The following comments have been submitted:
Comment #1Page Number: 4.2.2.2.2Paragraph / Figure / Table / Note: DRAFT PDS-01 BSR/RESNET/ICC 301-2019 Addendum E-202xComment Intent: ObjectionComment Type: GeneralComment: In 5 years of inspecting homes I cannot remember a single home where the insulation installation was poor enough to justify modeling 10% as R-0. This addendum seems unnecesarily harsh upon first glance. Proposed Change: Model 5% as R-0. Previously if more than 5% was missing it was to be modeled separately, so even this is failry harsh.
In 5 years of inspecting homes I cannot remember a single home where the insulation installation was poor enough to justify modeling 10% as R-0.
This addendum seems unnecesarily harsh upon first glance.
Model 5% as R-0. Previously if more than 5% was missing it was to be modeled separately, so even this is failry harsh.
Comment #2Page Number: p3 of the Word docParagraph / Figure / Table / Note: Normative Appendix AComment Intent: ObjectionComment Type: GeneralComment: First, I applaud the effort to overhaul the Standards language for Insulation Grading. I believe, however, that the effort needs to clean up some additional issues. My premise is that Insulation Grading is fundamentally about trying to represent how well the insulation (or radiant barrier) functions, as actually installed. This is consistent with how Insulation Grading is represented in the simulation – that is, as a void area for 0%, 2%, or 5% (or in proposed Addm E, 10%) of the area nominally covered by that insulation (or radiant barrier). However, the Std 301 specifications of ideal installation have other stuff entangled in them. For instance: Infiltration. If the insulation material is a mineral fiber, then fully enclosing it in an air barrier is indeed important for it to provide a fully-effective R-value. However, that is not true for SPF or EPS or XPS or polyisocyanurate. Although products like XPS can function as a Weather-Resistive Barrier, that is not how we model the product; it is modeled as a thermal resistance. And since Raters do a blower door test to measure the actual building leakage, so Grading an installation for the WRB traits is tantamount to double-counting the deficiency. Code requirements. Std 301 is about assigning an ERI to what is actually installed, not enforcing some code's "required R-Value." It should not be applying specific code-required thresholds for R-value in the Rated Home insulation grading criteria (as happens in multiple places, e.g. Addendum B's A-1.2 first Exception, or in proposed Addendum E's sections 1-1.1.4.5, 1-1.1.4.6, and 1-1.4.7.1, etc.). Nor should it be talking about whether code requires foam sheathing to be installed in multiple layers with staggered joints (section A-1.8.2.2 under 1-1.8.2). Other functions. The Grading of insulation installation thermal resistance has nothing to do with whether a given insulation product functions as a vapor retarder, as happens in section 1-1.4.2.2. And so on. Lastly, why do we reference 6 different ASTM standards for installation practices (at a current cost of $267), expecting Raters to know all the details of installation? We really only need for them to know how to observe if it appears to have been done correctly, which means that expecting them to read and know the content of those 6 standards is overkill and unreasonable. I believe Appendix A requires comprehensive re-work from the focused perspective I outlined at the top as my premise.
First, I applaud the effort to overhaul the Standards language for Insulation Grading. I believe, however, that the effort needs to clean up some additional issues.
My premise is that Insulation Grading is fundamentally about trying to represent how well the insulation (or radiant barrier) functions, as actually installed. This is consistent with how Insulation Grading is represented in the simulation – that is, as a void area for 0%, 2%, or 5% (or in proposed Addm E, 10%) of the area nominally covered by that insulation (or radiant barrier).
However, the Std 301 specifications of ideal installation have other stuff entangled in them. For instance:
Lastly, why do we reference 6 different ASTM standards for installation practices (at a current cost of $267), expecting Raters to know all the details of installation? We really only need for them to know how to observe if it appears to have been done correctly, which means that expecting them to read and know the content of those 6 standards is overkill and unreasonable.
I believe Appendix A requires comprehensive re-work from the focused perspective I outlined at the top as my premise.
Comment #3Page Number: 11Paragraph / Figure / Table / Note: 1-1.3.1.2 and 1-1.4.1.3Comment Intent: Not an ObjectionComment Type: TechnicalComment: New item proposal. The MD and LD spray foam insulation sections that describe the verification of cavity thickness should require specific guidance when applied to underside of roof decks. Proposed Change: Suggest the following lanugae added as item e) and f) respectively in each section: When SPF is to be applied to the underside of roofing to create an enclosed attic, insulation depth markers shall be applied with the 0 line against the roof deck extending to the attic area. These shall be installed at a rate of 1 per 300 square feet prior to SPF insulation installation.
New item proposal. The MD and LD spray foam insulation sections that describe the verification of cavity thickness should require specific guidance when applied to underside of roof decks.
Suggest the following lanugae added as item e) and f) respectively in each section:
When SPF is to be applied to the underside of roofing to create an enclosed attic, insulation depth markers shall be applied with the 0 line against the roof deck extending to the attic area. These shall be installed at a rate of 1 per 300 square feet prior to SPF insulation installation.
Comment #4Page Number: 7Paragraph / Figure / Table / Note: 1-1.1.5.4.1Comment Intent: ObjectionComment Type: GeneralComment: Comment referenced above refers to a rim joist needing to be "insulated per exterior wall insulation". In reality this comment is both ambiguous as well as incorrect. Rim joists can be insulated to a different value than exterior walls due to a larger "cavity" depth or other designer specific reasons. Separately, aligning with exterior walls is also ambiguous because walls may be specified based upon code prescribed minimums OR energy model required edicts. Proposed Change: I recommend that this passage be rewritte to state "All rim joists shall be insulated to the same R-value as the exterior walls insulation specified in the project's energy model or local prescriptive code requirement." Any reference to a space being "insulated per <insert assembly name here>" be instead labeled "...as specified in the project's energy model or local prescriptive code requirement."
Comment referenced above refers to a rim joist needing to be "insulated per exterior wall insulation". In reality this comment is both ambiguous as well as incorrect. Rim joists can be insulated to a different value than exterior walls due to a larger "cavity" depth or other designer specific reasons. Separately, aligning with exterior walls is also ambiguous because walls may be specified based upon code prescribed minimums OR energy model required edicts.
I recommend that this passage be rewritte to state "All rim joists shall be insulated to the same R-value as the exterior walls insulation specified in the project's energy model or local prescriptive code requirement."
Any reference to a space being "insulated per <insert assembly name here>" be instead labeled "...as specified in the project's energy model or local prescriptive code requirement."
Comment #5Page Number: AllComment Intent: ObjectionComment Type: GeneralComment: The change from a 3 grades system to pass/fail is a backwards movement will make it harder for QADs to complete their job. As a QAD and Rater I think that the change work in a couple ways. I think raters will take a bit of time to get re-trained on how to correctly be grading insulation according to RESNET Standards From a programatic standpoint, grading has been worked into many programs, either requiring grade 1 or grade 2 as being a part of certification As a QAD, I think that removing a 3rd grade, will make it harder to have common ground to find with raters when there may be a dissagreement on insulation install quality. Lastly, I think that insulation grading (for me) has been 1 aspect of being a rater that has not changed in all my time in this field, and I get the general monicer that change is good, but I think this change will not help the industry. Insulation grading is one of the most tried and true and understood parts of completing a HERS Rating, and going to a pass/fail is not something that should be accepted.
The change from a 3 grades system to pass/fail is a backwards movement will make it harder for QADs to complete their job. As a QAD and Rater I think that the change work in a couple ways.
Comment #6Page Number: 1Paragraph / Figure / Table / Note: 4.2.2.2.2 Section CComment Intent: ObjectionComment Type: EditorialComment: The Enclosure subcommittee finds the language confusion and recommends that RESNET consider adding some terms to the definition section of the 301 standards. Example of a terms that may need to be defined from this section would be “Areas” and “Assembly”. There are other terms within the new appendix A that could warrant definition as well but we did not list them all out. In this section we think that the section could be reworded to make it more clear. Proposed Change: Areas of an Assembies having different insulation types or R-Values (including uninsulated areas in excess of 5 percent of any otherwise insulated building component) shall be modeled separately with the applicable R-Values and assembly areas associated with each different insulation situation.
The Enclosure subcommittee finds the language confusion and recommends that RESNET consider adding some terms to the definition section of the 301 standards. Example of a terms that may need to be defined from this section would be “Areas” and “Assembly”. There are other terms within the new appendix A that could warrant definition as well but we did not list them all out.
In this section we think that the section could be reworded to make it more clear.
Comment #7Page Number: 3Paragraph / Figure / Table / Note: 1-1.1.1 Insulation R-value AssessmentComment Intent: Not an ObjectionComment Type: EditorialComment: Base R-value is a new concept and an example of a term that should either be defined or it was brought up in our discussion that “nominal” R-value might be a better term to use.
Base R-value is a new concept and an example of a term that should either be defined or it was brought up in our discussion that “nominal” R-value might be a better term to use.
Comment #8Page Number: 3Paragraph / Figure / Table / Note: 1-1.1.2 Air Barrier RequirementsComment Intent: ObjectionComment Type: TechnicalComment: The Enclosure Subcommittee believes that six-sided air barriers are need at rim joist and on the unconditioned side of knee walls when fibrous insulation is installed. They are particularly needed in areas that are difficult to install insulation and inspect. We recommend removing exceptions C and D. Proposed Change: 1-1.1.1.1 Insulation shall be enclosed with an air barrier on all six sides with permanent materials except for the following: a.Insulation installed in vented attics above ceilings shall not require an air barrier on the exterior side. b.Insulation installed under floors directly above an unvented crawl space or basement shall not require an air barrier on the side facing the crawl space or basement. c.Insulation installed in rim or band joists located in conditioned space shall not require an air barrier on the interior side. d.Insulation installed in knee walls shall not require an air barrier on the exterior side.
The Enclosure Subcommittee believes that six-sided air barriers are need at rim joist and on the unconditioned side of knee walls when fibrous insulation is installed. They are particularly needed in areas that are difficult to install insulation and inspect. We recommend removing exceptions C and D.
Comment #9Page Number: 4Paragraph / Figure / Table / Note: 1-1.1.3.7 Special Situations--Kneewalls and Skylight ShaftsComment Intent: ObjectionComment Type: TechnicalComment: This section discusses framing around knee walls and above it discusses air barriers and six-sided enclosure. We don’t understand why it is broken up in separate sections. We believe that it could be made clearer if there is additional language added here that discusses conditioned and unconditioned spaces. Proposed Change: 1-1.1.1.1.1 Insulation for all kneewall and skylight shafts shall be completely enclosed by vertical and horizontal framing, including horizontal plates at top and bottom of the insulation as well as continuous air barrier sheathing on the conditioned and unconditioned side of the knee wall or skylight shaft wall assembly.
This section discusses framing around knee walls and above it discusses air barriers and six-sided enclosure. We don’t understand why it is broken up in separate sections. We believe that it could be made clearer if there is additional language added here that discusses conditioned and unconditioned spaces.
Comment #10Page Number: 7Paragraph / Figure / Table / Note: 1-1.2.1 Insulation R-value AssessmentComment Intent: ObjectionComment Type: EditorialComment: The Subcommittee believes that in this section and in others throughout the appendix, that use the term “required” R-value should be edited because a RESNET HERS Energy Rating Index is an asset rating that is not looking for a required or specific R-value. We think that the word “rated” could replace required to convey the concept. Proposed Change: 1-1.1.1.1 Insulation shall be installed to the density and thickness required to attain the required rated R-Value.
The Subcommittee believes that in this section and in others throughout the appendix, that use the term “required” R-value should be edited because a RESNET HERS Energy Rating Index is an asset rating that is not looking for a required or specific R-value. We think that the word “rated” could replace required to convey the concept.
