The following comments have been submitted:
Comment #1Page Number: A-1Paragraph / Figure / Table / Note: Section A-1Comment Intent: ObjectionComment Type: GeneralComment: The final paragraph preceding section A-1.1 goes beyond the scope of Standard 301 by specifically seeking to address compliance with IECC energy codes. In accordance with the stated scope, I propose deleting at least those phrases relating to the IECC. However, the remainder of this paragraph is largely duplicative of the preceding paragraph, and so might better be struck entirely. Proposed Change: When inspecting the installation of insulation for compliance with the IECC, installations not complying with manufacturer’s installation instructions, the minimum installation requirements of the IECC, this Appendix, the relevant ASTM standard for the type of insulation, or the Grade I coverage requirements shall not be modeled as Grade I.
The final paragraph preceding section A-1.1 goes beyond the scope of Standard 301 by specifically seeking to address compliance with IECC energy codes. In accordance with the stated scope, I propose deleting at least those phrases relating to the IECC. However, the remainder of this paragraph is largely duplicative of the preceding paragraph, and so might better be struck entirely.
When inspecting the installation of insulation for compliance with the IECC, installations not complying with manufacturer’s installation instructions, the minimum installation requirements of the IECC, this Appendix, the relevant ASTM standard for the type of insulation, or the Grade I coverage requirements shall not be modeled as Grade I.
Comment #2Page Number: pp 44-45Paragraph / Figure / Table / Note: Section 4.2.2.1 and Table 4.2.2(6)Comment Intent: ObjectionComment Type: TechnicalComment: The content in Std 301 regarding Framing Fractions should only be applicable to wood-framed assemblies. For steel-framed assemblies, the Standard specifies that the modified zone method be used (per section 4.2.2.3.2). The Framing Fractions of Table 4.2.2(6) are not appropriate in the modified zone method. Thus, the Framing Fraction requirements of Section 4.2.2.1 and Table 4.2.2(6) should be restricted to wood-framed assemblies. In the following proposed change, I have only modified the red text. However, if my proposed change is accepted, the entire Section should be reviewed to clarify that the Framing Fraction specifications only apply to wood-framed assemblies. Proposed Change: 4.2.2.1. A framing fraction shall be designated for each segment of framed wall, floor, and ceiling assembly that separates one space type from another type or the exterior[1]. A wall segment is defined as a planar section bounded side-to-side by the wall corners and top-to-bottom by the top plate and bottom plate. A floor segment is defined as a planar section bounded by rim or band joists. A ceiling segment is defined as a planar section bounded by exterior top plates, eves, or gables. If different framing fractions are designated for different segments of the framed wall, floor, or ceiling assembly, then multiple entries are permitted to be entered into the rating software. Alternatively, the entire assembly can be modeled with the highest designated framing fraction. For ratings where the framing is not visible at the time of the site inspection, the framing fractions shall equal the highest default framing fraction for the assembly component listed in Table 4.2.2(56). For ratings where the framing is visible at the time of the site inspection, floor and ceiling assemblies shall use the default framing fractions for their framing spacing listed in Table 4.2.2(56). Wall assemblies shall use the default framing fractions for their framing spacing and the Standard framing type listed in Table 4.2.2(56), unless the wall assembly is a Structural Insulated Pane, or a steel-framed wall, or the conditions in Section 4.2.2.1.1 or Section 4.2.2.1.2 have been met. The default framing fractions for the Advanced framing type are permitted to be used if the wall segment complies with all the following conditions: Corners of cavities shall be completely filled with ≥ R-6[2] insulation. Intersections with interior walls shall be insulated to the same R-value as the remainder of the wall assembly.[3] Headers of frame walls shall be insulated ≥ R-3 for 2x4 framing or equivalent cavity width, and ≥ R-5 for all other assemblies[4], where the R-value requirement refers to the manufacturer’s nominal insulation value[5]. The framing shall be limited at all windows & doors to one pair of king studs, plus one pair of jack studs per window opening to support the header and sill. The assembly-specific framing fraction or 10%, whichever is larger, is permitted to be used if a framing plan with the design framing fraction and a professional engineer’s stamp has been obtained and the framing plan has been verified to match the actual assembly in field.[6] Table 4.2.2(6) Default Framing Fractions for Wood-framed Assembly Components Assembly Component Framing Spacing (Inches On-Center) Framing Type Default Framing Fraction (% Area) Wall 16 Standard 25% 16 Advanced 19% 24 Standard 22% 24 Advanced 16% n/a Structural Insulated Panel 10% Floor 16 n/a 13% 24 n/a 10% Ceiling 16 n/a 10% 24 n/a 7% [1] (Informative Note) For example, that separates a Conditioned Space Volume from an Unconditioned Space Volume, Unrated Heated Space, Non-Freezing Space, a Multifamily Buffer Boundary, or the exterior. [2] (Informative Note) Examples of compliance options include standard-density insulation with alternative framing techniques, such as using three studs per corner, or high-density insulation with standard framing techniques. [3] (Informative Note) Examples of compliance options include ladder blocking, full length 2x6 or 1x6 furring behind the first partition stud, or drywall clips. [4] (Informative Note) For example, with 2x6 framing. [5] (Informative Note) Examples of compliance options include continuous rigid insulation sheathing, SIP headers, other prefabricated insulated headers, or single-member or two-member headers with insulation either in between or on one side. [6] (Informative Note) For example, a SIP wall or other engineered framed wall is permitted to use a framing fraction better than the defaults in table 4.2.2(56) if it meets the requirements of this section.
