BSR/RESNET/ICC 380-202x, draft PDS-01 Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: 14
Paragraph / Figure / Table / Note: 5.4.2.1
Comment Intent: Objection
Comment Type: Technical

Comment:

"If ducts run outside the Infiltration Volume including attics, garages or crawlspaces, then any vents, access panels, doors or windows between those spaces and the outside shall be opened"

Wehn performing a duct leakage to outide test one must presurize the house to 25 PA. if you have duct runing in the attic, "outside of the infirtration volume" how can you open the attic hatch and presurize the house to 25 PA?  This only makes sense if you have a conditioned attic or crawl space.

Proposed Change:

If ducts run outside the Infiltration Volume includes including conditioned attics, garages or crawlspaces, then any vents, access panels, doors or windows between those spaces and the outside conditioned space shall be opened. All exterior doors and windows between the Infiltration Volume and outside, including garages shall be closed. Other openings to the outside with potential to hinder the ability of the air-moving fanAir-Moving Fan to achieve an induced enclosure pressure difference of 25 Pa (0.1 in. H2O) with reference to outside shall be closed or covered in some manner. Interior doors shall be opened.

 

Comment #2

Page Number: 32
Paragraph / Figure / Table / Note: 5.4.2.2 - 5.4.2.6
Comment Intent: Objection
Comment Type: Technical

Comment:

Running back and forth between the blower door and duct blaster makes no sense and does not increase the accuracy of the test enough to matter. Most raters and rating companies do not have two or more guages on site. The duct blaster should not have to be covered to get the baseline.  the blower door should be able to be run in cruise mode to maintain as close to 25 PA as possible and should not have to be rechecked over and over again.  ensuring that the duct pressure is zeroed out is the key.  It is confusing when standard does not state when to take the LTO measurment.

Proposed Change:

5.4.2.2. With the air-moving fanAir-Moving Fan for the enclosure and the duct leakage testerDuct Leakage Tester sealed and turned off, one measurement of the pressure difference across the enclosure shall be recorded with the outside as the reference. The measurement shall represent the average value over at least a 10-second period and shall be defined as the Pre-Test Baseline Dwelling Unit Pressure.

5.4.2.3. The air-moving fanAir-Moving Fan for the enclosure shall be unsealed, turned on and adjusted to continously maintain an  to create an induced enclosure pressure difference of 25 ± 3 Pa (0.1 ±0.012 in. H2O), defined as the induced enclosure pressure minus the Pre-Test Baseline Dwelling Unit Pressure. Note that this value is permitted to be positive or negative depending upon whether the enclosure is pressurized or depressurized.

If a 25 Pa (0.10 in. H2O) induced enclosure pressure difference is not achieved, then the highest possible value up to 25 Pa (0.10 in. H2O) shall be achieved with the equipment available.

5.4.2.4. The duct leakage testerDuct Leakage Tester shall be unsealed, turned on and adjusted to create an induced duct system pressure difference of 0.0 ± 0.5 Pa (0.0 ± 0.002 in. H2O) relative to the Dwelling Unit. If an induced duct system pressure difference of 0.0 Pa (0.0 in. H2O) is not achieved, then the airflow of the air-moving fanAir-Moving Fan for the enclosure shall be reduced until an induced duct system pressure difference of 0.0 Pa (0.0 in. H2O) is achieved.

5.4.2.5. The induced enclosure pressure difference shall be rechecked and the air-moving fanAir-Moving Fan for the enclosure shall be adjusted to maintain 25 Pa (0.10 in. H2O) or the highest achievable value up to 25 Pa (0.10 in. H2O), in accordance with Section 45.4.2.3, or the airflow required to maintain an induced duct system pressure difference of 0.0 Pa (0.0 in. H2O), in accordance with Section 5.4.2.4 it is permitted to use cruise functions on modern gauge controls to continuously maintain 25PA ± 3 Pa (0.1 ±0.012 in. H2O).