Comment #11Page Number: 1Paragraph / Figure / Table / Note: 4.2.2.2.2 Appendix AComment Intent: Not an ObjectionComment Type: GeneralComment: I am writing in support of the move to Proper insulation installation PII and Not proper installation NPI and away from the 1,2,3 grading system. The move does the following: It established a clear pass-fail criteria with no ambiguous middle ground that confuses installers, inspectors and Raters. It is either done correctly or it is not there should not be an exception. It better aligns with the IECC and manufacture instructions for the installation of insulation. We can now clearly point to an ANSI standard for how to install insulation that meets the requirements of the ICC for inclusion in code language. As Raters are asked to evaluate insulation installation for IECC, programs and HERS ERI scores it created one clear system that can be used across the board. Properly installed insulation passes for everything. Now we have some programs that are allowing Grade 2 and we have Rates doing code compliant rating that are using grade 2 and 3. This appendix change ensures a consistent interpretation of proper installation that works. Moving from a 5% to a 10% no insulation installed in the assembly when modeling NPI is a small increase for the penalty for poorly installed insulation that will continued to have a meaningful effect of changing the installation industries perception about the importance of doing the job correctly. This penalty will be reflected in the HERS ERI score as it should. If the house is also doing a program such as EnergyStar or IECC compliance rating it should never be able to pass with NPI installation in the first place. So, this change will only be applicable to homes that are only getting a HERS ERI score and complying with nothing else. Research from Southface: R13 assembly 16”oc framing (no void) R11.8, (5% voids) R10.8 (10% voids) R9.2 PII insulation installations follow manufacture installation instructions. Aligning this appendix with manufacture instruction will help the industry move forward on the same page. Industry will rework out of date brochures, training and messaging will be more consistent, and inspection and enforcement will be more consistent.
I am writing in support of the move to Proper insulation installation PII and Not proper installation NPI and away from the 1,2,3 grading system. The move does the following:
Comment #12Page Number: GeneralParagraph / Figure / Table / Note: GeneralComment Intent: ObjectionComment Type: GeneralComment: There are many instances of permissive, non-mandatory, or unenforceable language that do not align with the intent of a normative appendix for insulation installation. The entire document should be reviewed to fix such language to align with ICC policy for reference standards. There are 24 cases where the term “may” is used and several cases of “should”. A few examples of use of permissive language in the current draft are as follows: 1-1.3.7.2 Hybrid assemblies….should contain sufficient medium density SPF to meet the requirements of IRC Table R806.5 for condensation control. 1-2.3.1.3… (b) Cracks or gaps may not exceed 1mm width. 1-2.3.1.3…(e) … At least one check should be performed… 1-2.4.4.2 Low density SPF may be installed… 1-2.8.3.10.1 FPIS may be installed… There are many other examples. Some of these non-mandatory language usages (such as the first listed above) are related to functional matters that are beyond the scope of Appendix A and a rater’s responsibility for inspecting insulation installation and relate to building design in compliance with the building code. This scope and intent concern is addressed in a separate comment on Section 1-1 of Appendix A. Proposed Change: See examples given above. An editorial review of the entire document is needed to address non-mandatory/permissive language.
There are many instances of permissive, non-mandatory, or unenforceable language that do not align with the intent of a normative appendix for insulation installation. The entire document should be reviewed to fix such language to align with ICC policy for reference standards. There are 24 cases where the term “may” is used and several cases of “should”.
A few examples of use of permissive language in the current draft are as follows:
1-1.3.7.2 Hybrid assemblies….should contain sufficient medium density SPF to meet the requirements of IRC Table R806.5 for condensation control.
1-2.3.1.3… (b) Cracks or gaps may not exceed 1mm width.
1-2.3.1.3…(e) … At least one check should be performed…
1-2.4.4.2 Low density SPF may be installed…
1-2.8.3.10.1 FPIS may be installed…
There are many other examples. Some of these non-mandatory language usages (such as the first listed above) are related to functional matters that are beyond the scope of Appendix A and a rater’s responsibility for inspecting insulation installation and relate to building design in compliance with the building code. This scope and intent concern is addressed in a separate comment on Section 1-1 of Appendix A.
See examples given above. An editorial review of the entire document is needed to address non-mandatory/permissive language.
Comment #13Page Number: 3Paragraph / Figure / Table / Note: 1-1Comment Intent: ObjectionComment Type: GeneralComment: There are many instances in the current draft of Appendix A where guidance on matters beyond proper installation of insulation occurs. This matter of scope and intent is not consistently addressed by the different insulation material sections in Appendix A. It should not be the responsibility of raters to make decisions about design or functional considerations beyond inspection of matters related to the thermal performance of insulation installation that affect the HERS score. A couple examples of going beyond what was understood to be the scope and intent of an insulation installation/grading appendix are as follows: 1-2.4.2.1 Low density SPF shall be permitted to be used as cavity insulation and a component of the air barrier when… 1-2.4.2.2 Low density SPF shall be permitted to be used as its own Class III vapor retarder when installed at sufficient thickness (as referenced on the product’s TDS or CCR) in interior cavities of exterior walls conforming to IRCC Table R702.7.1. A supplemental Class I or II vapor retarder may not be required in these cases. 1-1.3.7.2 Hybrid assemblies….should contain sufficient medium density SPF to meet the requirements of IRC Table R806.5 for condensation control. The Appendix A draft should be reviewed and revised to ensure that such non-thermal performance attributes and building code compliance guidance/commentary are removed to align with the proposed added language to Section 1-1 addressing the scope and intent of Appendix A. The appendix should not be a guide on complying with other building code (non-energy code) related matters that the rater is not necessarily responsible for and which are not directly factored into a HERS score. Guidance on these other matters should be addressed in manufacturer literature or a separate guidance document planned to supplement Appendix A. However, if the intent is to use this Appendix to address a broader scope of guidance and performance attributes related to various insulation products, then we request opportunity to revise Section 1.1-8 to include guidance on installation and performance attributes beyond just those related to thermal performance as we understood to be the scope and intent of Appendix A. Proposed Change: 1-1 Insulation Installation Assessment To meet the requirements of proper insulation installation, the insulation material shall be installed in accordance with the requirements outlined in this Appendix for the applicable insulation type. Installations not complying with the requirements of this Appendix shall be considered not properly installed and shall be assessed an insulation grade of Not Properly Installed per Section 4.2.2.2.2 of this Standard. Where the requirements in this Appendix conflict with the installation requirements of the insulation material manufacturer, the more stringent requirement shall apply. The requirements in this Appendix apply only to insulation installation practices related to the thermal performance of the installed insulation products addressed. Other performance attributes of insulation materials and their manner of installation shall comply with the approved building plan and requirements of the locally applicable building code and are subject to inspection by the local authority having jurisdiction. NOTE TO REVIEWERS: As indicated in the commment justification with examples, the various sections of Appendix A should be reviewed and edited for conformity with the above scope and intent. Other functional capabilities beyond the scope of this appendix for the various insulation products should be addressed separately in manufacturer literature or in the planned industry guidance document to supplement Appendix A.
There are many instances in the current draft of Appendix A where guidance on matters beyond proper installation of insulation occurs. This matter of scope and intent is not consistently addressed by the different insulation material sections in Appendix A.
It should not be the responsibility of raters to make decisions about design or functional considerations beyond inspection of matters related to the thermal performance of insulation installation that affect the HERS score. A couple examples of going beyond what was understood to be the scope and intent of an insulation installation/grading appendix are as follows:
1-2.4.2.1 Low density SPF shall be permitted to be used as cavity insulation and a component of the air barrier when…
1-2.4.2.2 Low density SPF shall be permitted to be used as its own Class III vapor retarder when installed at sufficient thickness (as referenced on the product’s TDS or CCR) in interior cavities of exterior walls conforming to IRCC Table R702.7.1. A supplemental Class I or II vapor retarder may not be required in these cases.
The Appendix A draft should be reviewed and revised to ensure that such non-thermal performance attributes and building code compliance guidance/commentary are removed to align with the proposed added language to Section 1-1 addressing the scope and intent of Appendix A.
The appendix should not be a guide on complying with other building code (non-energy code) related matters that the rater is not necessarily responsible for and which are not directly factored into a HERS score. Guidance on these other matters should be addressed in manufacturer literature or a separate guidance document planned to supplement Appendix A. However, if the intent is to use this Appendix to address a broader scope of guidance and performance attributes related to various insulation products, then we request opportunity to revise Section 1.1-8 to include guidance on installation and performance attributes beyond just those related to thermal performance as we understood to be the scope and intent of Appendix A.
To meet the requirements of proper insulation installation, the insulation material shall be installed in accordance with the requirements outlined in this Appendix for the applicable insulation type. Installations not complying with the requirements of this Appendix shall be considered not properly installed and shall be assessed an insulation grade of Not Properly Installed per Section 4.2.2.2.2 of this Standard.
Where the requirements in this Appendix conflict with the installation requirements of the insulation material manufacturer, the more stringent requirement shall apply.
The requirements in this Appendix apply only to insulation installation practices related to the thermal performance of the installed insulation products addressed. Other performance attributes of insulation materials and their manner of installation shall comply with the approved building plan and requirements of the locally applicable building code and are subject to inspection by the local authority having jurisdiction.
NOTE TO REVIEWERS: As indicated in the commment justification with examples, the various sections of Appendix A should be reviewed and edited for conformity with the above scope and intent. Other functional capabilities beyond the scope of this appendix for the various insulation products should be addressed separately in manufacturer literature or in the planned industry guidance document to supplement Appendix A.
Comment #14Page Number: 1Paragraph / Figure / Table / Note: 4.2.2.2.2Comment Intent: Not an ObjectionComment Type: GeneralComment: In Section 4.2.2.2.2, references to Grade I, II, and III have been deleted. We agree with this to align with the intent of the new Appendix A. However, it is unclear that other instances of referencing these grades of insulation installation throughout the standard have been similarly deleted. This general comment is a request for staff, the Appendix A task group, or the committee to review the entire standard to be sure all references to Grade I, II, and III have been similarly deleted and, where appropriate, Appendix A referenced instead. Proposed Change: See comment justification. RESNET 301 should be reviewed to confirm all references to Grade I, II, and III have been identified and revised to align with the new Appendix A "PI" and "NPI" grading approach.
In Section 4.2.2.2.2, references to Grade I, II, and III have been deleted. We agree with this to align with the intent of the new Appendix A. However, it is unclear that other instances of referencing these grades of insulation installation throughout the standard have been similarly deleted. This general comment is a request for staff, the Appendix A task group, or the committee to review the entire standard to be sure all references to Grade I, II, and III have been similarly deleted and, where appropriate, Appendix A referenced instead.
See comment justification. RESNET 301 should be reviewed to confirm all references to Grade I, II, and III have been identified and revised to align with the new Appendix A "PI" and "NPI" grading approach.
Comment #15Page Number: 1Paragraph / Figure / Table / Note: 4.2.2.2.2Comment Intent: ObjectionComment Type: TechnicalComment: The description in Section 4.2.2.2.2 regarding modeling of not properly installed (NPI) insulation is unclear and somewhat awkward. The proposed revision is intended to clarify what is believed to have been intended. It clarifies how to model the entire insulated surface area for insulated areas that are deemed not compliant with Appendix A. This includes treatment of the10% of the insulated surface area assumed to have no insulation R-value and the remaining 90% of insulated surface area that is assumed to have improperly installed insulation resulting in a 10% reduction in its labeled/measured R-value (or 90% of the labeled/measured R-value). With this clarification, we support the technical implication and impact of not complying with Appendix A and believe it to be reasonable. It also will be sufficient to encourage proper installation of insulation as intended by Appendix A. Proposed Change: 4.2.2.2.2 Insulation Assessment:….. Installed insulation that is deemed to not be properly installed (NPI) in accordance with Appendix A shall be modeled such that there is no insulation R-Value for 10 percent of the insulated surface area and, for the remaining 90 percent of the insulated surface area, there is 90 percent of the its measured or labeled R-value, including other adjustments as described in Appendix A.
The description in Section 4.2.2.2.2 regarding modeling of not properly installed (NPI) insulation is unclear and somewhat awkward. The proposed revision is intended to clarify what is believed to have been intended. It clarifies how to model the entire insulated surface area for insulated areas that are deemed not compliant with Appendix A. This includes treatment of the10% of the insulated surface area assumed to have no insulation R-value and the remaining 90% of insulated surface area that is assumed to have improperly installed insulation resulting in a 10% reduction in its labeled/measured R-value (or 90% of the labeled/measured R-value). With this clarification, we support the technical implication and impact of not complying with Appendix A and believe it to be reasonable. It also will be sufficient to encourage proper installation of insulation as intended by Appendix A.
