Comment #1Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 3Paragraph / Figure / Table / Note: 2Comment Type: TechnicalComment:The proposed amendment still includes ... "If these spaces contain terminal HVAC supply devices that provide less than 10 Btu/hour per square foot, or if there is less than 15 CFM of supply air for every 100 square feet of floor area, these spaces must not be included as conditioned floor area." I would like to see an exception, that if the airflow is within 10% of Manual J, than the 15 CFM per 100 sq ft is not applicable. Justification for Change:We emphasize correct sizing and correct airflow but the tools that decide it are not referenced as an verification method. I see many instances where the Manual J 8th Ed calls for less airflow in a basement. I have seen some reports showing 8CFM/100 sq ft was all that was req. Proposed Change:"If these spaces contain terminal HVAC supply devices that provide less than 10 Btu/hour per square foot, or if there is less than 15 CFM of supply air for every 100 square feet of floor area, these spaces must not be included as conditioned floor area. Exception, if the airflow is within 10% of Manual J, than the 15 CFM per 100 sq ft does not apply."
The proposed amendment still includes ...
"If these spaces contain terminal HVAC supply devices that provide less than 10 Btu/hour per square foot, or if there is less than 15 CFM of supply air for every 100 square feet of floor area, these spaces must not be included as conditioned floor area."
I would like to see an exception, that if the airflow is within 10% of Manual J, than the 15 CFM per 100 sq ft is not applicable.
We emphasize correct sizing and correct airflow but the tools that decide it are not referenced as an verification method.
I see many instances where the Manual J 8th Ed calls for less airflow in a basement. I have seen some reports showing 8CFM/100 sq ft was all that was req.
"If these spaces contain terminal HVAC supply devices that provide less than 10 Btu/hour per square foot, or if there is less than 15 CFM of supply air for every 100 square feet of floor area, these spaces must not be included as conditioned floor area.
Exception, if the airflow is within 10% of Manual J, than the 15 CFM per 100 sq ft does not apply."
Comment #2Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 34-35Paragraph / Figure / Table / Note: oneComment Type: TechnicalComment:Power flow hods are not the only devices used to measure ventilation. Non-powered Balometer should also be included in the perferred equipment. This seems to be favoring one manufactor over others.Justification for Change:Non-powered devices which have been used in commercial applications longer than residential.Proposed Change:I recommend reconsideration of this section on measuring ventilation.
Power flow hods are not the only devices used to measure ventilation. Non-powered Balometer should also be included in the perferred equipment. This seems to be favoring one manufactor over others.
Non-powered devices which have been used in commercial applications longer than residential.
I recommend reconsideration of this section on measuring ventilation.
Comment #3Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: AllComment Type: GeneralComment:The procedural directive to measure/inspect/determine has been lost in translating the current Appendix A to this proposed language. The "task" column in the table in current Appendix A directs the rater to measure/inspect/determine characteristics/performance of the building elements. I recommend wholesale editing of this proposed language to reintroduce the original language directing raters to measure/inspect/determine.Justification for Change:Without appropriate language this normative Appendix does not sufficiently constitute on-site verification procedures needed to support the rating system.Proposed Change:Edit proposed amendment as appropriate to include language in "task" column of table in Appendix A in existing standard.
The procedural directive to measure/inspect/determine has been lost in translating the current Appendix A to this proposed language. The "task" column in the table in current Appendix A directs the rater to measure/inspect/determine characteristics/performance of the building elements. I recommend wholesale editing of this proposed language to reintroduce the original language directing raters to measure/inspect/determine.
Without appropriate language this normative Appendix does not sufficiently constitute on-site verification procedures needed to support the rating system.
Edit proposed amendment as appropriate to include language in "task" column of table in Appendix A in existing standard.
Comment #4Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 20Comment Type: TechnicalComment:Current Standard, including Appendix A, does list HVAC equipment rated output capacity as a minimum rated feature. I recommend adding this to Appendix A.Justification for Change:The information is needed in 303.5.1.4.Proposed Change:Determine the rated output capacity of the space heating and cooling equipment. This information may be collected from manufacturer's label afixed to the equipment or from the appropriate appliance directory from AHRI using the model number from label afxied to the equipment.
Current Standard, including Appendix A, does list HVAC equipment rated output capacity as a minimum rated feature. I recommend adding this to Appendix A.
The information is needed in 303.5.1.4.
Determine the rated output capacity of the space heating and cooling equipment. This information may be collected from manufacturer's label afixed to the equipment or from the appropriate appliance directory from AHRI using the model number from label afxied to the equipment.