5.4.2.6. The induced duct system pressure difference shall be rechecked, and the duct leakage testerDuct Leakage Tester shall be adjusted to maintain 0.0 ± 0.5 Pa (0.0 ± 0.002 in. H2O), in accordance with Section 5.4.2.4. when the guage reades zero take the lekage to ouside measurment.

 

Comment #3

Page Number: 9
Paragraph / Figure / Table / Note: 4.2.5-4.2.5.3
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

There are currently no provisions for when a home contains a conditioned crawl space served by the primary air handling equipment, does not have an operable opening from the living area and the crawlspace, and the air handling equipment is located in the attic. Can a provision be added for this construction site? 

Proposed Change:

Proposed: If a crawlspace is contiguous with and dedicated to the subject dwelling unit and is conditioned space volume and does not include an operable door or hatch beween the subject dwelling unit and the crawlspace, a secondary blower door may be utilized to test the air leakage of the crawlspace in conjunction with the air leakage of the occupiable space. 

Comment #4

Page Number: 3
Paragraph / Figure / Table / Note: Definitions
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 175 Raters and 9 Providers
from New Jersey to Maine.

We recommend modifying the language of the definition of Condtioned Floor Area to increase clarity and simplicity.

Proposed Change:

Conditioned Floor Area (CFA)[1] The floor area of the Conditioned Space Volume within a building or Dwelling Unit, not including the floor area of attics or, crawlspaces, and basements below air sealed and insulated floors. The following specific spaces are addressed to ensure consistent application of this definition:

  • The floor area of the full width of a wall assembly that is adjacent to Conditioned Space Volume shall be included. The floor area, including the full width of a wall assembly that is within Conditioned Space Volume shall be included

Exception: If the volume of one of the spaces horizontally adjacent to a wall assembly is a Dwelling Unit other than the subject Dwelling Unit, then the floor area of the full width of that wall assembly shall be evenly divided between both adjacent Dwelling Units Exception: If the volume of one of the Dwelling Unit spaces shares a common or demising wall, then the full width of the floor area shall be taken at the centerline or midpoint of the demising wall.

  • The floor area of a basement shall only be included if it is contiguous with and dedicated[2] to the subject Dwelling Unit and the party conducting the evaluations has either : The floor area of a basement shall only be included if it is contiguous with, and dedicated[1] to the subject Dwelling Unit and the party conducting the evaluations has either:

-       Obtained an ACCA Manual J, S, and either B or D report and verified that both the heating and cooling equipment and distribution system are designed to offset the entire design load of the volume; or

-       Verified through visual inspection that both the heating and cooling equipment and distribution system serve the volume and, in the judgment of the party conducting evaluations, are capable of maintaining space conditions at 78°F (26°C) for cooling and 68°F (20°C) for heatingthe heating and cooling temperatures specified by the Thermostat section in the Building Component column of Table 4.2.2(1) of ANSI/RESNET/ICC 301.

  • The floor area of a garage shall be excluded even when it is conditioned.
  • The floor area of a thermally isolated sunroom shall be excluded.
  • The floor area of an attic shall be excluded even when it is Conditioned Space Volume[3].
  • The floor area of a crawlspace shall be excluded even when it is Conditioned Space Volume.


 

 

Comment #5

Page Number: 4
Paragraph / Figure / Table / Note: Definitions
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 175 Raters and 9 Providers
from New Jersey to Maine.

We recommend revising the definition of Conditioned Space Volume for clarity and simplicity.

Proposed Change:

Conditioned Space Volume[1]The volume within a building or Dwelling Unit serviced by a space heating or cooling system designed to maintain space conditions at 78°F (26°C) for cooling and 68°F (20°C) for heating. The following specific spaces are addressed to ensure consistent application of this definition:

If the volume both above and below a floor assembly meets this definition and is part of the subject Dwelling Unit, then the volume of the full depth of the floor assembly shall

also be included. Otherwise, the volume of the full depth of the floor assembly shall be excluded.