4.2.2.2.2 Insulation Assessment:….. Installed insulation that is deemed to not be properly installed (NPI) in accordance with Appendix A shall be modeled such that there is no insulation R-Value for 10 percent of the insulated surface area and, for the remaining 90 percent of the insulated surface area, there is 90 percent of the its measured or labeled R-value, including other adjustments as described in Appendix A.
Comment #16Page Number: 1Paragraph / Figure / Table / Note: 4.2.2.2.2(a)Comment Intent: ObjectionComment Type: TechnicalComment: The proposed revision of Section 4.2.2.2.2(a) is not intended to be a technical change. It is intended to be an editorial or technical clarification. The current language in Section 4.2.2.2.2(a) regarding assessment and modeling of assemblies including framing members, insulation, and building materials is confusing and can lead to misapplication of the fundamentals of heat transfer through parallel path assemblies (or assemblies that follow other heat flow path theories). It may also result in incorrect inspection/compliance with insulation installation in specific assembly conditions as addressed in the new Appendix A. Furthermore, Section 4.2.2.2.2 as referenced in the existing (deleted) text gives no guidance on how to perform appropriate modeling of assemblies. The only thing it provides is a reference to the ASHRAE HOF for R-values of other building materials (including air-films). Thus, the revision above properly references Section 4.2.2.2.2 only for the purpose of assigning R-values to “other materials”. As an alternative to the proposed revision, it may be appropriate to more directly reference the parallel path method in the ASHRAE Handbook of Fundamentals as a means to assess and model wood frame wall assemblies. Steel framed wall assemblies are addressed separately in item (d) of Section 4.2.2.2.2 (which is the matter of a separate comment). Proposed Change: Revise Section 4.2.2.2.2 (a) as follows: (a) Insulated assemblies shall be assessed and modeled such that framing members and cavities are treated as separate surface areas. Cavity insulation shall be modeled as contributing only to the thermal performance of the cavity surface area. Continuous insulation shall be modeled as contributing to the thermal performance of the cavity and framing member surface areas combined, or the total assembly area covered by the continuous insulation. The framing and cavity paths shall also include the R-value of other building materials covering the interior and exterior sides of the assembly and such other building materials shall be assigned an R-value in accordance with Section 4.2.2.2.2. Assemblies shall not be modeled by simply adding the labeled or measured R-values of continuous and cavity insulation materials. Insulation that does not cover framing members shall not be modeled as if it covers the framing. Insulated surfaces that have continuous insulation, including rigid foam, fibrous batt, loose fill, sprayed insulation or insulated siding, covering the framing members shall be assessed and modeled according to Section 4.2.2.2 and combined with the cavity insulation, framing and other materials to determine the overall assembly R-Value.
The proposed revision of Section 4.2.2.2.2(a) is not intended to be a technical change. It is intended to be an editorial or technical clarification. The current language in Section 4.2.2.2.2(a) regarding assessment and modeling of assemblies including framing members, insulation, and building materials is confusing and can lead to misapplication of the fundamentals of heat transfer through parallel path assemblies (or assemblies that follow other heat flow path theories). It may also result in incorrect inspection/compliance with insulation installation in specific assembly conditions as addressed in the new Appendix A. Furthermore, Section 4.2.2.2.2 as referenced in the existing (deleted) text gives no guidance on how to perform appropriate modeling of assemblies. The only thing it provides is a reference to the ASHRAE HOF for R-values of other building materials (including air-films). Thus, the revision above properly references Section 4.2.2.2.2 only for the purpose of assigning R-values to “other materials”.
As an alternative to the proposed revision, it may be appropriate to more directly reference the parallel path method in the ASHRAE Handbook of Fundamentals as a means to assess and model wood frame wall assemblies. Steel framed wall assemblies are addressed separately in item (d) of Section 4.2.2.2.2 (which is the matter of a separate comment).
Revise Section 4.2.2.2.2 (a) as follows:
(a) Insulated assemblies shall be assessed and modeled such that framing members and cavities are treated as separate surface areas. Cavity insulation shall be modeled as contributing only to the thermal performance of the cavity surface area. Continuous insulation shall be modeled as contributing to the thermal performance of the cavity and framing member surface areas combined, or the total assembly area covered by the continuous insulation. The framing and cavity paths shall also include the R-value of other building materials covering the interior and exterior sides of the assembly and such other building materials shall be assigned an R-value in accordance with Section 4.2.2.2.2. Assemblies shall not be modeled by simply adding the labeled or measured R-values of continuous and cavity insulation materials. Insulation that does not cover framing members shall not be modeled as if it covers the framing. Insulated surfaces that have continuous insulation, including rigid foam, fibrous batt, loose fill, sprayed insulation or insulated siding, covering the framing members shall be assessed and modeled according to Section 4.2.2.2 and combined with the cavity insulation, framing and other materials to determine the overall assembly R-Value.
Comment #17Page Number: 2Paragraph / Figure / Table / Note: 4.2.2.2.2(d)Comment Intent: Not an ObjectionComment Type: TechnicalComment: The proposed revision to Section 4.2.2.2.2(d) references more appropriate and up-to-date provisions for modeling or calculating the thermal performance of cold-formed steel framed assemblies. ANSI/AISI S-250 is a newly approved standard that provides updated means to calculate thermal performance of a wide range of insulated cold-formed steel assemblies. For the I-Codes, the current practice (at least continuing for the next several years) is to use the cavity correction factor method in Section C402.1.4.2 of the IECC commercial provisions. Thus, both approaches are referenced and generally give very similar answers for identical assemblies (although the IECC method is simpler to apply but covers a narrower scope of common wall assemblies). With these references, there should no longer be a need for the deleted language. Proposed Change: Revise Section 4.2.2.2.2 (d) as follows: (d) The overall thermal properties of steel-framed walls, ceilings and floors shall be calculated in accordance with the ANSI/AISI S-250 standard or the cavity correction factor method of the International Energy Conservation Code, Section C402.1.4.2 Thermal resistance of cold-formed steel walls. modified zone method specified by Chapter 27, ASHRAE Handbook of Fundamentals or tested in accordance with ASTM Standard C1363. Modification of test results to add or subtract R-Values to the tested assembly that reflect differences between the tested assembly and proposed assemblies is authorized when such differences are continuous and occur outside of the cavity.
The proposed revision to Section 4.2.2.2.2(d) references more appropriate and up-to-date provisions for modeling or calculating the thermal performance of cold-formed steel framed assemblies. ANSI/AISI S-250 is a newly approved standard that provides updated means to calculate thermal performance of a wide range of insulated cold-formed steel assemblies. For the I-Codes, the current practice (at least continuing for the next several years) is to use the cavity correction factor method in Section C402.1.4.2 of the IECC commercial provisions. Thus, both approaches are referenced and generally give very similar answers for identical assemblies (although the IECC method is simpler to apply but covers a narrower scope of common wall assemblies). With these references, there should no longer be a need for the deleted language.
Revise Section 4.2.2.2.2 (d) as follows:
(d) The overall thermal properties of steel-framed walls, ceilings and floors shall be calculated in accordance with the ANSI/AISI S-250 standard or the cavity correction factor method of the International Energy Conservation Code, Section C402.1.4.2 Thermal resistance of cold-formed steel walls. modified zone method specified by Chapter 27, ASHRAE Handbook of Fundamentals or tested in accordance with ASTM Standard C1363. Modification of test results to add or subtract R-Values to the tested assembly that reflect differences between the tested assembly and proposed assemblies is authorized when such differences are continuous and occur outside of the cavity.
Comment #18Page Number: 6 and 9Paragraph / Figure / Table / Note: 1-1.1.4.8 and 1.2.4.10.1Comment Intent: Not an ObjectionComment Type: GeneralComment: As an example, Section 1-1.1.4.8 addresses the special situation of below roof deck insulation for a vented attic using batt and blanket insulation (similar for Section 1-1.2.4.10.1 and loose-fill insulation). It is unclear, with attic ventilation occurring in the attic space below the insulation (regardless of the insulation type), how the below roof deck insulation will impact the energy performance (and rating) of the dwelling unit (and this may vary by climate zone, shading of the roof, orientation, reflectance/emissivity of the roof covering, as well as whether or not there is equipment/ductwork in the vented attic space). On the one hand, if this insulation installation condition is not relevant to inspecting insulation installation in relation to confirming a particular HERS score, then should such conditions be addressed in the installation provisions? On the other hand, if this installation condition (and the effects of having outdoor air ventilation occurring between the insulated assembly and the condition space below the attic) are accounted for in the HERS scoring procedure of RESNET 301, where are the provisions or rules that address that condition which may depend on many variables as noted above? Are these rules transparent or are they considered “proprietary” and buried within the software tools that perform the scoring? There should be a transparent connection between all insulation applications (and nuances or special conditions) -- not just for this one example addressed in this comment -- and a specific provision in RESNET 301 that addresses how that particular insulation application would affect the score of a building (i.e., basically this is a request to disclose or reference a calculation procedure, table, data, etc. for how special insulation conditions influence the HERS scoring analysis). Proposed Change: The task group and RESENT 301 committee should discuss this concern to determine how to best resolve. It relates to association of installation of insulation for special conditions with how it is treated for rating purposes in the body of the standard (or associated software tools).
As an example, Section 1-1.1.4.8 addresses the special situation of below roof deck insulation for a vented attic using batt and blanket insulation (similar for Section 1-1.2.4.10.1 and loose-fill insulation). It is unclear, with attic ventilation occurring in the attic space below the insulation (regardless of the insulation type), how the below roof deck insulation will impact the energy performance (and rating) of the dwelling unit (and this may vary by climate zone, shading of the roof, orientation, reflectance/emissivity of the roof covering, as well as whether or not there is equipment/ductwork in the vented attic space).
On the one hand, if this insulation installation condition is not relevant to inspecting insulation installation in relation to confirming a particular HERS score, then should such conditions be addressed in the installation provisions? On the other hand, if this installation condition (and the effects of having outdoor air ventilation occurring between the insulated assembly and the condition space below the attic) are accounted for in the HERS scoring procedure of RESNET 301, where are the provisions or rules that address that condition which may depend on many variables as noted above? Are these rules transparent or are they considered “proprietary” and buried within the software tools that perform the scoring? There should be a transparent connection between all insulation applications (and nuances or special conditions) -- not just for this one example addressed in this comment -- and a specific provision in RESNET 301 that addresses how that particular insulation application would affect the score of a building (i.e., basically this is a request to disclose or reference a calculation procedure, table, data, etc. for how special insulation conditions influence the HERS scoring analysis).
The task group and RESENT 301 committee should discuss this concern to determine how to best resolve. It relates to association of installation of insulation for special conditions with how it is treated for rating purposes in the body of the standard (or associated software tools).