The content in Std 301 regarding Framing Fractions should only be applicable to wood-framed assemblies. For steel-framed assemblies, the Standard specifies that the modified zone method be used (per section 4.2.2.3.2). The Framing Fractions of Table 4.2.2(6) are not appropriate in the modified zone method.
Thus, the Framing Fraction requirements of Section 4.2.2.1 and Table 4.2.2(6) should be restricted to wood-framed assemblies. In the following proposed change, I have only modified the red text. However, if my proposed change is accepted, the entire Section should be reviewed to clarify that the Framing Fraction specifications only apply to wood-framed assemblies.
4.2.2.1. A framing fraction shall be designated for each segment of framed wall, floor, and ceiling assembly that separates one space type from another type or the exterior[1].
A wall segment is defined as a planar section bounded side-to-side by the wall corners and top-to-bottom by the top plate and bottom plate. A floor segment is defined as a planar section bounded by rim or band joists. A ceiling segment is defined as a planar section bounded by exterior top plates, eves, or gables. If different framing fractions are designated for different segments of the framed wall, floor, or ceiling assembly, then multiple entries are permitted to be entered into the rating software. Alternatively, the entire assembly can be modeled with the highest designated framing fraction.
For ratings where the framing is not visible at the time of the site inspection, the framing fractions shall equal the highest default framing fraction for the assembly component listed in Table 4.2.2(56).
For ratings where the framing is visible at the time of the site inspection, floor and ceiling assemblies shall use the default framing fractions for their framing spacing listed in Table 4.2.2(56). Wall assemblies shall use the default framing fractions for their framing spacing and the Standard framing type listed in Table 4.2.2(56), unless the wall assembly is a Structural Insulated Pane, or a steel-framed wall, or the conditions in Section 4.2.2.1.1 or Section 4.2.2.1.2 have been met.
Table 4.2.2(6) Default Framing Fractions for Wood-framed Assembly Components
Assembly Component
Framing Spacing
(Inches On-Center)
Framing Type
Default Framing Fraction
(% Area)
Wall
16
Standard
25%
Advanced
19%
24
22%
16%
n/a
Structural Insulated Panel
10%
Floor
13%
Ceiling
7%
[1] (Informative Note) For example, that separates a Conditioned Space Volume from an Unconditioned Space Volume, Unrated Heated Space, Non-Freezing Space, a Multifamily Buffer Boundary, or the exterior.
[2] (Informative Note) Examples of compliance options include standard-density insulation with alternative framing techniques, such as using three studs per corner, or high-density insulation with standard framing techniques.
[3] (Informative Note) Examples of compliance options include ladder blocking, full length 2x6 or 1x6 furring behind the first partition stud, or drywall clips.
[4] (Informative Note) For example, with 2x6 framing.
[5] (Informative Note) Examples of compliance options include continuous rigid insulation sheathing, SIP headers, other prefabricated insulated headers, or single-member or two-member headers with insulation either in between or on one side.
[6] (Informative Note) For example, a SIP wall or other engineered framed wall is permitted to use a framing fraction better than the defaults in table 4.2.2(56) if it meets the requirements of this section.