Exception:  The wall height of the volume shall extend from the finished floor to the bottom side of the floor decking above the subject Dwelling Unit for non-top floor level Dwelling Units and to the exterior enclosure air barrier for top floor level Dwelling Units.  Exception:  The wall height used to determine the volume shall extend from the top surface of  finished floor to the bottom surface of the floor decking above the subject Dwelling Unit for all floors other than the top floor level. For top floor level Dwelling Units this dimension shall end at the exterior surface of the enclosure air barrier.

  • If the volume of at least one of the spaces horizontally adjacent to a wall assembly meets this definition and that volume is part of the subject Dwelling Unit, then the volume of the full width of the wall assembly shall also be included. Otherwise, the volume of the full width of the wall assembly shall be excluded.

Exception: If the volume of one of the spaces horizontally adjacent to a wall assembly is a Dwelling Unit other than the subject Dwelling Unit, then the volume of the full width of that wall assembly shall be evenly divided between both adjacent Dwelling Units. Exception: If the volume of one of the Dwelling Unit spaces shares a common or demising wall, then the full width of the floor area shall be taken at the centerline or midpoint of the demising wall.

  • The volume of an attic that is not both air sealed and insulated at the roof deck shall be excluded.
  • The volume of a vented crawlspace shall be excluded.
  • The volume of a garage shall be excluded even when it is conditioned.
  • The volume of a thermally isolated sunroom shall be excluded.
  • The volume of an attic that is both air sealed and insulated at the roof deck, the volume of an unvented crawlspace, and or the volume of a basement shall only be included if the volume it is contiguous with and dedicated[1] to the subject Dwelling Unit and the party conducting evaluations has either : The volume of an attic, crawlspace, or basement shall only be included if it is contiguous with and dedicated[1] to the subject Dwelling Unit and the party conducting evaluations has either:

-       Obtained an ACCA Manual J, S, and either B or D report and verified that both the heating and cooling equipment and distribution system are designed to offset the entire design load of the volume; or

-       Verified through visual inspection that both the heating and cooling equipment and distribution system serve the volume and, in the judgment of the party conducting evaluations, can maintain the heating and cooling temperatures specified by the Thermostat section in the Building Component column of      Table 4.2.2(1) of ANSI/RESNET/ICC 301.are capable of maintaining space conditions at 78°F (26°C) for cooling and 68°F (20°C) for heating.

  • The volume of an adjacent mechanical closet, regardless of access location, shall only be included if it that is contiguous with and dedicated5 to the subject Dwelling Unit, only includes equipment serving the subject Dwelling Unit, and the party conducting evaluations has either shall be included if : The volume of an adjacent mechanical closet, regardless of access location, shall only be included if it is within the thermal envelope and dedicated to the subject Dwelling unit, and the party conducting the evaluations has either:
Exception:  The wall height used to determine the volume shall extend from the top surface of  finished floor to the bottom surface of the floor decking above the subject Dwelling Unit for all floors other than the top floor level. For top floor level Dwelling Units this dimension shall end at the exterior surface of the enclosure air barrier

Exception: If the volume of one of the Dwelling Unit spaces shares a common or demising wall, then the full width of the floor area shall be taken at the centerline or midpoint of the demising wall.

  •  The volume of an attic, crawlspace, or basement shall only be included if the volume it is contiguous with and dedicated[1] to the subject Dwelling Unit and the party conducting evaluations has either:

 

The volume of an adjacent mechanical closet, regardless of access location, shall only be included if it is within the thermal envelope and dedicated to the subject Dwelling unit, and the party conducting the evaluations has either:

-       Obtained an ACCA Manual J, S, and either B or D report and verified that both the heating and cooling equipment and distribution system are designed to offset the entire design load of the volume; or

-       Verified through visual inspection that both the heating and cooling equipment and distribution system serve the volume and, in the judgment of the party conducting evaluations, are capable of maintaining space conditions at 78°F (26°C) for cooling and 68°F (20°C) for heating.