Comment #19Page Number: 19 and 20Paragraph / Figure / Table / Note: 1-1.5 and 1-1.6Comment Intent: ObjectionComment Type: TechnicalComment: Sections 1-1.5 for interior radiation control coating (IRCC) and 1-1.6 for radiant barriers (RB) lack sufficient guidance for raters to ensure installed performance consistent with how the product and installation conditions were modeled to influence a HERS score. As mentioned in a separate comment, all products and installation conditions or applications should have a direct connection to rules in RESNET 301 that establish how a HERS score is affected or calculated for that application. In this case, there are many installation variables omitted that can influence achieving an installation that was assumed by RESENT 301-compliant analysis to have a particular influence on the calculated HERS score (which is the fundamental basis and purpose of inspection and installation requirements). For example, the energy efficiency impact of an IRCC or RB installed on the underside of an attic roof deck will depend on many factors related to the installation and which are part of the installation and coupled to its performance. Here are a list of some of the items of this nature that appear to be omitted from Section A-1.5: 1. How is emittance verified/measured in the field, particularly if it is not a labelled product and is field installed, such as with spray-applied reflective coating? 2. What type of surface was the emissivity based on? Is the surface in the field consistent with the basis of the rating? 3. How much air space ventilation was considered (in this case attic ventilation) and how does that influence the intended installed performance? Is the ventilation level (free vent open area or even mechanic ventilation) great enough that it alters the intended or assumed impact of the IRCC on the calculated HERS score? 4. How does building orientation or shading affect the intended performance? 5. Was the performance (i.e., influence on HERS score) based on a certain installation assumption regarding equipment/ductwork in the air space (vented attic)? What insulation and leakage rates were assume for that equipment/ductwork and are those features present with the installation? 6. Was the performance (i.e., influence on HERS score) based on a certain installation assumption regard the ceiling insulation levels below the attic space? Is that installed condition present? 7. Does the surface emittance value factor in fouling over time or perhaps due to construction exposure and handling (as is the case with reflective roof coverings)? How is this addressed in inspection? 8. What climate zone or solar radiation condition (which varies significantly within a given climate zone) was assumed in calculating the HERS score as influenced by the IIRC or RB? Is the building actually located in those conditions? The above items would seem to be important inspection and rating considerations for this type of energy efficiency measure or system that is not conventional insulation and which has a greatly expanded number of variables that can affect proper installation and intended performance. Proposed Change: The Appendix A task group should consider the concerns itemized in the comment justification and determine how to best address them in Sections 1-1.5 and 1-1.6. The RESNET 301 committee may also need to assess how these same concerns are addressed in evaluation procedures for determining a HERS score. Installation/inspection requirements and rating requirements should be coordinated and consistent (and transparent).
Sections 1-1.5 for interior radiation control coating (IRCC) and 1-1.6 for radiant barriers (RB) lack sufficient guidance for raters to ensure installed performance consistent with how the product and installation conditions were modeled to influence a HERS score. As mentioned in a separate comment, all products and installation conditions or applications should have a direct connection to rules in RESNET 301 that establish how a HERS score is affected or calculated for that application. In this case, there are many installation variables omitted that can influence achieving an installation that was assumed by RESENT 301-compliant analysis to have a particular influence on the calculated HERS score (which is the fundamental basis and purpose of inspection and installation requirements).
For example, the energy efficiency impact of an IRCC or RB installed on the underside of an attic roof deck will depend on many factors related to the installation and which are part of the installation and coupled to its performance. Here are a list of some of the items of this nature that appear to be omitted from Section A-1.5:
1. How is emittance verified/measured in the field, particularly if it is not a labelled product and is field installed, such as with spray-applied reflective coating?
2. What type of surface was the emissivity based on? Is the surface in the field consistent with the basis of the rating?
3. How much air space ventilation was considered (in this case attic ventilation) and how does that influence the intended installed performance? Is the ventilation level (free vent open area or even mechanic ventilation) great enough that it alters the intended or assumed impact of the IRCC on the calculated HERS score?
4. How does building orientation or shading affect the intended performance?
5. Was the performance (i.e., influence on HERS score) based on a certain installation assumption regarding equipment/ductwork in the air space (vented attic)? What insulation and leakage rates were assume for that equipment/ductwork and are those features present with the installation?
6. Was the performance (i.e., influence on HERS score) based on a certain installation assumption regard the ceiling insulation levels below the attic space? Is that installed condition present?
7. Does the surface emittance value factor in fouling over time or perhaps due to construction exposure and handling (as is the case with reflective roof coverings)? How is this addressed in inspection?
8. What climate zone or solar radiation condition (which varies significantly within a given climate zone) was assumed in calculating the HERS score as influenced by the IIRC or RB? Is the building actually located in those conditions?
The above items would seem to be important inspection and rating considerations for this type of energy efficiency measure or system that is not conventional insulation and which has a greatly expanded number of variables that can affect proper installation and intended performance.
The Appendix A task group should consider the concerns itemized in the comment justification and determine how to best address them in Sections 1-1.5 and 1-1.6. The RESNET 301 committee may also need to assess how these same concerns are addressed in evaluation procedures for determining a HERS score. Installation/inspection requirements and rating requirements should be coordinated and consistent (and transparent).
Comment #20Page Number: 21Paragraph / Figure / Table / Note: 1-1.7.1Comment Intent: ObjectionComment Type: TechnicalComment: Revisions to Section 1-1.7.1 are needed to ensure proper installation and avoid improper installations of reflective insulations. First, we agree that the reflective insulation must be located in an enclosed cavity that is unventilated (although the actual R-values often applied assume a perfectly sealed cavity, not just enclosed). However, it is important that the reflective face of the reflective insulation material actually face the air space and not be placed facing and in contact with the building material surfaces bounding the air space. Second, while cavities behind exterior wall coverings may be considered enclosed, they are effectively ventilated systems or vented systems, even if there are no designated vents or weeps. Joints between cladding and other discontinuities create avenues for air flow (which is good for moisture control purposes). In addition, buoyancy and wind effects can significantly increase air flow through and behind claddings such that any air space behind cladding does not behave like an “enclosed” and “unventilated” cavity. The second sentence added to Section 1-1.7.1.1 addresses this concern. This also is consistent with treatment of such air spaces in ASHRAE 90.1. Third, a new Section 1-1.7.1.2 is added to recognize that even if the material is not installed with a properly enclosed and unventilated air space, the reflective insulation material itself does have an R-value like any other conventional insulation product. Thus, that portion of the R-value (excluding the contribution of a non-compliant reflective air space), should be able to be used, counted toward the HERS score, and not totally discounted should a rater encounter such a situation. Proposed Change: Revise Section 1-1.7.1 as follows: 1-1.7 Reflective Insulation 1-1.7.1 General Installation Requirements 1-1.7.1.1 Reflective insulation assemblies shall be installed in enclosed cavities that are unventilated and the reflective surface shall face the air space created by the enclosed cavity. Cavities behind exterior wall covering materials shall not be considered as an enclosed or unventilated cavity. 1-1.7.1.2 Where located in cavities not complying with Section 1-1.2.1.1 the R-value assigned to the reflective insulation shall be for the material R-value only and shall not include the R-value contribution of the reflective air space. 1-1.7.1.23 Where necessary, reflective insulation shall be cut to fit as required to provide coverage without gaps or openings. 1-1.7.1.34 Any penetrations or cuts from damage shall be repaired with an acrylic adhesive foil tape.
Revisions to Section 1-1.7.1 are needed to ensure proper installation and avoid improper installations of reflective insulations.
First, we agree that the reflective insulation must be located in an enclosed cavity that is unventilated (although the actual R-values often applied assume a perfectly sealed cavity, not just enclosed). However, it is important that the reflective face of the reflective insulation material actually face the air space and not be placed facing and in contact with the building material surfaces bounding the air space.
Second, while cavities behind exterior wall coverings may be considered enclosed, they are effectively ventilated systems or vented systems, even if there are no designated vents or weeps. Joints between cladding and other discontinuities create avenues for air flow (which is good for moisture control purposes). In addition, buoyancy and wind effects can significantly increase air flow through and behind claddings such that any air space behind cladding does not behave like an “enclosed” and “unventilated” cavity. The second sentence added to Section 1-1.7.1.1 addresses this concern. This also is consistent with treatment of such air spaces in ASHRAE 90.1.
Third, a new Section 1-1.7.1.2 is added to recognize that even if the material is not installed with a properly enclosed and unventilated air space, the reflective insulation material itself does have an R-value like any other conventional insulation product. Thus, that portion of the R-value (excluding the contribution of a non-compliant reflective air space), should be able to be used, counted toward the HERS score, and not totally discounted should a rater encounter such a situation.
Revise Section 1-1.7.1 as follows:
Comment #21Page Number: 1Comment Intent: Not an ObjectionComment Type: GeneralComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Valuable info to share – (no void) R11.8 to (5% voids) R10.8 to (10% voids) R9.2 in a standard wood R-13 assembly Proposed Change: TEXT REFERENCE FOR COMMENT ONE: shall be modeled such that there is no insulation R-Value for 105 percent of the insulated surface area and its measured or labeled value
Comment #22Page Number: 3Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: If 1-1 above is not installed to manufacturer’s instructions, this contradicts – should be clarified; If no voids/gaps present but insulation is compressed, is this still considered PII, or is it NPI and the 90% existing modeled insulation is modeled via BI506? COMMENT TWO: ADD this exception for vented crawl spaces: A vented crawlspace that has Class I vapor retarder installed and has crawl venting meeting 1 sq ft to 1500 sq ft floor area. (explanation: Crawl spaces that meet IRC 1sq ft venting to 150 sq ft floor area are not required to have Class 1 vapor retarder on crawl space floor, but should have underfloor insulation air barrier on side facing the crawl space.) COMMENT THREE: What about rim joist insulation in not-fully conditioned areas? Should be clarified here via footnote or additional reference. COMMENT FOUR: Delete this exception – ALL kneewalls should require an exterior side air barrier (for insulated walls) Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.1.1 Insulation R-value Assessment Insulation shall be installed to the density and thickness required to attain the required R-Value. The base R-Value of fibrous batt insulation that is compressed to less than its full rated thickness in a completely enclosed cavity shall be assessed according to the manufacturer’s documentation. In the absence of such documentation, use “Estimated R-values for Compressed Fiber Glass Batt Insulation” (NAIMA BI506) for assessing the compressed R-value. TEXT REFERENCE TO COMMENT TWO: b. Insulation installed under floors directly above an unvented crawl space or basement shall not require an air barrier on the side facing the crawl space or basement. TEXT REFERENCE TO COMMENT THREE: c. Insulation installed in rim or band joists located in conditioned space shall not require an air barrier on the interior side. TEXT REFERENCE TO COMMENT FOUR: d. Insulation installed in knee walls shall not require an air barrier on the exterior side.