Comment #3Page Number: 23-24Paragraph / Figure / Table / Note: 4.2.2, Table 4.2.2(1)Comment Intent: ObjectionComment Type: GeneralComment: I am the chair of the CRRC Ratings, Codes and Standards Committee, and I have been authorized to present this comment on behalf of the Cool Roof Rating Council (CRRC) by Mr. Jeffrey Steuben, Executive Director (jeff@coolroofs.org). The CRRC is proposing that the CRRC Normative Note be modified from stating Appendix “9” to read as Appendix “8.” The CRRC Board of Directors recently (June 2021) approved further modifications to the CRRC-1 Program Manual that affected the numbering of the appendices. The appendix number for the "Standard Test Method for Determining the Directional-Hemispherical Solar Reflectance of Materials Using a Directional-Hemispherical Portable Reflectometer" in the CRRC-1 Program Manual has changed. The test method is now contained in Appendix 8 of the CRRC-1 Program Manual (it's no longer in Appendix 9). The CRRC’s goal in this public comment is to ensure that the RESNET 301 Standard be up to date as possible, therefore we are asking that the appendix number designation be modified as shown in the modification below. A copy of the CRRC-1 Program is included as a separate attachment for reference. Proposed Change: TABLE 4.2.2(1) Specifications for the Energy Rating Reference and Rated Homes Building Component: Above Grade Walls 27 (Normative Note) Solar Reflectance is permitted to be measured in accordance with the CRRC-1 Product Rating Program Manual Appendix 9 8 “Standard Test Method for Determining the Directional-Hemispherical Solar Reflectance of Materials Using a Directional-Hemispherical Portable Reflectometer” with the ASTM G197 air-mass 1.5 sun-facing global vertical solar spectral irradiance.
I am the chair of the CRRC Ratings, Codes and Standards Committee, and I have been authorized to present this comment on behalf of the Cool Roof Rating Council (CRRC) by Mr. Jeffrey Steuben, Executive Director (jeff@coolroofs.org).
The CRRC is proposing that the CRRC Normative Note be modified from stating Appendix “9” to read as Appendix “8.” The CRRC Board of Directors recently (June 2021) approved further modifications to the CRRC-1 Program Manual that affected the numbering of the appendices. The appendix number for the "Standard Test Method for Determining the Directional-Hemispherical Solar Reflectance of Materials Using a Directional-Hemispherical Portable Reflectometer" in the CRRC-1 Program Manual has changed. The test method is now contained in Appendix 8 of the CRRC-1 Program Manual (it's no longer in Appendix 9).
The CRRC’s goal in this public comment is to ensure that the RESNET 301 Standard be up to date as possible, therefore we are asking that the appendix number designation be modified as shown in the modification below. A copy of the CRRC-1 Program is included as a separate attachment for reference.
TABLE 4.2.2(1) Specifications for the Energy Rating Reference and Rated Homes
Building Component: Above Grade Walls
27 (Normative Note) Solar Reflectance is permitted to be measured in accordance with the CRRC-1 Product Rating Program Manual Appendix 9 8 “Standard Test Method for Determining the Directional-Hemispherical Solar Reflectance of Materials Using a Directional-Hemispherical Portable Reflectometer” with the ASTM G197 air-mass 1.5 sun-facing global vertical solar spectral irradiance.
Comment #4Page Number: 118Paragraph / Figure / Table / Note: Section 8, Informative ReferencesComment Intent: ObjectionComment Type: GeneralComment: I am the chair of the CRRC Ratings, Codes and Standards Committee, and I have been authorized to present this comment on behalf of the Cool Roof Rating Council (CRRC) by Mr. Jeffrey Steuben, Executive Director (jeff@coolroofs.org). The CRRC is proposing that the CRRC informative reference be modified from stating Appendix “9” to read as Appendix “8.” The CRRC Board of Directors recently (June 2021) approved further modifications to the CRRC-1 Program Manual that affected the numbering of the appendices. The appendix number for the "Standard Test Method for Determining the Directional-Hemispherical Solar Reflectance of Materials Using a Directional-Hemispherical Portable Reflectometer" in the CRRC-1 Program Manual has changed. The test method is now contained in Appendix 8 of the CRRC-1 Program Manual (it's no longer in Appendix 9). The CRRC’s goal in this public comment is to ensure that the RESNET 301 Standard be up to date as possible, therefore we are asking that the appendix number designation be modified as shown in the modification below. The CRRC-1 Program can be found at: https://coolroofs.org/documents/CRRC-1_Program_Manual.pdf Proposed Change: 8. Informative References Cool Roof Rating Council, CRRC-1 Product Rating Program Manual, Appendix 9 8 , 2001. Portland, OR, www.coolroofs.org
The CRRC is proposing that the CRRC informative reference be modified from stating Appendix “9” to read as Appendix “8.” The CRRC Board of Directors recently (June 2021) approved further modifications to the CRRC-1 Program Manual that affected the numbering of the appendices. The appendix number for the "Standard Test Method for Determining the Directional-Hemispherical Solar Reflectance of Materials Using a Directional-Hemispherical Portable Reflectometer" in the CRRC-1 Program Manual has changed. The test method is now contained in Appendix 8 of the CRRC-1 Program Manual (it's no longer in Appendix 9).