-       It is serviced by a space heating or cooling system designed to maintain space conditions at 78°F (26°C) for cooling and 68°F (20°C) for heating; and

-       It only includes equipment serving the subject Dwelling Unit; and

-       The mechanical room is not intentionally air sealed from the subject Dwelling Unit.

 

Comment #6

Page Number: 9
Paragraph / Figure / Table / Note: 4.2.4
Comment Intent: 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 175 Raters and 9 Providers
from New Jersey to Maine.

 

Reference to the removal of the blower compartment panel should be removed from all sections relating to air tightness testing set-up, as the removal of the panel does not constitue "normal operating conditions".

 

 

Proposed Change:

4.2.4. Attics. An attic shall only be included in the Infiltration Volume if it meets the conditions in Section 4.2.4.2 or 4.2.4.3.

4.2.4.1. An attic shall be configured as follows, unless it meets the conditions in Section 4.2.4.2 or 4.2.4.3: any doors and hatches between the subject Dwelling Unit and the attic shall be closed; and any exterior attic access doors, hatches and vents shall be left in their as-found position.

4.2.4.2. If an attic is contiguous with and dedicated[1] to the subject Dwelling Unit and is Conditioned Space Volume, then any doors and hatches between the subject Dwelling Unit and the attic shall be opened; if none are present, then if a Forced-Air HVAC System is in the attic, the blower compartment panel shall be removed, if permitted to do so; and any exterior attic access doors, hatches and vents shall beclosed to the extent possible pressure shall be measured within 10% of Conditioned Space Volume test pressure.  Where adjacent infiltration volume is not accessible within CSV, methods may include: blower compartment panel removal, pressure hose to space, jump duct to space.

4.2.4.3. If an attic is contiguous with and dedicated14 to the subject Dwelling Unit, and is Unconditioned Space Volume, unvented, and its roof deck and exterior walls are both insulated and air-sealed, then any doors and hatches between the subject Dwelling Unit and the attic shall be opened; if none are present, then if a Forced-Air HVAC System is in the attic, the blower compartment panel shall be removed, if permitted to do so; and any exterior attic access doors, hatches and vents shall be closed to the extent possible.pressure shall be measured within 10% of Conditioned Space Volume test pressure.  Where adjacent infiltration volume is not accessible within CSV, methods may include: blower compartment panel removal, pressure hose to space, jump duct to space.

4.2.4.4. The following shall be recorded: whether or not the attic is included in the Infiltration Volume; the position of the attic access doors and hatches, if present; and if a Forced-Air HVAC System is in the attic, whether or not the blower compartment panel was removed .

Comment #7

Page Number: 9
Paragraph / Figure / Table / Note: 4.2.5
Comment Intent: 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 175 Raters and 9 Providers
from New Jersey to Maine.

 

Reference to the removal of the blower compartment panel should be removed from all sections relating to air tightness testing set-up, as the removal of the panel does not constitue "normal operating conditions".

Proposed Change:

4.2.5. Crawlspaces. A crawlspaceCrawlspaces shall be configured as follows, and the position of the crawlspace access doors and hatches shall be recorded. When the access doors and hatches between Conditioned Space Volume and the crawlspace are closed due to requirements in Section 4.2.3.1 or Section 4.2.3.2.1, the crawlspace shall be excluded from Infiltration Volume and Conditioned Space Volume. and the full depth of its floor assembly above shall only be included in the Infiltration Volume if it meets the conditions in Section 4.2.5.2 or 4.2.5.3.

4.2.5.1. A crawlspace shall be configured as follows, unless it meets the conditions in Section 4.2.5.2 or 4.2.5.3: any doors and hatches between the subject Dwelling Unit and the crawlspace shall be closed; and any exterior crawlspace access doors, hatches and vents shall be left in their as-found position.