Comment #23Page Number: 4Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Are these defined anywhere? We recommend a single, consistent definition for voids/gaps COMMENT TWO: ALL other COMMENT THREE: Remove TO COMMENT FOUR: THEY COMMENT FIVE: Replace: Friction fit, without compression COMMENT SIX: Is this intended to imply only main-level foundation-level flooring? Not standard practice on 2nd floor, so many dwellings will be NPI. COMMENT SEVEN: Replace: neatly and completely COMMENT EIGHT: Replace this: Narrow spaces 1 inch and greater in width COMMENT NINE: Replace: friction fit without compression COMMENT TEN: This term should be defined/clarified (not currently identified in ANSI301) – We recommend using GA’s amended IECC language: “ATTIC KNEEWALL. Any vertical or near-vertical wall in the building thermal envelope that has conditioned space on one side and unconditioned attic space on the other side. If the envelope features the insulation installed along the sloped ceiling, the vertical wall is considered an interior wall and thus does not require insulation.” COMMENT ELEVEN: ADD: Attic side shall contain a sealed air barrier to fully encapsulate insulation Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.1.3.1 Batt and blanket insulation shall be correctly sized or cut to fit properly on all sides without voids or gaps TEXT REFERENCE TO COMMENT TWO: 1-1.1.3.1.2 Insulation shall be placed between the sheathing and the rear of electrical boxes and other obstructions that are not as deep as the cavity TEXT REFERENCE TO COMMENT THREE: 1-1.1.3.2 Wall stud cavity penetrations shall be caulked, foamed or otherwise sealed to provide a substantially air-tight envelope to between conditioned and TEXT REFERENCE TO COMMENT FOUR: from unconditioned space shall be sealed, and sealed to the surface the penetrate. All gaps in the air barrier shall be caulked, taped, or sealed. TEXT REFERENCE TO COMMENT FIVE: When batt and blanket insulation are cut to fit a non-standard cavity, they shall be snugly fitted to fill the cavity without gaps or voids. TEXT REFERENCE TO COMMENT SIX: 1-1.1.3.5 Bottom plates of framed assemblies shall be sealed or gasketed to the subfloor or slab beneath the bottom plate. TEXT REFERENCE TO COMMENT SEVEN: batt insulation cut to width and snugly fitted in the space TEXT REFERENCE TO COMMENT EIGHT: 1 inch to less than 2 inches in width TEXT REFERENCE TO COMMENT NINE: insulation snugly fitted in the space TEXT REFERENCE TO COMMENT TEN: 1-1.1.3.7 Special Situations--Kneewalls and Skylight Shafts TEXT REFERENCE TO COMMENT ELEVEN: 1-1.1.3.7.1 Insulation for all kneewall and skylight shafts shall be completely enclosed by vertical and horizontal framing, including horizontal plates at top and bottom of the insulation
Comment #24Page Number: 5Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Amend: We have concern as this term can cause confusion; can be an acoustical ceiling tile, such as in a commercial space, basements, etc. \ We think this is supposed to referring to a change in ceiling height. COMMENT TWO: REMOVE: “and recessed lights “ Code requires all air-tight IC-rated cans installed in insulated ceilings since at least 2009 IECC, making this moot. COMMENT THREE: Amend: Consider ‘Insulated Roofline’ as alternate term. COMMENT FOUR: REPLACE: Or. Using ‘and’ implies both materials be installed as mandatory. This is an either/or statement. COMMENT FIVE: REPLACE: perimeter Clarification needed – Is this vertical door, pull-down, scuttle access, etc.? Are all of these covered by this language and are each to be treated differently? Consider individual bullets for each of these 3 scenarios. Kneewall doors are otherwise not addressed elsewhere. Proposed Change: TEXT REFERENCE TO COMMENT ONE: placed over all drop ceiling areas and interior TEXT REFERENCE TO COMMENT TWO: appliance flues and recessed lights in accordance TEXT REFERENCE TO COMMENT THREE: 1-1.1.4.4 Special Situations--Enclosed Rafter Ceilings TEXT REFERENCE TO COMMENT FOUR: 1-1.1.4.5.1 Batt and blanket insulation TEXT REFERENCE TO COMMENT FIVE: The bottom of the attic access shall be gasketed to prevent air leakage of conditioned air to the unconditioned attic
Comment #25Page Number: 6Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: ADD: to cover framing members. COMMENT TWO: Which standard? This does not exist in ANSI301, nor in this appendix. Should say ‘baffles shall be installed continuously from eave to upper attic vent opening’, etc. COMMENT THREE: amend to mimic 1-1.1.4.7.4, e.g. support spacing/location, or continuous rigid support, etc. Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.1.4.7.5 When the batt thickness nominally exceeds the depth of the roof framing members, full-width batts must be used. TEXT REFERENCE TO COMMENT TWO: Eave vent baffles shall be installed per A-2.1.4.2. TEXT REFERENCE TO COMMENT THREE: 1-1.1.5.3 Batt and blanket insulation shall be properly supported to avoid gaps or voids.
Comment #26Page Number: 7Comment Intent: Not an ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: ADD: supporting it. COMMENT TWO: Clarify: unconditioned to unconditioned does not have a thermal boundary? Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.1.5.5.1 On floors that are over unconditioned spaces, or where there is an air space between the insulation and the subfloor, the rim or band joist shall be insulated to the same R-value as exterior walls. TEXT REFERENCE TO COMMENT TWO: shall have an air barrier installed in full contact with the thermal boundary .
Comment #27Page Number: 8Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While MeetingIntent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: CLARIFY: This language doesn’t clearly state what is being measured, how many measurements are required and if this is occurring against specified depth/manufacturer R-value. Language also implicitly requires verification of attic ruler install? COMMENT TWO: Align with above Air Barrier Requirements section amendments (incl. eliminating ‘d’, as all kneewalls should require attic-side air barrier) COMMENT THREE: Consistent language needed/align with similar statement in above batt section COMMENT FOUR: Align with above language for floor-levels COMMENT FIVE: may be COMMENT SIX: Align with consistent language above Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.2.1.3 Ceilings. The rater shall verify the insulation depth indicated as independently measured against manufacturer specified depth for R-value as indicated by properly installed attic rulers TEXT REFERENCE TO COMMENT TWO: a. Insulation installed in ventilated attics above ceilings shall not require an air barrier on the exterior side. b. Insulation installed under floors directly above an unvented crawl space or basement shall not require an air barrier on the side facing the crawl space or basement. c. Insulation installed in rim or band joists located in conditioned space shall not require an air barrier on the interior side. d. Insulation installed in knee walls shall not require an air barrier on the exterior side. TEXT REFERENCE TO COMMENT THREE: 1-1.2.3.4 Insulation shall fill between the exterior sheathing and the rear of electrical boxes and junction boxes. TEXT REFERENCE TO COMMENT FOUR: 1-1.2.3.5 Bottom plates of framed assemblies shall be sealed or gasketed to the subfloor or slab beneath the bottom plate. TEXT REFERENCE TO COMMENT FIVE: batt insulation cut to TEXT REFERENCE TO COMMENT SIX: and snugly fitted in the space
Comment #28Page Number: 9Comment Intent: Not an ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Align with consistent language above COMMENT TWO: Align with consistent language above COMMENT THREE: Align with consistent language above COMMENT FOUR: REMOVE: under COMMENT FIVE: ADD: (wind-washing) COMMENT SIX: Align with consistent language above COMMENT SEVEN: Consider aligning with consistent language above COMMENT EIGHT: Align with consistent language above COMMENT NINE: ADD: complete COMMENT TEN: Align with consistent language above Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.2.3.6.2 Narrow spaces 1 inch to less than 2 inches in width, including between studs at building corners, and at the intersection of interior partition walls to exterior walls, shall be completely filled with insulation snugly fitted in the space. TEXT REFERENCE TO COMMENT TWO: 1-1.2.3.7.1 Insulation for all kneewall and skylight shafts shall be completely enclosed by vertical and horizontal framing, including horizontal plates at top and bottom of the insulation. TEXT REFERENCE TO COMMENT THREE: over all drop ceiling areas TEXT REFERENCE TO COMMENT FOUR: air barrier and entering under the insulation TEXT REFERENCE TO COMMENT FIVE: the insulation. The effective TEXT REFERENCE TO COMMENT SIX: flues and recessed lights in accordance TEXT REFERENCE TO COMMENT SEVEN: 1-1.2.4.7 Special Situations--Enclosed Rafter Ceilings TEXT REFERENCE TO COMMENT EIGHT: 1-1.2.4.7.1 In vented rafter ceilings, an air space shall be maintained between the insulation and roof sheathing as specified by IRC Section R806.3, or as specified by the local building code. TEXT REFERENCE TO COMMENT NINE: insulation shall be in contact with the air barrier TEXT REFERENCE TO COMMENT TEN: 1-1.2.4.9 Permanently attach insulation with the required R-value to the access door using adhesive or mechanical fastener. The bottom of the attic access shall be gasketed to prevent air leakage of conditioned air to the unconditioned attic.
Comment #29Page Number: 10Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Align with consistent language above COMMENT TWO: Which standard? This does not exist in ANSI301, nor in this appendix. Should state baffles shall be installed continuously from eave to ridge, etc. COMMENT THREE: REMOVE: ed COMMENT FOUR: Swap 10.3 with 10.1 – restructuring this order may add more clarity/context COMMENT FIVE: Align with consistent language above (0-1.2.4.5) COMMENT SIX: Clarify – add details for minimum required support material. distances, etc. COMMENT SEVEN: REMOVE COMMENT EIGHT: REMOVE – this section appears moot COMMENT NINE: Align with consistent language above Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.2.4.10.1 For vented attics, below deck loose-fill insulation shall be installed in a manner that does not obstruct soffit, eave, ridge or other vents to allow for adequate attic ventilation. Baffles shall be used to provide ventilation space from soffit to ridge. At the soffit, baffles shall be installed per A-2.1.4.2 TEXT REFERENCE TO COMMENT TWO: installed per A-2.1.4.2 TEXT REFERENCE TO COMMENT THREE: shall be secureded around conduit TEXT REFERENCE TO COMMENT FOUR: 1-1.2.4.10.3 Loose-fill insulation shall be installed uniformly in the netted cavity side-to-side, top-to-bottom, and front-to-back and be in continuous contact with the roof sheathing or continuous baffle material. TEXT REFERENCE TO COMMENT FIVE: 1-1.2.4.11 Loose-fill insulation shall be installed to fit around wiring, conduit, plumbing, and other obstructions. TEXT REFERENCE TO COMMENT SIX: 1-1.2.5.3 Insulation shall be properly supported where necessary to avoid sagging, gaps, and voids. TEXT REFERENCE TO COMMENT SEVEN: , or where there is an air space between the insulation and the subfloor, TEXT REFERENCE TO COMMENT EIGHT: 1-1.2.5.4.2 For dwelling units with conditioned space over unconditioned spaces, the separation between conditioned space (house) and unconditioned space shall be insulated to create a continuous thermal barrier. All rim and band joists adjoining conditioned space shall be airtight and insulated to the same R-value as exterior walls. TEXT REFERENCE TO COMMENT NINE: 1-1.2.5.4.3 For dwelling units with no conditioned space over unconditioned spaces, the band joist where the unconditioned space transitions to an attic above conditioned space shall have an air barrier installed in full contact with the edge of the attic insulation.
Comment #30Page Number: 11Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: ADD (‘Closed Cell’, or ‘nominal 2lb density’) COMMENT TWO: Is Code compliance the object of spray foam install? Why not for Batts, loose fill, etc.? COMMENT THREE: Consider removing this statement – Average is not consistent with the specific language below COMMENT FOUR: This is a lot of testing – maybe add ‘where feasible/accessible’? COMMENT FIVE: REPLACE: In cases where a specification (plans, manufacturer, etc.) requires a minimum thickness or R-value, more than half of all measured thicknesses shall meet or exceed the specified thickness. REASONING: This approach eliminates the need for installers and inspectors to perform averaging math but results in the same outcome (average minus 10%, at worst) COMMENT SIX: ADD: of the specified thickness, COMMENT SEVEN: REPLACE: 1/16” [in all references to 1mm] COMMENT EIGHT: AMEDN ORDER: d, b,a,c,e COMMENT NINE: How is this feasible? Who is ‘the reviewer’? Is this per-dwelling unit, what about for mulit-family. Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.3 Medium Density Spray TEXT REFERENCE TO COMMENT TWO: verify applications are code compliant TEXT REFERENCE TO COMMENT THREE: obtain the average thickness of the installation TEXT REFERENCE TO COMMENT FOUR: 100 square feet evenly TEXT REFERENCE TO COMMENT FIVE: b. In cases where a specification requires a minimum thickness or R-value, the average reference thicknesses shall not be below the minimum thickness minus 10%. TEXT REFERENCE TO COMMENT SIX: % variance per inch for a TEXT REFERENCE TO COMMENT SEVEN: less than 1mm in width TEXT REFERENCE TO COMMENT EIGHT: b. Cracks or gaps may not exceed 1mm in width. TEXT REFERENCE TO COMMENT NINE: e. SPF shall be well-adhered to the substrate. At least one check should be performed by the installer with results provided to the reviewer. The adhesion check may be performed using a coring tool. The removed foam square shall be replaced and sealed with one-component polyurethane foam or using a method recommended by the SPF manufacturer.
Comment #31Page Number: 12Comment Intent: Not an ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Consider deleting – this seems arbitrary. What force is acceptable to achieve depression, etc. Proposed Change: TEXT REFERENCE TO COMMENT ONE: The cured SPF should be solid and depress no more than ¼” when finger pressure is applied.
