The following comments have been submitted:
Comment #1Page Number: 72 and following pagesParagraph / Figure / Table / Note: 4.5.2.4Comment Intent: ObjectionComment Type: GeneralComment: Addendum B makes dozens of references to BSR/RESNET/ACCA Standard 310. Unfortunately, this is not a published standard; when last seen, the second comment period was pending. I believe that it is inappropriate for Std 301-2019 to reference and rely upon an unpublished standard. Furthermore, the Board of Directors of RESNET decided that draft Std 310 will not become a public standard. Given that Std 301 is a public standard, and is referenced by ICC energy codes, Std 301 should not be referencing a proprietary standard. Proposed Change: Strike all references to BSR/RESNET/ACCA 310 and the edits associated with those references.
Addendum B makes dozens of references to BSR/RESNET/ACCA Standard 310. Unfortunately, this is not a published standard; when last seen, the second comment period was pending.
I believe that it is inappropriate for Std 301-2019 to reference and rely upon an unpublished standard.
Furthermore, the Board of Directors of RESNET decided that draft Std 310 will not become a public standard. Given that Std 301 is a public standard, and is referenced by ICC energy codes, Std 301 should not be referencing a proprietary standard.
Strike all references to BSR/RESNET/ACCA 310 and the edits associated with those references.
Comment #2Page Number: 28; 76Paragraph / Figure / Table / Note: Table 4.2.2(1); Table 4.5.2(2)Comment Intent: Not an ObjectionComment Type: TechnicalComment: Dehumidifier capacity will vary based on ambient conditions (i.e., temperature and relative humidity). Often manufacturers provide the rated capacity at multiple ambient conditions. For example this Honeywell system lists capacity at 60, 70, and 80 F. The proposed section on dehumidification systems requires the capacity to be the same as the Rated Home, but does not specify the conditions at which the corresponding capacity should be used for the rating. For example, for the Honeywell product cited above, would the capacity be 47 (@60F), 65 (@70F), or 90 (@80F) pints? The latest DOE test procedures test portable dehumidifiers at 65 °F and 60 %RH, and whole-home dehumidifiers at 73 °F and 60 %RH. Prior DOE test procedures tested equipment at 80 °F and 60 %RH. To ensure consistent ratings and calculations, the standard should specify the conditions (dry bulb temperature and relative humidity) at which the corresponding rated dehumidifier capacity should be used for the rating. Ideally these conditions would align with the conditions used to determine the reference design Integrated energy factor. The issue raised in this comment is not applicable to the other dehumidification system metric, integrated energy factor, because this metric is defined and determined by manufacturers according to DOE test procedures so that will ensure consistency. The proposed change assumes the reference design uses the current DOE test points, and therefore capacity should be reported at those same conditions. Proposed Change: Include a new note for table 4.2.2.(1): Dehumidification System None, except where a dehumidification system is specified by the Rated Home, in which case: Type: Stand-alone dehumidifier Capacity: aa Same as Rated Home Efficacy: Integrated energy factor (liters/kWh) determined as a function of capacity in pints/day, as follows: 25.00 or less: 0.79 liters/kWh 25.01 – 35.00: 0.95 liters/kWh 35.01-54.00: 1.04 liters/kWh 54.01-74.99: 1.20 liters/kWh 75.00 or more: 1.82 liters/kWh Dehumidistat setpoint: 60% RH Type: Same as Rated Home Capacity: aa Same as Rated Home Efficacy: Same as Rated Home Dehumidistat setpoint: Same as Energy Rating Reference Home aa. The dehumidification system capacity used for the rating shall be the capacity that corresponds to 65 °F and 60 % relative humidity for portable dehumidifiers and 73 °F and 60 % relative humidity for whole-home dehumidifiers. Additionally, Table 4.5.2(2) should be updated as follows: 27. Dehumidification Equipment Equipment type, capacity corresponding to 65 °F and 60 % relative humidity for portable dehumidifiers and 73 °F and 60 % relative humidity for whole-home dehumidifiers, integrated energy factor.
Dehumidifier capacity will vary based on ambient conditions (i.e., temperature and relative humidity). Often manufacturers provide the rated capacity at multiple ambient conditions. For example this Honeywell system lists capacity at 60, 70, and 80 F.
The proposed section on dehumidification systems requires the capacity to be the same as the Rated Home, but does not specify the conditions at which the corresponding capacity should be used for the rating. For example, for the Honeywell product cited above, would the capacity be 47 (@60F), 65 (@70F), or 90 (@80F) pints?
The latest DOE test procedures test portable dehumidifiers at 65 °F and 60 %RH, and whole-home dehumidifiers at 73 °F and 60 %RH. Prior DOE test procedures tested equipment at 80 °F and 60 %RH.
To ensure consistent ratings and calculations, the standard should specify the conditions (dry bulb temperature and relative humidity) at which the corresponding rated dehumidifier capacity should be used for the rating. Ideally these conditions would align with the conditions used to determine the reference design Integrated energy factor.
The issue raised in this comment is not applicable to the other dehumidification system metric, integrated energy factor, because this metric is defined and determined by manufacturers according to DOE test procedures so that will ensure consistency.
The proposed change assumes the reference design uses the current DOE test points, and therefore capacity should be reported at those same conditions.
Include a new note for table 4.2.2.(1):
Dehumidification System
None, except where a dehumidification system is specified by the Rated Home, in which case:
Type: Stand-alone dehumidifier
Capacity: aa Same as Rated Home
Efficacy: Integrated energy factor (liters/kWh) determined as a function of capacity in pints/day, as follows:
25.00 or less: 0.79 liters/kWh
25.01 – 35.00: 0.95 liters/kWh
35.01-54.00: 1.04 liters/kWh
54.01-74.99: 1.20 liters/kWh
75.00 or more: 1.82 liters/kWh
Dehumidistat setpoint: 60% RH
Type: Same as Rated Home
Efficacy: Same as Rated Home
Dehumidistat setpoint: Same as Energy Rating Reference Home
aa. The dehumidification system capacity used for the rating shall be the capacity that corresponds to 65 °F and 60 % relative humidity for portable dehumidifiers and 73 °F and 60 % relative humidity for whole-home dehumidifiers.
Additionally, Table 4.5.2(2) should be updated as follows:
27. Dehumidification Equipment
Equipment type, capacity corresponding to 65 °F and 60 % relative humidity for portable dehumidifiers and 73 °F and 60 % relative humidity for whole-home dehumidifiers, integrated energy factor.