4.2.5.2. If a crawlspace is contiguous with and dedicated14 to the subject Dwelling Unit and is Conditioned Space Volume, then any doors and hatches between the subject Dwelling Unit and the crawlspace shall be opened; if none are present, then if a Forced-Air HVAC System is in the crawlspace, the blower compartment panel shall be removed, if permitted to do so; and any exterior crawlspace access doors, hatches and vents shall be closed to the extent possible. pressure shall be measured within 10% of Conditioned Space Volume test pressure.  Where adjacent infiltration volume is not accessible within CSV, methods may include: blower compartment panel removal, pressure hose to space, jump duct to space.

4.2.5.3. If a crawlspace is contiguous with and dedicated14 to the subject Dwelling Unit, and is Unconditioned Space Volume, unvented, and its exterior walls are both insulated and air-sealed, then any doors and hatches between the subject Dwelling Unit and the crawlspace shall be opened; if none are present, then if a Forced-Air HVAC System is in the crawlspace, the blower compartment panel shall be removed, if permitted to do so; and any exterior crawlspace access doors, hatches and vents shall be closed to the extent possible. pressure shall be measured within 10% of Conditioned Space Volume test pressure.  Where adjacent infiltration volume is not accessible within CSV, methods may include: blower compartment panel removal, pressure hose to space, jump duct to space.

4.2.5.4. The following shall be recorded: whether or not the crawlspace is included in the Infiltration Volume; the position of the crawlspace access doors and hatches, if present; and if a Forced-Air HVAC System is in the crawlspace, whether or not the blower compartment panel was removed.


 

Comment #8

Page Number: 10
Paragraph / Figure / Table / Note: 4.2.6
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 175 Raters and 9 Providers
from New Jersey to Maine.

 

Reference to the removal of the blower compartment panel should be removed or modified in all sections relating to air tightness testing set-up, as the removal of the panel does not constitue "normal operating conditions". Instead, language should be changed to reflect the intent, which is to include zones that may otherwise be inaccessible.

Proposed Change:

4.2.6. Basements. A basement and the full depth of its floor assembly above shall only be included in the Infiltration Volume if it meets the conditions in Section 4.2.6.2 or 4.2.6.3Basements shall be configured as follows, and the position of the basement doors shall be recorded. When doors between the Conditioned Space Volume and the basement are closed, due to requirements in Section 4.2.5.1.1, the basement shall be excluded from Infiltration Volume and Conditioned Space Volume.

4.2.6.1. A basement shall be configured as follows, unless it meets the conditions in Section 4.2.6.2 or 4.2.6.3: any doors and hatches between the subject Dwelling Unit and the basement shall be closed; and any exterior basement access doors, hatches and vents shall be left in their as-found position.

4.2.6.2. If a basement is contiguous with and dedicated14 to the subject Dwelling Unit and is Conditioned Space Volume, then any doors and hatches between the subject Dwelling Unit and the basement shall be opened; if none are present, then if a Forced-Air HVAC System is in the basement, the blower compartment panel shall be removed, if permitted to do so; and any exterior basement access doors, hatches and vents shall be closed to the extent possible. pressure shall be measured within 10% of Conditioned Space Volume test pressure.  Where adjacent infiltration volume is not accessible within CSV, methods may include: blower compartment panel removal, pressure hose to space, jump duct to space.

4.2.6.3. If a basement is contiguous with and dedicated14 to the subject Dwelling Unit, and is Unconditioned Space Volume, unvented, and its exterior walls are both insulated and air-sealed, then any doors and hatches between the subject Dwelling Unit and the basement shall be opened; if none are present, then if a Forced-Air HVAC System is in the basement, the blower compartment panel shall be removed, if permitted to do so; and any exterior basement access doors, hatches and vents shall be closed to the extent possible. pressure shall be measured within 10% of Conditioned Space Volume test pressure.  Where adjacent infiltration volume is not accessible within CSV, methods may include: blower compartment panel removal, pressure hose to space, jump duct to space.