Comment #32Page Number: 13Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Gasketing of bottom plate (as mentioned in batt and blanket assemblies, under air barrier requirements) is not mentioned in this section. Seems inconsistent and should be consistently required across all wall types and assemblies. COMMENT TWO: See language in 1-1.4.1.6 and make consistent COMMENT THREE: ADD: in Climate Zones Marine 4-8, COMMENT FOUR: Please clarify – is this for above grade walls? Assuming the intent for this is per Code termite inspection clearance? Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.3.3 Exterior Wall (Interior Cavity Insulation) TEXT REFERENCE TO COMMENT TWO: 1-1.3.3.2 In hybrid walls, consisting of a layer of medium density SPF along with air permeable cavity insulation, a supplemental vapor retarder shall not be required, provided the thickness of medium density SPF conforms to the requirements of IRC Table R702.7.1. TEXT REFERENCE TO COMMENT THREE: insulation, a supplemental TEXT REFERENCE TO COMMENT FOUR: b. 6 inches of ground clearance shall be maintained between below grade SPF and untreated wood framed assemblies
Comment #33Page Number: 14Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Is sprayed foam ever applied under a slab on grade? Consider deleting. Perplexed by this concept. COMMENT TWO: Please clarify. Unsure of the intent/application of this. Doesn’t seem common or appropriate COMMENT THREE: REPLACE: Shall COMMENT FOUR: REPLACE: , COMMENT FIVE: ADD: that are part of the building thermal envelope Proposed Change: TEXT REFERENCE TO COMMENT ONE: SPF under slab on grade TEXT REFERENCE TO COMMENT TWO: bottom of the floor framing TEXT REFERENCE TO COMMENT THREE: SPF may extend to TEXT REFERENCE TO COMMENT FOUR: joists or trusses TEXT REFERENCE TO COMMENT FIVE: joists. Medium density
Comment #34Page Number: 15Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Align language with above for medium density foam (align with 1-1.3.1.2 and 1-1.3.1.3), especially b and c (these are highly subjective). COMMENT TWO: Align with above language 1-1.3.1.3 Proposed Change: TEXT REFERENCE TO COMMENT ONE: b. No more than 10% area shall be filled below the required thickness in the cavity. c. No more than 20% of the trimmed foam shall contain visible gaps or voids, and no voids may extend from the interior sheathing to the exterior of the cavity. d. The foam shall have no signs of shrinkage, such as pulling away from the substrate or framing. e. At least one adhesion check shall be performed by installing contractor (either witnessed by or with results provided to reviewer) to determine whether there is a gap between the SPF and the substrate in at least one location per job site. A 5-inch square shall be cut out of the center of a cavity and removed. If there is significant resistance when removing the square, or if the foam breaks before it lifts off the substrate, the adhesion shall be recorded as proper. If there is no resistance when removing the square, a gap behind the SPF shall be measured. Gaps may not exceed ½”. The removed foam square shall be replaced and sealed with one-component polyurethane foam or product recommended by the manufacturer. TEXT REFERENCE TO COMMENT TWO: a. A pin and disc depth gauge, as described in ASTM C167, shall be used to measure the average thickness of installed SPF. i. Average thickness shall be measured once every 100 square feet evenly distributed (e.g. at the top, middle, and bottom of the assembly.) These measurements shall be averaged to get the reference thickness for each assembly. b. In cases where a specification requires a minimum thickness or R-value, the average reference thicknesses shall not be below the minimum thickness minus 10%. c. No individual measurement shall fall below 25% variance per inch for a total installed thickness up to and including 4 inches. d. No individual measurement shall fall below 1” of the specified thickness for total installed thicknesses of over 4 inches.
Comment #35Page Number: 16Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Please add consistent language for gasketing under wall bottom plates, etc. (currently only listed under batt and blanket section) Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.4.2 Exterior Wall (Interior Cavity Insulation)
Comment #36Page Number: 17Comment Intent: ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Please clarify – are these 2 sections indirectly stating that no continuous low-density application is allowable directly against a foundation wall? COMMENT TWO: Please clarify/reword ‘can be permitted’. What are the criteria for permission/prohibitionf. COMMENT THREE: REMOVE: ed COMMENT FOUR: What does this mean? Not a requirement/instruction Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.4.3 Basement or Crawl Space 1-1.4.3.1 Low density SPF on basement or crawlspace walls shall be permitted to serve as a cavity insulation component of a continuous air barrier when it is in continuous and substantial contact with the substrate and all framing members and meets the minimum thickness for an air barrier as referenced on the product’s TDS or CCR. 1-1.4.3.2 Low density SPF on the interior can be permitted with non-structural framing and installed directly against the structural wall (providing cavity insulation only) or at a “stand-off” distance from exterior walls so as to provide room for SPF to flow behind framing and thermally isolate the interior from the exterior wall (providing cavity and continuous insulation). TEXT REFERENCE TO COMMENT TWO: interior can be permitted with TEXT REFERENCE TO COMMENT THREE: provided needed vapor TEXT REFERENCE TO COMMENT FOUR: typically provided needed vapor retarder protection.
Comment #37Page Number: 19Comment Intent: Not an ObjectionComment Type: GeneralComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: Can this not exist on manufactured sheathing? Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.5.2.1 The IRCC shall be sprayed, roller applied, or brushed to the underside of a roof assembly.
Comment #38Page Number: 24Comment Intent: Not an ObjectionComment Type: TechnicalComment: JUSTIFICATION: Clarity, Consistency, Comprehensiveness, and Improvement of Likelihood of Successful Execution in the Field While Meeting Intent *SEE MARKED UP COPY HERE: https://docs.google.com/document/d/1qzNKqC09vH6cgXEamRVgtVCI-_qc4JkO/edit?usp=sharing&ouid=102966834864672870737&rtpof=true&sd=true COMMENT ONE: This section coul/should be repeated in other sections (SPF, batts) Proposed Change: TEXT REFERENCE TO COMMENT ONE: 1-1.8.3.11 Attic Hatch and Door
Comment #39Page Number: Refer to section citationParagraph / Figure / Table / Note: Refer to Comment sectionComment Intent: ObjectionComment Type: GeneralComment: October 11, 2021 Residential Energy Services Network (RESNET) RE: Comments to BSR/RESNET/ICC 301-2019 Addendum E-202x, Appendix A Update, Draft PDS-01 (Cut and Pasted to: https://www1.resnet.us/comments/comment.aspx?DocumentID=62&layout=1) RESNET Staff: We appreciate the opportunity to be part of this process and look forward to discussing the additional comments noted herein. Owens Corning is a leader in fiberglass and related materials, systems and solutions. Our products are largely a result of our applied Building Science and Sustainability efforts which drive our innovation and our global operations. Owens Corning product specifications and operational activities are specifically undertaken with a measurable awareness towards natural resources stewardship as an integral part of our self-imposed sustainability journey. We are also deeply connected to our distributors, installation installers and many HERS Raters/Energy Consultants. Accordingly, we are sensitive to the totality of the following market challenges: The need for proper insulation installation The impact regulation has on the contractor and labor resources The need for fairness and accountability for all insulation product types Taking these elements into consideration and with a view towards long-term resource sustainability, durability, occupant comfort and energy efficiency, we offer the following perspectives. With respect to the current 45-day language, we strongly encourage RESNET to consider the following changes and concerns: 1-1.1.4.4.2 Where insulation is installed in unvented rafter ceilings or to the underside of unvented roofsWhere insulation is installed to the underside of unvented roofs, the air barrier shall be uniform across the transition of roof to wall. The insulation shall be in contact with the air barrier. Reasoning: For clarity of intent and so as not to be confused as applicable above or beyond the ceiling plane of a sealed attic wherein the insulation/thermal boundary remains at the ceiling plane and not at the roof deck. 1-1.1.5 Floor Insulation 1-1.1.5.1 Batt and blanket insulation shall be in full contact with the air barrier. 1-1.1.5.2 Faced batts or blankets shall be placed toward the living space and be in contact with the underside of the floor sheathing. Continuous support shall be provided to keep the facing in contact with the floor sheathing. The insulation shall be properly supported by stapling of flanges, netting, or other method approved by the manufacturer and required codes for the product. 1-1.1.5.3 Batt and blanket insulation shall be properly supported to avoid gaps or voids. 1-1.5.1 Floor cavity insulation shall comply with one of the following: 1-1.1.5.1 Insulation shall be installed to maintain permanent contact with the underside of the subfloor decking in accordance with manufacturer instructions to maintain required R-value or readily fill the available cavity space. 1-1.1.5.2 Floor framing cavity insulation shall be permitted to be in contact with top side of sheathing separating the cavity and the unconditioned space below. Insulation shall extend from the bottom to the top of all perimeter floor framing members and the framing members shall be air sealed. 1-1.1.5.3 A combination of cavity and continuous insulation shall be installed so that the cavity insulation is in contact with the top side of the continuous insulation that is installed on the underside of the floor framing separating the cavity and the unconditioned space below. The combined R-value of the cavity and continuous insulation shall equal the required R-value for floors. Insulation shall extend from the bottom to the top of all perimeter floor framing members and the framing members shall be air sealed. Reasoning: To align with verbiage in 2021 IECC, section R402.2.7 1-1.1.5.2 Faced batts or blankets shall be placed toward the living space and be in contact with the underside of the floor sheathing. Continuous support shall be provided to keep the facing in contact with the floor sheathing. The insulation shall be properly supported by stapling of flanges, netting, or other method approved by the manufacturer and required codes for the product. Reasoning: There are various methods for accomplishing continuous support and the Standard should not attempt to limit or define which method is used. The existing stated outcome is what’s relevant. 1-1.1.1.5.5.2 For dwelling units with conditioned space over other unconditioned spaces, the separation between conditioned space and the unconditioned space shall be insulated to create a continuous thermal boundary. All rim and band joists adjoining conditioned space shall be airtight and insulated to the same R-value as exterior walls. Reasoning: It is not technically possible to create a true continuous boundary where framing members intersect. We believe the intent here is that the available surface area be insulated, which the remaining language stipulates. 1-1.2.4.7.2 Where insulation is installed in unvented rafter ceilings or to the underside of roof sheathingWhere insulation is installed to the underside of unvented roofs the air barrier shall be uniform across the transition of roof to wall. The insulation shall be in contact with the air barrier. Reasoning: For clarity of intent and so as not to be confused as applicable above or beyond the ceiling plane of a sealed attic wherein the insulation/thermal boundary remains at the ceiling plane and not at the roof deck. 1-1.2.4.10.2 Where installed, netting shall be securededsecured around conduit, plumbing, roof penetrations and all other obstructions that penetrate the netting. Reasoning: Typo/spelling 1-1.2.5.4.2 For dwelling units with conditioned space over unconditioned spaces, the separation between conditioned space (house) and unconditioned space shall be insulated to create a continuous thermal barrier. All rim and band joists adjoining conditioned space shall be airtight and insulated to the same R-value as exterior walls. Reasoning: It is not technically possible to create a true continuous barrier where framing members intersect. We believe the intent here is that the available surface area be insulated, which the remaining language stipulates. Also, there seems to be interchangeable use of the term “boundary” and “barrier” when referring to the thermal boundary – consideration should be given to consistency of terminology when used. 1-1.3 Medium Density Spray Polyurethane Foam Insulation Q: How is Medium Density defined? 1-1.3.1.2b In cases where a specification requires a minimum thickness or R-value, the average reference thicknesses shall not be below the minimum thickness minus 10%??. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.3.1.2c. No individual measurement shall fall below 25%?? variance per inch for a total installed thickness of up to and including 4 inches. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.3.4.2 If “stand off wall” framing is being used, a percentage of the installed thickness of spray foam qualifies as “continuous” insulation and the remainder as cavity insulation. Consult installation details for information on framing dimensions and stand-off distance. Concern: This condition applies to any insulation type that would fill the void at the stand off wall framing, as does the resulting R-value calculations – both of which are common industry knowledge. Additionally, the issue this verbiage attempts to address are for performance calculations, not installation related. Accordingly, this does not need to be called out in this Standard. 1-1.4 Low Density Spray Polyurethane Foam Insulation Q: How is Low Density defined? 1-1.4.1.2b No more than 10%?? area shall be filled below the required thickness in the cavity. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.4.1.2b No more than 20%?? of the trimmed foam shall contain visible gaps or voids, and no voids may extend from the interior sheathing to the exterior of the cavity. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.4.1.3b In cases where a specification requires a minimum thickness or R-value, the average reference thicknesses shall not be below the minimum thickness minus 10%??. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.4.1.3c No individual measurement shall fall below 25%?? variance per inch for a total installed thickness up to and including 4 inches. