BSR/RESNET/ICC 301-2019 Addendum C-202x, draft PDS-01 Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: 28
Paragraph / Figure / Table / Note: 4.2.2(1)
Comment Intent: Objection
Comment Type: General

Comment:

For untested systems that meet the requirements for the duct testing exemption DSE = 1.0. For systems that do not meet the requirements for the system then they should equal DSE= 0.70 

Proposed Change:

For untested forced air distribution systems: That meet the duct testing exemption DSE= 1.0. For duct systems that do not meet the exemption DSE=0.70

For tested f

Comment #2

Page Number: 28
Paragraph / Figure / Table / Note: 4.2.2(1)
Comment Intent: Objection
Comment Type: General

Comment:

For untested systems that meet the requirements for the duct testing exemption DSE = 1.0. For systems that do not meet the requirements for the system then they should equal DSE= 0.70 

Proposed Change:

For untested forced air distribution systems: That meet the duct testing exemption DSE= 1.0. For duct systems that do not meet the exemption DSE=0.70

For tested f

Comment #3

Page Number: 35
Paragraph / Figure / Table / Note: x.2
Comment Intent: Objection
Comment Type: Technical

Comment:

For untested forced air distribution systems: That meet the duct testing exemption DSE= 1.0. For duct systems that do not meet the exemption DSE=0.70 to match the table above.

 

Proposed Change:

If at a pre-drywall stage of construction, the ductwork is visually verified to be 100 percent fully ducted with no building cavities used as supply or return ducts, a DSE of 0.88 1.0 shall be applied to both the heating and cooling system efficiencies.

 

Comment #4

Page Number: 28
Paragraph / Figure / Table / Note: x.2
Comment Intent: Objection
Comment Type: General

Comment:

The concept of a duct leakage exception is acceptable based on the presuposition that the untested distrobution system would be as good, not applicable, or better than the proposed testing. 2021 IECC R403.3.6 allows duct leaking thresholds up to 8 cfm per 100 square feet so a DSE of .92 should be the applied DSE exemption rate applied to both the heating and cooling system efficiencies [OR] duct leakage exemptions for ducts within the thermal envelope should be disallowed. 

Proposed Change:

If at a pre-drywall stage of construction, the ductwork is visually verified to be 100 percent fully ducted with no building cavities used as supply or return ducts, a DSE of 0.88 0.92 shall be applied to both the heating and cooling system efficiencies.

 

Comment #5

Page Number: p28 & p35
Paragraph / Figure / Table / Note: Table 4.2.2(1), row "Thermal Distribution Systems"
Comment Intent: Objection
Comment Type: Technical

Comment:

While I am fine with the intent, there is an internal conflict presented by the new Rated Home distinctions for Untested  vs Tested forced air distribution.

The imperative "For untested forced air distribution systems: DSE=0.70" contradicts the test-exempt simulation options specified in Note (x) to Table 4.2.2(1).  Systems that are exempted from testing are inherently untested.

The language conflict can be avoided and greater clarity achieved by tabulating all the options for untested forced-air thermal distribution systems, as follows:

Distribution System

DSE

Untested forced air distribution

0.70

Test Exempt:

  • 100% of Ductwork & AH contained with CSV

0.80

Test Exempt:

  • 100% of Ductwork & AH contained with CSV
  • And, fully ducted with no building cavities used as supply or return ducts

0.88