4.2.5.1.4.2.6.4. The following shall be recorded: whether or not the basement is included in the Infiltration Volume; the position of the basement access doors and hatches, if present; and if a Forced-Air HVAC System is in the basement, whether or not the blower compartment panel was removedAll doors between the Conditioned Space Volume and basement shall be opened. Exterior basement access doors, vents and hatches shall be closed to the extent possible.

4.2.5.1.1. Exception: When the floor above the basement is air sealed and insulated, doors between the basement and Conditioned Space Volume shall be closed.  Exterior basement access doors, hatches and vents shall be left in their as found position.

Comment #9

Page Number: 11
Paragraph / Figure / Table / Note: 4.2.7
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 175 Raters and 9 Providers
from New Jersey to Maine.

 

Reference to the removal of the blower compartment panel should be removed or modified in all sections relating to air tightness testing set-up, as the removal of the panel does not constitue "normal operating conditions". Instead, language should be changed to reflect the intent, which is to include zones that may otherwise be inaccessible.

Proposed Change:

4.2.7. Adjacent mechanical closets. An adjacent mechanical closet and the full width of the wall assembly between it and the subject Dwelling Unit shall only be included in the Infiltration Volume if it meets the conditions in Section 4.2.7.2 or 4.2.7.3.

4.2.7.1. An adjacent mechanical closet shall be configured as follows, unless it meets the conditions in Section 4.2.7.2 or 4.2.7.3: any doors and hatches between the subject Dwelling Unit and the mechanical closet shall be closed; and any exterior mechanical closet access doors, hatches and vents shall be left in their as-found position.

4.2.7.2. If an adjacent mechanical closet is contiguous with and dedicated14 to the subject Dwelling Unit, only includes equipment serving the subject Dwelling Unit, and is Conditioned Space Volume, then any doors and hatches between the subject Dwelling Unit and the mechanical closet shall be opened; if none are present, then if a Forced-Air HVAC System is in the mechanical closet, the blower compartment panel shall be removed, if permitted to do so; and any exterior mechanical closet access doors, hatches and vents shall be closed to the extent possible. pressure shall be measured within 10% of Conditioned Space Volume test pressure.  Where adjacent infiltration volume is not accessible within CSV, methods may include: blower compartment panel removal, pressure hose to space, jump duct to space.

4.2.7.3. If an adjacent mechanical closet is contiguous with and dedicated14 to the subject Dwelling Unit, only includes equipment serving the subject Dwelling Unit, and is Unconditioned Space Volume, unvented, and the wall assembly between it and the subject Dwelling Unit is not air sealed, then any doors and hatches between the subject Dwelling Unit and the mechanical closet shall be opened; if none are present, then if a Forced-Air HVAC System is in the mechanical closet, the blower compartment panel shall be removed, if permitted to do so; and any exterior mechanical closet access doors, hatches and vents shall be closed to the extent possible. pressure shall be measured within 10% of Conditioned Space Volume test pressure.  Where adjacent infiltration volume is not accessible within CSV, methods may include: blower compartment panel removal, pressure hose to space, jump duct to space.

4.2.7.4. The following shall be recorded: whether or not the adjacent mechanical closet is included in the Infiltration Volume; the position of the mechanical closet access doors and hatches, if present; and if a Forced-Air HVAC System is in the mechanical closet, whether or not the blower compartment panel was removed.

Comment #10

Page Number: 8
Paragraph / Figure / Table / Note: 4.2.3
Comment Intent: Objection
Comment Type: General

Comment:

The creation of an opening in an adjacent garage regardless of the location of the blower door does not reflect the normal operation or pressure conditions of the building. We recommend maintaining the existing language.

Proposed Change:

4.2.3. Attached garages. An unrestricted air pathway larger than 20 square feet shall be opened between the attached garage and outside[1]All exterior garage doors and windows shall be closed and latched unless the Blower Door is installed between the Conditioned Space Volume and the garage in which case the garage shall be opened to outside by opening at least one exterior garage door .