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.7.1.1 Reflective insulation assemblies shall be installed in enclosed cavities that are unventilated. Reasoning: Even in an enclosed cavity the thermal buoyancy will dominate the heat transfer and negate any radiative resistance Proposed Change: October 11, 2021 Residential Energy Services Network (RESNET) RE: Comments to BSR/RESNET/ICC 301-2019 Addendum E-202x, Appendix A Update, Draft PDS-01 (Cut and Pasted to: https://www1.resnet.us/comments/comment.aspx?DocumentID=62&layout=1) RESNET Staff: We appreciate the opportunity to be part of this process and look forward to discussing the additional comments noted herein. Owens Corning is a leader in fiberglass and related materials, systems and solutions. Our products are largely a result of our applied Building Science and Sustainability efforts which drive our innovation and our global operations. Owens Corning product specifications and operational activities are specifically undertaken with a measurable awareness towards natural resources stewardship as an integral part of our self-imposed sustainability journey. We are also deeply connected to our distributors, installation installers and many HERS Raters/Energy Consultants. Accordingly, we are sensitive to the totality of the following market challenges: The need for proper insulation installation The impact regulation has on the contractor and labor resources The need for fairness and accountability for all insulation product types Taking these elements into consideration and with a view towards long-term resource sustainability, durability, occupant comfort and energy efficiency, we offer the following perspectives. With respect to the current 45-day language, we strongly encourage RESNET to consider the following changes and concerns: 1-1.1.4.4.2 Where insulation is installed in unvented rafter ceilings or to the underside of unvented roofsWhere insulation is installed to the underside of unvented roofs, the air barrier shall be uniform across the transition of roof to wall. The insulation shall be in contact with the air barrier. Reasoning: For clarity of intent and so as not to be confused as applicable above or beyond the ceiling plane of a sealed attic wherein the insulation/thermal boundary remains at the ceiling plane and not at the roof deck. 1-1.1.5 Floor Insulation 1-1.1.5.1 Batt and blanket insulation shall be in full contact with the air barrier. 1-1.1.5.2 Faced batts or blankets shall be placed toward the living space and be in contact with the underside of the floor sheathing. Continuous support shall be provided to keep the facing in contact with the floor sheathing. The insulation shall be properly supported by stapling of flanges, netting, or other method approved by the manufacturer and required codes for the product. 1-1.1.5.3 Batt and blanket insulation shall be properly supported to avoid gaps or voids. 1-1.5.1 Floor cavity insulation shall comply with one of the following: 1-1.1.5.1 Insulation shall be installed to maintain permanent contact with the underside of the subfloor decking in accordance with manufacturer instructions to maintain required R-value or readily fill the available cavity space. 1-1.1.5.2 Floor framing cavity insulation shall be permitted to be in contact with top side of sheathing separating the cavity and the unconditioned space below. Insulation shall extend from the bottom to the top of all perimeter floor framing members and the framing members shall be air sealed. 1-1.1.5.3 A combination of cavity and continuous insulation shall be installed so that the cavity insulation is in contact with the top side of the continuous insulation that is installed on the underside of the floor framing separating the cavity and the unconditioned space below. The combined R-value of the cavity and continuous insulation shall equal the required R-value for floors. Insulation shall extend from the bottom to the top of all perimeter floor framing members and the framing members shall be air sealed. Reasoning: To align with verbiage in 2021 IECC, section R402.2.7 1-1.1.5.2 Faced batts or blankets shall be placed toward the living space and be in contact with the underside of the floor sheathing. Continuous support shall be provided to keep the facing in contact with the floor sheathing. The insulation shall be properly supported by stapling of flanges, netting, or other method approved by the manufacturer and required codes for the product. Reasoning: There are various methods for accomplishing continuous support and the Standard should not attempt to limit or define which method is used. The existing stated outcome is what’s relevant. 1-1.1.1.5.5.2 For dwelling units with conditioned space over other unconditioned spaces, the separation between conditioned space and the unconditioned space shall be insulated to create a continuous thermal boundary. All rim and band joists adjoining conditioned space shall be airtight and insulated to the same R-value as exterior walls. Reasoning: It is not technically possible to create a true continuous boundary where framing members intersect. We believe the intent here is that the available surface area be insulated, which the remaining language stipulates. 1-1.2.4.7.2 Where insulation is installed in unvented rafter ceilings or to the underside of roof sheathingWhere insulation is installed to the underside of unvented roofs the air barrier shall be uniform across the transition of roof to wall. The insulation shall be in contact with the air barrier. Reasoning: For clarity of intent and so as not to be confused as applicable above or beyond the ceiling plane of a sealed attic wherein the insulation/thermal boundary remains at the ceiling plane and not at the roof deck. 1-1.2.4.10.2 Where installed, netting shall be securededsecured around conduit, plumbing, roof penetrations and all other obstructions that penetrate the netting. Reasoning: Typo/spelling 1-1.2.5.4.2 For dwelling units with conditioned space over unconditioned spaces, the separation between conditioned space (house) and unconditioned space shall be insulated to create a continuous thermal barrier. All rim and band joists adjoining conditioned space shall be airtight and insulated to the same R-value as exterior walls. Reasoning: It is not technically possible to create a true continuous barrier where framing members intersect. We believe the intent here is that the available surface area be insulated, which the remaining language stipulates. Also, there seems to be interchangeable use of the term “boundary” and “barrier” when referring to the thermal boundary – consideration should be given to consistency of terminology when used. 1-1.3 Medium Density Spray Polyurethane Foam Insulation Q: How is Medium Density defined? 1-1.3.1.2b In cases where a specification requires a minimum thickness or R-value, the average reference thicknesses shall not be below the minimum thickness minus 10%??. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.3.1.2c. No individual measurement shall fall below 25%?? variance per inch for a total installed thickness of up to and including 4 inches. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.3.4.2 If “stand off wall” framing is being used, a percentage of the installed thickness of spray foam qualifies as “continuous” insulation and the remainder as cavity insulation. Consult installation details for information on framing dimensions and stand-off distance. Concern: This condition applies to any insulation type that would fill the void at the stand off wall framing, as does the resulting R-value calculations – both of which are common industry knowledge. Additionally, the issue this verbiage attempts to address are for performance calculations, not installation related. Accordingly, this does not need to be called out in this Standard. 1-1.4 Low Density Spray Polyurethane Foam Insulation Q: How is Low Density defined? 1-1.4.1.2b No more than 10%?? area shall be filled below the required thickness in the cavity. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.4.1.2b No more than 20%?? of the trimmed foam shall contain visible gaps or voids, and no voids may extend from the interior sheathing to the exterior of the cavity. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.4.1.3b In cases where a specification requires a minimum thickness or R-value, the average reference thicknesses shall not be below the minimum thickness minus 10%??. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.4.1.3c No individual measurement shall fall below 25%?? variance per inch for a total installed thickness up to and including 4 inches. Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types. 1-1.7.1.1 Reflective insulation assemblies shall be installed in enclosed cavities that are unventilated. Reasoning: Even in an enclosed cavity the thermal buoyancy will dominate the heat transfer and negate any radiative resistance
October 11, 2021
Residential Energy Services Network (RESNET)
RE: Comments to BSR/RESNET/ICC 301-2019 Addendum E-202x, Appendix A Update, Draft PDS-01
(Cut and Pasted to: https://www1.resnet.us/comments/comment.aspx?DocumentID=62&layout=1)
RESNET Staff:
We appreciate the opportunity to be part of this process and look forward to discussing the additional comments noted herein.
Owens Corning is a leader in fiberglass and related materials, systems and solutions. Our products are largely a result of our applied Building Science and Sustainability efforts which drive our innovation and our global operations. Owens Corning product specifications and operational activities are specifically undertaken with a measurable awareness towards natural resources stewardship as an integral part of our self-imposed sustainability journey. We are also deeply connected to our distributors, installation installers and many HERS Raters/Energy Consultants. Accordingly, we are sensitive to the totality of the following market challenges:
Taking these elements into consideration and with a view towards long-term resource sustainability, durability, occupant comfort and energy efficiency, we offer the following perspectives.
With respect to the current 45-day language, we strongly encourage RESNET to consider the following changes and concerns:
1-1.1.4.4.2 Where insulation is installed in unvented rafter ceilings or to the underside of unvented roofsWhere insulation is installed to the underside of unvented roofs, the air barrier shall be uniform across the transition of roof to wall. The insulation shall be in contact with the air barrier.
Reasoning: For clarity of intent and so as not to be confused as applicable above or beyond the ceiling plane of a sealed attic wherein the insulation/thermal boundary remains at the ceiling plane and not at the roof deck.
1-1.1.5 Floor Insulation
1-1.1.5.1 Batt and blanket insulation shall be in full contact with the air barrier.
1-1.1.5.2 Faced batts or blankets shall be placed toward the living space and be in contact with the underside of the floor sheathing. Continuous support shall be provided to keep the facing in contact with the floor sheathing. The insulation shall be properly supported by stapling of flanges, netting, or other method approved by the manufacturer and required codes for the product.
1-1.1.5.3 Batt and blanket insulation shall be properly supported to avoid gaps or voids.
1-1.5.1 Floor cavity insulation shall comply with one of the following:
1-1.1.5.1 Insulation shall be installed to maintain permanent contact with the underside of the subfloor decking in accordance with manufacturer instructions to maintain required R-value or readily fill the available cavity space.
1-1.1.5.2 Floor framing cavity insulation shall be permitted to be in contact with top side of sheathing separating the cavity and the unconditioned space below. Insulation shall extend from the bottom to the top of all perimeter floor framing members and the framing members shall be air sealed.
1-1.1.5.3 A combination of cavity and continuous insulation shall be installed so that the cavity insulation is in contact with the top side of the continuous insulation that is installed on the underside of the floor framing separating the cavity and the unconditioned space below. The combined R-value of the cavity and continuous insulation shall equal the required R-value for floors. Insulation shall extend from the bottom to the top of all perimeter floor framing members and the framing members shall be air sealed.
Reasoning: To align with verbiage in 2021 IECC, section R402.2.7
Reasoning: There are various methods for accomplishing continuous support and the Standard should not attempt to limit or define which method is used. The existing stated outcome is what’s relevant.
1-1.1.1.5.5.2 For dwelling units with conditioned space over other unconditioned spaces, the separation between conditioned space and the unconditioned space shall be insulated to create a continuous thermal boundary. All rim and band joists adjoining conditioned space shall be airtight and insulated to the same R-value as exterior walls.
Reasoning: It is not technically possible to create a true continuous boundary where framing members intersect. We believe the intent here is that the available surface area be insulated, which the remaining language stipulates.
1-1.2.4.7.2 Where insulation is installed in unvented rafter ceilings or to the underside of roof sheathingWhere insulation is installed to the underside of unvented roofs the air barrier shall be uniform across the transition of roof to wall. The insulation shall be in contact with the air barrier.
1-1.2.4.10.2 Where installed, netting shall be securededsecured around conduit, plumbing, roof penetrations and all other obstructions that penetrate the netting.
Reasoning: Typo/spelling
1-1.2.5.4.2 For dwelling units with conditioned space over unconditioned spaces, the separation between conditioned space (house) and unconditioned space shall be insulated to create a continuous thermal barrier. All rim and band joists adjoining conditioned space shall be airtight and insulated to the same R-value as exterior walls.
Reasoning: It is not technically possible to create a true continuous barrier where framing members intersect. We believe the intent here is that the available surface area be insulated, which the remaining language stipulates. Also, there seems to be interchangeable use of the term “boundary” and “barrier” when referring to the thermal boundary – consideration should be given to consistency of terminology when used.
1-1.3 Medium Density Spray Polyurethane Foam Insulation
Q: How is Medium Density defined?
1-1.3.1.2b In cases where a specification requires a minimum thickness or R-value, the average reference thicknesses shall not be below the minimum thickness minus 10%??.
Concern: This appears to be an arbitrary value and as such one could argue is too lenient in its present form to equate to the required PII condition. Please advise as to how this percentage was determined. Open to discussing less arbitrary metrics that are more on par with other insulation types.
1-1.3.1.2c. No individual measurement shall fall below 25%?? variance per inch for a total installed thickness of up to and including 4 inches.
1-1.3.4.2 If “stand off wall” framing is being used, a percentage of the installed thickness of spray foam qualifies as “continuous” insulation and the remainder as cavity insulation. Consult installation details for information on framing dimensions and stand-off distance.