The CRRC’s goal in this public comment is to ensure that the RESNET 301 Standard be up to date as possible, therefore we are asking that the appendix number designation be modified as shown in the modification below. The CRRC-1 Program can be found at: https://coolroofs.org/documents/CRRC-1_Program_Manual.pdf
8. Informative References
Cool Roof Rating Council, CRRC-1 Product Rating Program Manual, Appendix 9 8 , 2001. Portland, OR, www.coolroofs.org
Comment #5Page Number: B-18Paragraph / Figure / Table / Note: Normative Appendix BComment Intent: ObjectionComment Type: GeneralComment: I am the chair of the CRRC Ratings, Codes and Standards Committee, and I have been authorized to present this comment on behalf of the Cool Roof Rating Council (CRRC) by Mr. Jeffrey Steuben, Executive Director (jeff@coolroofs.org). The CRRC is proposing that the CRRC Normative Note be modified from stating Appendix “9” to read as Appendix “8.” The CRRC Board of Directors recently (June 2021) approved further modifications to the CRRC-1 Program Manual that affected the numbering of the appendices. The appendix number for the "Standard Test Method for Determining the Directional-Hemispherical Solar Reflectance of Materials Using a Directional-Hemispherical Portable Reflectometer" in the CRRC-1 Program Manual has changed. The test method is now contained in Appendix 8 of the CRRC-1 Program Manual (it's no longer in Appendix 9). The CRRC’s goal in this public comment is to ensure that the RESNET 301 Standard be up to date as possible, therefore we are asking that the appendix number designation be modified as shown in the modification below. The CRRC-1 Program can be found at: https://coolroofs.org/documents/CRRC-1_Program_Manual.pdf Proposed Change: Building Element: Wall Assembly, Footnote 103 Rated Feature: Color Category: On-Site Inspection Protocol 103 (Normative Note) Solar Reflectance is permitted to be measured in accordance with the CRRC-1 Product Rating Program Manual Appendix 9 8 “Standard Test Method for Determining the Directional-Hemispherical Solar Reflectance of Materials Using a Directional-Hemispherical Portable Reflectometer” with the ASTM G197 air-mass 1.5 sun-facing global vertical solar spectral irradiance.
Building Element: Wall Assembly, Footnote 103
Rated Feature: Color
Category: On-Site Inspection Protocol
103 (Normative Note) Solar Reflectance is permitted to be measured in accordance with the CRRC-1 Product Rating Program Manual Appendix 9 8 “Standard Test Method for Determining the Directional-Hemispherical Solar Reflectance of Materials Using a Directional-Hemispherical Portable Reflectometer” with the ASTM G197 air-mass 1.5 sun-facing global vertical solar spectral irradiance.
Comment #6Page Number: pp 46-48Paragraph / Figure / Table / Note: Section 4.2.2.2Comment Intent: Not an ObjectionComment Type: GeneralComment: The new section 4.2.2.2 provides a standardized mechanism to automate the effective R-value calculation for attic insulation whose depth is restricted by a sloping roof. Unfortunately, it involves a number of parameters that are not Minimum Rated Features, and so relies on specifying default values for those parameters. If this standardized mechanism is important enough to embody in the Standard, then those parameters ought to be considered Minimum Rated Features. The equations in this section would probably be a little less opaque if the concepts of U-factor and UA product were employed. My key points for making this section viable are as follows: Using the label "kVal" for thermal resistivity is confusing, given that "k" is the conventional notation for thermal conductivity, which is the reciprocal of thermal resistivity. Perhaps "invK" would be a better label; it certainly would have confused me less! Eq. 4.2-1a appears to have an extra opening parenthesis before "insH". The roof slope is not a Minimum Rated Feature, and so needs a default value. I recommend 5:12. The eaveL default calculation relies on data about the shape of a given attic, which is not typically a software input. Default choices for the shape (length:width ratio) may be necessary. Alternatively, the section could make clear that it is sufficient for the Rater to simply identify the total area eaveA that is subject to this insulation depth restriction. It is not clear whether the default values for eaveH are factoring in the effect of an eave vent baffle. It is probably also important to create criteria for when these assumptions are invalid -- such as when eave vent baffles are improperly installed, creating even more compression over the exterior wall.