Comment #11

Page Number: 10
Paragraph / Figure / Table / Note: 4.2.6.3
Comment Intent: Not an Objection
Comment Type: General

Comment:

There are a number of dwelling units that include basements that do not have insulation/air sealing at the walls nor floor over basement, but otherwise have things like uninsulated leaky ductwork, air handlers, etc. According to the language of 4.2.6.3, these spaces would be excluded from infiltration volume, despite the fact that they are clearly part of the building thermal envelope. This is a step backwards in clarity/consistency; you've undefined a huge swath of buildings with this language. 

Proposed Change:

4.2.6. Basements. A basement and the full depth of its floor assembly above shall only be included in the Infiltration Volume if it meets the conditions in Section 4.2.6.2 or 4.2.6.3Basements shall be configured as follows, and the position of the basement doors shall be recorded. When doors between the Conditioned Space Volume and the basement are closed, due to requirements in Section 4.2.5.1.1, the basement shall be excluded from Infiltration Volume and Conditioned Space Volume.

4.2.6.1. A basement shall be configured as follows, unless it meets the conditions in Section 4.2.6.2 or 4.2.6.3: any doors and hatches between the subject Dwelling Unit and the basement shall be closed; and any exterior basement access doors, hatches and vents shall be left in their as-found position.

4.2.6.2. If a basement is contiguous with and dedicated14 to the subject Dwelling Unit and is Conditioned Space Volume, then any doors and hatches between the subject Dwelling Unit and the basement shall be opened; if none are present, then if a Forced-Air HVAC System is in the basement, the blower compartment panel shall be removed, if permitted to do so; and any exterior basement access doors, hatches  and vents shall be closed to the extent possible.

4.2.6.3. If a basement is contiguous with and dedicated14 to the subject Dwelling Unit, and is Unconditioned Space Volume and unvented, and its exterior walls are both insulated and air-sealed, then any doors and hatches between the subject Dwelling  Unit and the basement shall be opened; if none are present, then if a Forced-Air HVAC System is in the basement, the blower compartment panel shall be removed, if permitted to do so; and any exterior basement access doors, hatches and vents shall be closed to the extent possible.

4.2.5.1.4.2.6.4. The following shall be recorded: whether or not the basement is included in the Infiltration Volume; the position of the basement access doors and hatches, if present; and if a Forced-Air HVAC System is in the basement, whether or not the blower compartment panel was removedAll doors between the Conditioned Space Volume and basement shall be opened. Exterior basement access doors, vents and hatches shall be closed to the extent possible.

4.2.5.1.1. Exception: When the floor above the basement is air sealed and insulated, doors between the basement and Conditioned Space Volume shall be closed.  Exterior basement access doors, hatches and vents shall be left in their as found position.

 

Comment #12

Page Number: 13
Paragraph / Figure / Table / Note: 4.2.13.1
Comment Intent: Not an Objection
Comment Type: General

Comment:

Why is it important to document where it was sealed? This creates an extra documentation burden for little value, and we recommend removing this language.

Proposed Change:

.4.2.13. Non-dampered oOpenings for ventilation Ventilation, combustion air and make-up air.

4.2.13.1. Each continuously-operating local mechanical exhaust system[1] and continuously-operating Dwelling Unit Mechanical Ventilation System shall be sealed[2] for the duration of the test at the inlet terminal for that fan, at a location within the Ventilation or exhaust duct, at the Ventilation or exhaust equipment itself, or at the outlet terminal for that fan[3], whichever is accessible. The sealing location selected shall be documented.

4.2.13.2. All intermittently-operating local mechanical exhaust systems and intermittently-operating Dwelling Unit Mechanical Ventilation Systems shall not be sealed, including such systems that control the HVAC fan.