Concern: This condition applies to any insulation type that would fill the void at the stand off wall framing, as does the resulting R-value calculations – both of which are common industry knowledge. Additionally, the issue this verbiage attempts to address are for performance calculations, not installation related. Accordingly, this does not need to be called out in this Standard.
1-1.4 Low Density Spray Polyurethane Foam Insulation
Q: How is Low Density defined?
1-1.4.1.2b No more than 10%?? area shall be filled below the required thickness in the cavity.
1-1.4.1.2b No more than 20%?? of the trimmed foam shall contain visible gaps or voids, and no voids may extend from the interior sheathing to the exterior of the cavity.
1-1.4.1.3b In cases where a specification requires a minimum thickness or R-value, the average reference thicknesses shall not be below the minimum thickness minus 10%??.
1-1.4.1.3c No individual measurement shall fall below 25%?? variance per inch for a total installed thickness up to and including 4 inches.
1-1.7.1.1 Reflective insulation assemblies shall be installed in enclosed cavities that are unventilated.
Reasoning: Even in an enclosed cavity the thermal buoyancy will dominate the heat transfer and negate any radiative resistance
Comment #40Page Number: 38Paragraph / Figure / Table / Note: 1-1.1.2Comment Intent: ObjectionComment Type: TechnicalComment: 1-1.1.2 Air Barrier Requirements 1-1.1.2.1 Insulation shall be enclosed with an air barrier on all six sides with permanent materials except for the following: a.Insulation installed in vented attics above ceilings shall not require an air barrier on the exterior side. b.Insulation installed under floors directly above an unvented crawl space or basement shall not require an air barrier on the side facing the crawl space or basement. c.Insulation installed in rim or band joists located in conditioned space shall not require an air barrier on the interior side. d.Insulation installed in knee walls shall not require an air barrier on the exterior side. Item d. is a reversal of our understanding of industry standards. We have been calling out and failing all knee walls in attics that do not have an attic side air barrier. To be fully effective any fibrous insulation in a vertical assembly needs to be encapsulated on all 6 sides. This is also in contradiction to IECC table R402.4.1.1 (2015) which specifically states that “knee walls shall be sealed” and “Exterior thermal envelope insulation for framed walls shall be installed in substantial contact and continuous alignment with the air barrier.” Proposed Change: RECOMMENDATION; Strike item d. from this list of exceptions. This holds true to section 1-1.2.2 (page 8) as well.
Item d. is a reversal of our understanding of industry standards. We have been calling out and failing all knee walls in attics that do not have an attic side air barrier. To be fully effective any fibrous insulation in a vertical assembly needs to be encapsulated on all 6 sides. This is also in contradiction to IECC table R402.4.1.1 (2015) which specifically states that “knee walls shall be sealed” and “Exterior thermal envelope insulation for framed walls shall be installed in substantial contact and continuous alignment with the air barrier.”
RECOMMENDATION;
Strike item d. from this list of exceptions. This holds true to section 1-1.2.2 (page 8) as well.
Comment #41Page Number: 1-25Paragraph / Figure / Table / Note: 4.2.2.2.2Comment Intent: ObjectionComment Type: GeneralComment: 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 propose that Addendum E-202x be stricken in its entirety. These changes would not improve the issue of subjectivity in the grading of insulation and would create undue burden on stakeholders throughout the industry, including but not limited to Raters, RFIs, QADs, and software development. It would also create a ripple effect throughout programs that reference the ANSI 301 standard, such as ENERGY STAR. Further, we are concerned about the confusion that would be created in regards to the transition between the existing grading standard and this proposed change. Proposed Change: Modify Section 4.2.2.2.2. as follows: 4.2.2.2.2. Insulation Assessment: Properly Installed insulation as defined in Appendix A, (Inspection procedures for Insulation Type and Proper Insulation installation (PII)), Insulated surfaces categorized as “Grade I” shall be modeled such that the insulation R-Value is considered at its measured (for loose fill, spray foam, etc.), or labeled (when an R-value mark is provided by the manufacturer), or installer certified value, including other adjustments,[1] as described in Appendix A.for the insulated surface area (not including framing or other structural materials which shall be accounted for separately). Insulated surfaces categorized as “Grade II” shall be modeled such that there is no insulation R-Value for 2 percent of the insulated surface area and its measured or labeled value, including other adjustments,[2] for the remainder of the insulated surface area (not including framing or other structural materials). Installed insulation that is deemed to not be properly installed (NPI) in accordance with Appendix A Insulated surfaces categorized as “Grade III” shall be modeled such that there is no insulation R-Value for 105 percent of the insulated surface area and its measured or labeled value, including other adjustments as described in Appendix A. ,[3] for the remainder of the insulated surface area (not including framing or other structural materials). Other building materials, including framing, sheathing and air films, shall be assigned aged or settled values according to ASHRAE Handbook of Fundamentals. In addition, the following accepted conventions shall be used in modeling Rated Home insulation enclosures (a) Insulation that does not cover framing members shall not be modeled as if it covers the framing. Insulated surfaces that have continuous insulation, including rigid foam, fibrous batt, loose fill, sprayed insulation or insulated siding, covering the framing members shall be assessed and modeled according to Section 4.2.2.2 and combined with the cavity insulation, framing and other materials to determine the overall assembly R-Value. (b) The base R-Value of fibrous batt insulation that is compressed to less than its full rated thickness in a completely enclosed cavity shall be assessed as described in Appendix A.according to the manufacturer’s documentation. In the absence of such documentation, use R-Value correction factor (CF) for Compressed Batt or Blanket from ACCA Manual J, 8th edition, Appendix 4. (c) Areas of an assembly having different insulation types or R-Values (including uninsulated areas in excess of 5 percent of any otherwise insulated building component) shall be modeled separately with the applicable R-Values and assembly areas associated with each different insulation situation. (d) The overall thermal properties of steel-framed walls, ceilings and floors shall be calculated in accordance with the modified zone method specified by Chapter 27, ASHRAE Handbook of Fundamentals or tested in accordance with ASTM Standard C1363. Modification of test results to add or subtract R-Values to the tested assembly that reflect differences between the tested assembly and proposed assemblies is authorized when such differences are continuous and occur outside of the cavity. For brevity, I will not include the entire text to be stricken. We propose striking the entire addendum, maintaining the current Appendix A language. Strike ALL of ANSI/RESNET/ICC 301-2019 Appendix A and replace with the following:
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 propose that Addendum E-202x be stricken in its entirety. These changes would not improve the issue of subjectivity in the grading of insulation and would create undue burden on stakeholders throughout the industry, including but not limited to Raters, RFIs, QADs, and software development. It would also create a ripple effect throughout programs that reference the ANSI 301 standard, such as ENERGY STAR. Further, we are concerned about the confusion that would be created in regards to the transition between the existing grading standard and this proposed change.
Modify Section 4.2.2.2.2. as follows:
4.2.2.2.2. Insulation Assessment: Properly Installed insulation as defined in Appendix A, (Inspection procedures for Insulation Type and Proper Insulation installation (PII)), Insulated surfaces categorized as “Grade I” shall be modeled such that the insulation R-Value is considered at its measured (for loose fill, spray foam, etc.), or labeled (when an R-value mark is provided by the manufacturer), or installer certified value, including other adjustments,[1] as described in Appendix A.for the insulated surface area (not including framing or other structural materials which shall be accounted for separately). Insulated surfaces categorized as “Grade II” shall be modeled such that there is no insulation R-Value for 2 percent of the insulated surface area and its measured or labeled value, including other adjustments,[2] for the remainder of the insulated surface area (not including framing or other structural materials). Installed insulation that is deemed to not be properly installed (NPI) in accordance with Appendix A Insulated surfaces categorized as “Grade III” shall be modeled such that there is no insulation R-Value for 105 percent of the insulated surface area and its measured or labeled value, including other adjustments as described in Appendix A. ,[3] for the remainder of the insulated surface area (not including framing or other structural materials). Other building materials, including framing, sheathing and air films, shall be assigned aged or settled values according to ASHRAE Handbook of Fundamentals. In addition, the following accepted conventions shall be used in modeling Rated Home insulation enclosures
(a) Insulation that does not cover framing members shall not be modeled as if it covers the framing. Insulated surfaces that have continuous insulation, including rigid foam, fibrous batt, loose fill, sprayed insulation or insulated siding, covering the framing members shall be assessed and modeled according to Section 4.2.2.2 and combined with the cavity insulation, framing and other materials to determine the overall assembly R-Value.
(b) The base R-Value of fibrous batt insulation that is compressed to less than its full rated thickness in a completely enclosed cavity shall be assessed as described in Appendix A.according to the manufacturer’s documentation. In the absence of such documentation, use R-Value correction factor (CF) for Compressed Batt or Blanket from ACCA Manual J, 8th edition, Appendix 4.
(c) Areas of an assembly having different insulation types or R-Values (including uninsulated areas in excess of 5 percent of any otherwise insulated building component) shall be modeled separately with the applicable R-Values and assembly areas associated with each different insulation situation.
(d) The overall thermal properties of steel-framed walls, ceilings and floors shall be calculated in accordance with the modified zone method specified by Chapter 27, ASHRAE Handbook of Fundamentals or tested in accordance with ASTM Standard C1363. Modification of test results to add or subtract R-Values to the tested assembly that reflect differences between the tested assembly and proposed assemblies is authorized when such differences are continuous and occur outside of the cavity.
Strike ALL of ANSI/RESNET/ICC 301-2019 Appendix A and replace with the following:
Comment #42Page Number: 1-25Paragraph / Figure / Table / Note: 4.2.2.2.2Comment Intent: ObjectionComment Type: GeneralComment: e Number: 1-25 Paragraph / Figure / Table / Note: 4.2.2.2.2 Comment Intent: Objection Comment Type: General Comment: A concern In southern climates where the insulation type chosen is predominantly batt, imposing a PII or NPI grading system will prevent the builder from being allowed to have certain minor defects and be responsible for the repairs without having to stop production, pay for a reinspection, and potentially have to go through that process multiple times. This sytem will cause many more homes to fail code compliance to avoid the penalty within the rating that have both ratings and code compliance performed simultaneously. With the current shortage of quality labor and the difficulty with installing batt insulation correctly, this has the potential to negatively impact the production home industry to the point where ratings may become less valuable. There's an ongoing struggle to complete homes on time as it is. We understand there's a need for some change in how insulation is graded/rated, but this seems to not be the correct time or approach. We don't anticipate this addendum having the positive results for more consistent ratings as intended, but rather more penalty, higher indexes, or dissention from the rating industry. The change as written will require a training overhaul of all stakeholders including Raters, RFIs, QADs, insulation vendors, builders, code officials, data collection platforms, softwares,etc. This also digresses from other rating methodology such as standard 310 which is entirely based on a tiered grading system. How will EEPs such as Energy Star be guaged? If an Energy Star home has continuos insulation around the frame currently, grade 2 insulation is acceptable. Wiil an Energy Star builder partner not get additional credit for CI and have to have the cavity insulation installed the same either way? Pre-drywall insulation QA has just been approved for use to meet the field QA quota. This hasn't been available long enough to drive any change or increase conformity. There's little guidance within the language on how the standard will be inspected. Does one minor defect in an assembly cause an NPI and a 10% penalty? Can that be justified? If the grading needs to be changed to a pass/fail approach, then it makes more sense to us that the penalty be lowered from 10% to 5% for R-0 so theres not such a negative impact on the index when too many other variables are not factored in. We believe this could potentially have another unintended negative consequence. Raters will be more likely to pass (PII) homes that would have received a grade 2 in current standards. Or, if follow manufacturer's installation instructions and fail more homes under the current addendum language, may potentially lose clients to other Raters who will be more willing to give a PII on homes that should have been graded an NPI to gain the business. Proposed Change: Strike out entire addendum and maintain current Appendix A, or Model 5% as R-0 vs 10% if PII and NPI are to replace tiered grading.
Strike out entire addendum and maintain current Appendix A, or Model 5% as R-0 vs 10% if PII and NPI are to replace tiered grading.