Comment #5Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 3Comment Type: EditorialComment:As written: Measure the house or assembly element (window, wall, ceiling, etc.) to the nearest inch, and record the square footage to the nearest square foot.Justification for Change:Rounding individual windows to nearest square foot might introduce higher than necessary rounding errors.Proposed Change:Measure the house or assembly element (window, wall, ceiling, etc.) to the nearest inch, and record the total area for each type of element to the nearest square foot.
As written:
Measure the house or assembly element (window, wall, ceiling, etc.) to the nearest inch, and record the square footage to the nearest square foot.
Rounding individual windows to nearest square foot might introduce higher than necessary rounding errors.
Measure the house or assembly element (window, wall, ceiling, etc.) to the nearest inch, and record the total area for each type of element to the nearest square foot.
Comment #6Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 4Comment Type: EditorialComment:delete second paragraph (divide basement and crawl walls into above and below grade).Justification for Change:duplicates what has already been stated on previous page (3).Proposed Change:detete the paragraph "Note to divide basement and crawl space walls into above and below grade."
delete second paragraph (divide basement and crawl walls into above and below grade).
duplicates what has already been stated on previous page (3).
detete the paragraph "Note to divide basement and crawl space walls into above and below grade."
Comment #7Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 4Comment Type: EditorialComment:As written, "Measure the area of the window or skylight openings to the nearest inch. Calculate the area using the measured width multiplied by the height."Justification for Change:Make wording consistent wording with previous text. Also, the Standard requires window areas to be recorded by orientation.Proposed Change:Measure the area of the windows and skylights to the nearest inch, and record the total area for each orientation to the nearest foot.
As written,
"Measure the area of the window or skylight openings to the nearest inch. Calculate the area using the measured width multiplied by the height."
Make wording consistent wording with previous text. Also, the Standard requires window areas to be recorded by orientation.
Measure the area of the windows and skylights to the nearest inch, and record the total area for each orientation to the nearest foot.
Comment #8Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5-10Comment Type: EditorialComment:numerous inappropriate language throughout the insulation and grading section: "must require" (1 instance) "must not require" (5 instances) "must be permitted to" (5 instances) "must not be permitted" (9 instances)Justification for Change:This wording is inappropriate for a standard.Proposed Change:must require => must have (1 instance) must not require => is not required to have (5 instances) must be permitted => must or may, depending on context (5 instances) must not be permitted => are not allowed (9 instances)
numerous inappropriate language throughout the insulation and grading section:
"must require" (1 instance)
"must not require" (5 instances)
"must be permitted to" (5 instances)
"must not be permitted" (9 instances)
This wording is inappropriate for a standard.
must require => must have (1 instance)
must not require => is not required to have (5 instances)
must be permitted => must or may, depending on context (5 instances)
must not be permitted => are not allowed (9 instances)
Comment #9Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: numerousComment Type: TechnicalComment:Pg. 2 paragraph 2: The statement "Conditioned floor area does not include spaces such as uninsulated basements or attics that are unfinished, if there is no intentional HVAC supply or if the HVAC supply is inadequate to be considered directly conditioned space according to the definition in Appendix B of these Standards" is misleading. This would seem to indicate that unfinished or uninsulated attics with supply air going to them would be allowed to be considered part of CFA, even though that is ridiculous. Attics should NEVER be part of CFA unless they are fully finished and conditioned living spaces. Thus, you need to differentiate from basements, wihch can be unfinished and uninsulated but still have the floor area counted as CFA such as in existing homes as the spaces are used as living area, from attics which are almost never used in this way and thus should never be part of CFA. You should also make a statement regarding crawlspaces never being part of CFA. Pg 3 paragraph 2: This entire paragraph is really misleading. Once again, when did we start including attics and crawlspaces in CFA? My understanding is that CFA has a very specific purpose, which is to have the softwrae calculate sqft normalized cost and consumption parameters which simulate people living in a home. PEOPLE DO NOT LIVE IN ATTICS OR CRAWLSPACES. This is a real step in the wrong direction if you start to allow this because A) it is totally illogical and B) it will make logical people like me have the impossible job of explaining why crawlspaces and attics can be included in CFA during HERS courses when i know for a fact they should not. Thus, my opinion is that you cannot lump in basements, crawlspaces and attics all together in this. Basements are a different animal in which, due the prevelance of unfinished but conditioned basements in existing homes, it actually makes it easier to allow people to include them in CFA from a comprehension standpoint. With attics/crawls being included in this you are mucking up logic. Pg 4: Shouldn't it mention that windows are measured using the RO dimension? You mention that the exterior of the frame is included for existing homes... but isnt this also true for new construction? Pg 9: With this new wording of insulation grading, there are only 3 categories: Perfect, less than perfect, nothing. To make GIII = uninsulated means you really only have two choices... GI and GII... this is a step in the wrong direction, as I think GIII should be a separate definition that is more similar to how it once was (ie 5% missing or whatnot). Also, how practical is it to have a separate guide for grading radiant barriers and reflective insulation? I just don't see the value. Pg 14: The definitions of covered vs exposed don't make a lot of sense to me. Why would floors with a floor covering not be considered as having one? To me this is an erroneous distinction and should be scrapped. Pg 28: For interior doors, conditoined space boundary should be referenced in Appendix B Pg 28-: I don't see the value of repeating the informatoin contained in Chapter 8 here. Instead, Chapter 8 should simply be referenced. Justification for Change:I think the above are techincal flaws with the standard which should be reconsidred. Proposed Change:See above
Pg. 2 paragraph 2: The statement "Conditioned floor area does not include spaces such as uninsulated basements or attics that are unfinished, if there is no intentional HVAC supply or if the HVAC supply is inadequate to be considered directly conditioned space according to the definition in Appendix B of these Standards" is misleading. This would seem to indicate that unfinished or uninsulated attics with supply air going to them would be allowed to be considered part of CFA, even though that is ridiculous. Attics should NEVER be part of CFA unless they are fully finished and conditioned living spaces. Thus, you need to differentiate from basements, wihch can be unfinished and uninsulated but still have the floor area counted as CFA such as in existing homes as the spaces are used as living area, from attics which are almost never used in this way and thus should never be part of CFA. You should also make a statement regarding crawlspaces never being part of CFA.
Pg 3 paragraph 2: This entire paragraph is really misleading. Once again, when did we start including attics and crawlspaces in CFA? My understanding is that CFA has a very specific purpose, which is to have the softwrae calculate sqft normalized cost and consumption parameters which simulate people living in a home. PEOPLE DO NOT LIVE IN ATTICS OR CRAWLSPACES. This is a real step in the wrong direction if you start to allow this because A) it is totally illogical and B) it will make logical people like me have the impossible job of explaining why crawlspaces and attics can be included in CFA during HERS courses when i know for a fact they should not. Thus, my opinion is that you cannot lump in basements, crawlspaces and attics all together in this. Basements are a different animal in which, due the prevelance of unfinished but conditioned basements in existing homes, it actually makes it easier to allow people to include them in CFA from a comprehension standpoint. With attics/crawls being included in this you are mucking up logic.
Pg 4: Shouldn't it mention that windows are measured using the RO dimension? You mention that the exterior of the frame is included for existing homes... but isnt this also true for new construction?
Pg 9: With this new wording of insulation grading, there are only 3 categories: Perfect, less than perfect, nothing. To make GIII = uninsulated means you really only have two choices... GI and GII... this is a step in the wrong direction, as I think GIII should be a separate definition that is more similar to how it once was (ie 5% missing or whatnot). Also, how practical is it to have a separate guide for grading radiant barriers and reflective insulation? I just don't see the value.
Pg 14: The definitions of covered vs exposed don't make a lot of sense to me. Why would floors with a floor covering not be considered as having one? To me this is an erroneous distinction and should be scrapped.
Pg 28: For interior doors, conditoined space boundary should be referenced in Appendix B
Pg 28-: I don't see the value of repeating the informatoin contained in Chapter 8 here. Instead, Chapter 8 should simply be referenced.
I think the above are techincal flaws with the standard which should be reconsidred.
See above
Comment #10Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: allComment Type: GeneralComment:The document would be much easier to reference, teach from and share if there were a numbering system (e.g. A 1.1 would be Appendix A item 1.1). Justification for Change:ease of useProposed Change:edit to have such a reference system
The document would be much easier to reference, teach from and share if there were a numbering system (e.g. A 1.1 would be Appendix A item 1.1).
ease of use
edit to have such a reference system
Comment #11Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 40Comment Type: TechnicalComment:Requires testing of direct or power vented combustion appliances at the termination. This can often terminate at the roof thus requiring testing on the roof. Direct or power vented combustion appliances are less of a concern for testing of CO since they don't rely on indoor (occupant) air for combustion. More of a concern is when a sealed unit is not gasketed for gas pentetrations.Justification for Change:Being on the roof puts HERS Raters (an endangered species) at much more risk. Especially the moutain rater (higher risk endangerment) with snow and icy roofs. It also would increase the costs of insurance for some companies as insurance companies jack up the rates if a company policy allows for employees to go on roofs.Proposed Change:Consider exempting this requirement when the termination is at the roof. In thise case the rater can check for ambient CO levels instead and inspect that the system is fully sealed with gaskets at the furnace cabinet.
Requires testing of direct or power vented combustion appliances at the termination. This can often terminate at the roof thus requiring testing on the roof. Direct or power vented combustion appliances are less of a concern for testing of CO since they don't rely on indoor (occupant) air for combustion. More of a concern is when a sealed unit is not gasketed for gas pentetrations.