4.2.13.3. If a continuously-operating Exhaust Ventilation System is present in the Dwelling Unit, all operable window trickle vents, operable through-the-wall vents, outdoor air intakes with an operable shutoff damper[1], and other operable Ventilation air openings shall be placed in their closed position for the duration of the test, but shall not be sealed.

4.2.11.1.4.2.13.1. Ventilation air openings besides those listed in Section 4.2.13.3 shall be left in their as-found position and shall not be sealed.Non-dampered ventilation openings of intermittently operating local exhaust ventilation systems[2] that connect the Conditioned Space Volume to the exterior or to Unconditioned Space Volume shall be left open.

 

Comment #13

Page Number: 37-38
Paragraph / Figure / Table / Note: 6.4.3.2.1
Comment Intent: Not an Objection
Comment Type: General

Comment:

This should be a preference not a requirement. Time-averaged readings in flex can also be reasonably accurate.

Proposed Change:

6.4.3.2 Procedure to conduct airflow test.

6.4.3.2.1. To facilitate accurate readings, it is preferable to utilize a section of permanently installed smooth-walled ductwork must be installed with a hole that accommodates the test instrument. This length of smooth-walled ductwork shall be visually verified to comply with the airflow measurement instrument’s specifications for minimum distance to both upstream and downstream duct fittings and fan outlets. If an appropriate section of smooth-walled ductwork is unavailable, readings may be taken in a section of flexible ductwork.

6.4.3.2.2. Measurements shall be made across the diameter of the Ventilation duct following manufacturer’s instructions. The velocity measurements, averaged over at least a 10-second period, shall be recorded.

6.4.3.2.3. The airflow measurement instrument manufacturer’s instructions shall be used to covert the measured velocities into volumetric air flow.

6.4.3.2.4. The hot wire anemometer shall be removed and the port sealed with a sheet metal plug or metallic tape.

 

Comment #14

Page Number: 37
Paragraph / Figure / Table / Note: 6.4.2.2
Comment Intent: Not an Objection
Comment Type: General

Comment:

This should be a preference not a requirement. Time-averaged readings in flex can also be reasonably accurate.

Proposed Change:

6.4.2.2. Procedure to conduct airflow test.

6.4.2.2.1. To facilitate accurate readings, it is preferable to utilize a section of permanently installed smooth-walled ductwork must be installed with a hole that accommodates the test instrument. This length of smooth-walled ductwork shall be visually verified to comply with the airflow measurement instrument’s specifications for minimum distance to both upstream and downstream duct fittings and fan outlets. If an appropriate section of smooth-walled ductwork is unavailable, readings may be taken in a section of flexible ductwork.

6.4.2.2.2. The manometer shall be connected to the velocity pressure probe. Measurements shall be made across the diameter of the Ventilation duct following manufacturer’s instructions. A probe that performs pressure averaging across the duct may be used. The pressure measurements, averaged over at least a 10-second period, shall be recorded.

6.4.2.2.3. The airflow measurement instrument manufacturer’s instructions shall be used to covert the measured pressure(s) into volumetric air flow.

6.4.2.2.4. The velocity pressure probe shall be removed and the port sealed with a sheet metal plug or metallic tape.

 

 

 

 

Comment #15

Page Number: 42
Paragraph / Figure / Table / Note: Informative Annex A
Comment Intent: Not an Objection
Comment Type: General

Comment:

There are a number of dwelling units that include basements that do not have insulation/air sealing at the walls nor floor over basement, but otherwise have things like uninsulated leaky ductwork, air handlers, etc. According to the language of 4.2.6.3, these spaces would be excluded from infiltration volume, despite the fact that they are clearly part of the building thermal envelope. This is a step backwards in clarity/consistency; you've undefined a huge swath of buildings with this language.

Proposed Change:

 

Basement is contiguous with and dedicated to subject Dwelling Unit, is not conditioned and is unvented, and its exterior walls are both insulated & air-sealed.