The new section 4.2.2.2 provides a standardized mechanism to automate the effective R-value calculation for attic insulation whose depth is restricted by a sloping roof. Unfortunately, it involves a number of parameters that are not Minimum Rated Features, and so relies on specifying default values for those parameters. If this standardized mechanism is important enough to embody in the Standard, then those parameters ought to be considered Minimum Rated Features.
The equations in this section would probably be a little less opaque if the concepts of U-factor and UA product were employed.
My key points for making this section viable are as follows:
Comment #7Page Number: 24Paragraph / Figure / Table / Note: Table 4.2.2(1), 2nd rowComment Intent: ObjectionComment Type: EditorialComment: The second row of Table 4.2.2(1) specifies how to configure the Reference Home walls that face a multifamily space type, when that space type is not fully conditioned. That specification references tables within the 2004 version of ASHRAE 90.1. The use of the 2004 version of Std 90.1 is understandable, since Standard 301 uses the 2006 IECC as the basis of the ERI Reference Home. Std 90.1-2004 is the version that was current at that point in time. However, referencing an archaic standard for such a substantial part of the Reference Home configuration essentially forces people to purchase an archaic standard, simply to understand how the ERI Reference Home shall be configured. I believe those tables should be reproduced within Std 301, or perhaps RESNET can arrange to make those tables from Std 90.1-2004 freely viewable online in conjunction with the web viewer for Standard 301.
The second row of Table 4.2.2(1) specifies how to configure the Reference Home walls that face a multifamily space type, when that space type is not fully conditioned. That specification references tables within the 2004 version of ASHRAE 90.1.
The use of the 2004 version of Std 90.1 is understandable, since Standard 301 uses the 2006 IECC as the basis of the ERI Reference Home. Std 90.1-2004 is the version that was current at that point in time.
However, referencing an archaic standard for such a substantial part of the Reference Home configuration essentially forces people to purchase an archaic standard, simply to understand how the ERI Reference Home shall be configured.
I believe those tables should be reproduced within Std 301, or perhaps RESNET can arrange to make those tables from Std 90.1-2004 freely viewable online in conjunction with the web viewer for Standard 301.
Comment #8Page Number: 40Paragraph / Figure / Table / Note: Table 4.2.2(1) Note xComment Intent: ObjectionComment Type: TechnicalComment: x. When both of the following conditions are met and documented, duct leakage testing is not required. At a pre-drywall stage of construction, 100 percent of the ductwork and airhandler shall be visible and visually verified to be contained inside the Conditioned Space Volume. At a final stage of construction, ductwork that is visible and the air handler shall be verified again to be contained in the Conditioned Space Volume. At a pre-drywall stage of construction, the ductwork shall be visually verified to be 100 percent fully ducted with no building cavities used as supply or return ducts. To calculate the energy impacts on the Rated Home, a DSE of 0.88 shall be applied to both the heating and cooling system efficiencies. A DSE of 1.0 may be applied if the total supply duct length of the system, including all supply trunks and branches, is ≤ 10 ft. As an alternative to the DSE = 0.88, a value of 4 cfm per 100 square feet of Conditioned Floor Area may be modeled for duct leakage to outside if the above conditions are met and no ductwork is contained within envelope assemblies adjacent to the exterior or Unconditioned Space Volumes. While this is a step in the right direction based on years of Leakage to the Outside testing results, it still penalizes duct systems in wall cavities and floor over garage even if they comply with section R403.3.2 of the 2021 IECC as stated below. 3. Ductwork in floor cavities located over unconditioned space shall comply with all of the following: 3.1. A continuous air barrier installed between unconditioned space and the duct. 3.2. Insulation installed in accordance with Section R402.2.7. 3.3. A minimum R-19 insulation installed in the cavity width separating the duct from unconditioned space. 4. Ductwork located within exterior walls of the building thermal envelope shall comply with the following: 4.1. A continuous air barrier installed between unconditioned space and the duct. 4.2. Minimum R-10 insulation installed in the cavity width separating the duct from the outside sheathing. 4.3. The remainder of the cavity insulation shall be fully insulated to the drywall side RESNET is working to integrate with IECC code compliance, therefore they should reference code sections to determine the effects of duct leakage to the outside. If the above items are met, testing results for leakage to the outside will be well below the penalty applied by using the .88 DSE. Proposed Change: RECOMMENDATION Allow the 4 CFM per 100 square feet of Conditioned Floor area alternative to be applied as the alternative to .88 DSE when all conditions in Section 403.3.2 item 3 and 4 are met.
x. When both of the following conditions are met and documented, duct leakage testing is not required.
