grade III shall be designated for refrigerant charge:

Section 8.4.3.8.4

If the measured liquid line temperature, per Section 8.4.3.5.3, is < T _{liquid line, minor} > T _{liquid line, max}, then refrigerant charge shall not be evaluated the Forced-air HVAC System shall not be further evaluated using this standard, and Grade III shall be designated for refrigerant charge.

Section 8.4.3.9.5

If the measured suction line temperature, per Section8.4.3.5.2, is >65 °F (18 °C), < T _{suction line, min}, or > T _{suction line, max}, then refrigerant charge shall not be evaluated the Forced-air HVAC System shall not be further evaluated using this standard, and Grade III shall be designated for refrigerant charge.

Comment #42

Page Number: 16, 28, 44, 45
Paragraph / Figure / Table / Note: 5.3, 6.7.3.11, 8.5.3.5, 8.5.3.7
Comment Intent: Not an Objection
Comment Type: General

Comment:

The phrase “and recorded” is used throughout the standard to indicate when a parameter should be documented. This requirement should be extended to a few additional parameters, as noted in the proposed change.

 

Proposed Change:

5.3. Procedure to Measure Total Duct Leakage. The total duct leakage of the Forced-Air HVAC system under test shall be measured in accordance with ANSI/RESNET/ICC 380. The total duct leakage; time of test, either rough-in or final; and number of returns shall be and recorded.

6.7.3.11. The total operational pressure of the system, Ptop, shall be calculated in IWC or Pa using Equation 9 and recorded

8.5.3.5. The total anticipated refrigerant weight shall be calculated using Equation 25 and recorded.

8.5.3.7. The deviation between the total anticipated and total reported refrigerant weight shall be calculated using Equation 27 and recorded.