To calculate the energy impacts on the Rated Home, a DSE of 0.88 shall be applied to both the heating and cooling system efficiencies. A DSE of 1.0 may be applied if the total supply duct length of the system, including all supply trunks and branches, is ≤ 10 ft. As an alternative to the DSE = 0.88, a value of 4 cfm per 100 square feet of Conditioned Floor Area may be modeled for duct leakage to outside if the above conditions are met and no ductwork is contained within envelope assemblies adjacent to the exterior or Unconditioned Space Volumes.
While this is a step in the right direction based on years of Leakage to the Outside testing results, it still penalizes duct systems in wall cavities and floor over garage even if they comply with section R403.3.2 of the 2021 IECC as stated below.
3. Ductwork in floor cavities located over unconditioned space shall comply with all of the following:
3.1. A continuous air barrier installed between unconditioned space and the duct.
3.2. Insulation installed in accordance with Section R402.2.7.
3.3. A minimum R-19 insulation installed in the cavity width separating the duct from unconditioned space.
4. Ductwork located within exterior walls of the building thermal envelope shall comply with the following:
4.1. A continuous air barrier installed between unconditioned space and the duct.
4.2. Minimum R-10 insulation installed in the cavity width separating the duct from the outside sheathing.
4.3. The remainder of the cavity insulation shall be fully insulated to the drywall side
RESNET is working to integrate with IECC code compliance, therefore they should reference code sections to determine the effects of duct leakage to the outside. If the above items are met, testing results for leakage to the outside will be well below the penalty applied by using the .88 DSE.
RECOMMENDATION
Allow the 4 CFM per 100 square feet of Conditioned Floor area alternative to be applied as the alternative to .88 DSE when all conditions in Section 403.3.2 item 3 and 4 are met.
Comment #9Page Number: 41Paragraph / Figure / Table / Note: Table 4.2.2(1) Note yyComment Intent: ObjectionComment Type: TechnicalComment: yy. When the air distribution system leakage split between the supply and return side is not measured, the air distribution system leakage to outdoors at 25 Pascal pressure difference shall be split equally between the supply and return side of the air distribution system with the leakage distributed evenly across the duct system. Experience shows that leakage to the outside does not happen equally over the entire system. When all supplies are located within the thermal boundary and a small portion of the return is located in the attic, that return may be responsible for the entire quantity of leakage to the outside. Proposed Change: RECOMMENDATION Air leakage to the outside should be allocated based on location of duct work rather than an equal split.
yy. When the air distribution system leakage split between the supply and return side is not measured, the air distribution system leakage to outdoors at 25 Pascal pressure difference shall be split equally between the supply and return side of the air distribution system with the leakage distributed evenly across the duct system.
Experience shows that leakage to the outside does not happen equally over the entire system. When all supplies are located within the thermal boundary and a small portion of the return is located in the attic, that return may be responsible for the entire quantity of leakage to the outside.
Air leakage to the outside should be allocated based on location of duct work rather than an equal split.
Comment #10Page Number: 46-48Paragraph / Figure / Table / Note: Section 4.2.2.2 - Attic Eave calculationsComment Intent: Not an ObjectionComment Type: GeneralComment: We need to be able to see examples and understand the impact of this update if we are to comment with any kind of authority. We don’t know if this is an update to software and we are just entering values or are we expected to calculate the actual insulation value based on these formulas? Proposed Change: RECOMMENDATION Recent updates to software and energy modeling calculations have changed the HERS index and code compliance results dramatically without warning. When updating formulas or calculations, provide examples of calculations based on actual insulation and eave heights along with the impact on the HERS index as well as code compliance.
We need to be able to see examples and understand the impact of this update if we are to comment with any kind of authority. We don’t know if this is an update to software and we are just entering values or are we expected to calculate the actual insulation value based on these formulas?
Recent updates to software and energy modeling calculations have changed the HERS index and code compliance results dramatically without warning. When updating formulas or calculations, provide examples of calculations based on actual insulation and eave heights along with the impact on the HERS index as well as code compliance.