Being on the roof puts HERS Raters (an endangered species) at much more risk. Especially the moutain rater (higher risk endangerment) with snow and icy roofs. It also would increase the costs of insurance for some companies as insurance companies jack up the rates if a company policy allows for employees to go on roofs.
Consider exempting this requirement when the termination is at the roof. In thise case the rater can check for ambient CO levels instead and inspect that the system is fully sealed with gaskets at the furnace cabinet.
Comment #12Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 39Comment Type: TechnicalComment:Standard says “When spillage occurs or CO exceeds the limits specified below in section 9” (on proposed page 39), but I don't see where section 9 exists and don’t see limits anywhere in Appendix A.Justification for Change:Need limits to apply StandardProposed Change:Create CO Limits Chart
Standard says “When spillage occurs or CO exceeds the limits specified below in section 9” (on proposed page 39), but I don't see where section 9 exists and don’t see limits anywhere in Appendix A.
Need limits to apply Standard
Create CO Limits Chart
Comment #13Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 8Comment Type: TechnicalComment:Why does open cell SPF insulation allow for 1 inch variance from specified thickness for grade I, and closed cell 3/4 inch, while others are only allowed 1/2 inch voids?Justification for Change:Shouldn't they all insulation be graded by the same variance in thickness?Proposed Change:Provide explanation why SPF is allowed more flexibility or have all insulation thickness variance be the same regadless of type.
Why does open cell SPF insulation allow for 1 inch variance from specified thickness for grade I, and closed cell 3/4 inch, while others are only allowed 1/2 inch voids?
Shouldn't they all insulation be graded by the same variance in thickness?
Provide explanation why SPF is allowed more flexibility or have all insulation thickness variance be the same regadless of type.
Comment #14Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Comment Type: EditorialComment:Batt insulation 2a---The way this is read it could be interpreted that attic kneewall insulation when "installed in an attic above a ceiling must not require an air barrier"...this is confusing and could be misread. It should be written that "ceiling insulation with attic space above must not require an air barrier on the attic side". to clarify this only applies to ceiling insualtion.Justification for Change:If I were playing devils advocate I could interpret the phrase "insulation installed in an attic above a ceiling" to be kneewall insulation that is in an "attic above a ceiling" would not require an air barrier, which is not the intent.Proposed Change:rephrase to clarify that this only applies to ceiling insulation not vertical attic kneewalls.
Batt insulation 2a---The way this is read it could be interpreted that attic kneewall insulation when "installed in an attic above a ceiling must not require an air barrier"...this is confusing and could be misread. It should be written that "ceiling insulation with attic space above must not require an air barrier on the attic side". to clarify this only applies to ceiling insualtion.
If I were playing devils advocate I could interpret the phrase "insulation installed in an attic above a ceiling" to be kneewall insulation that is in an "attic above a ceiling" would not require an air barrier, which is not the intent.
rephrase to clarify that this only applies to ceiling insulation not vertical attic kneewalls.
Comment #15Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 9Paragraph / Figure / Table / Note: Grade 3Comment Type: TechnicalComment:Page 9, Grade 3 second paragraph---This section implies we must model grade 3 as uninsulated? I think the difference between grade 3 and uninsulated should be defined whereas if an install is less than grade 3, then that percentage of excess voids or compressed area should be modeled as uninsulated or as a different insulation level. am I looking at this wrong?Justification for Change:This could be misinterpreted that anything less than Grade 2 would be considered uninsulated which would be inaccurate.Proposed Change:The difference between grade 3 and uninsulated should be defined whereas if an install is less than grade 3, then that percentage of excess voids or compressed area should be naoted as uninsulated or at a different insulation level.
Page 9, Grade 3 second paragraph---This section implies we must model grade 3 as uninsulated? I think the difference between grade 3 and uninsulated should be defined whereas if an install is less than grade 3, then that percentage of excess voids or compressed area should be modeled as uninsulated or as a different insulation level. am I looking at this wrong?
This could be misinterpreted that anything less than Grade 2 would be considered uninsulated which would be inaccurate.
The difference between grade 3 and uninsulated should be defined whereas if an install is less than grade 3, then that percentage of excess voids or compressed area should be naoted as uninsulated or at a different insulation level.
Comment #16Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: allComment Type: GeneralComment:•Why do we have two testing procedures in the standard? Shouldn't Appendix A just reference chapter 8 for each of these tests?Justification for Change:Consistency and elminate confusion with have testing standards in two different sectionsProposed Change:Reference Chapter 8 for each of the tests required in Appendix A
•Why do we have two testing procedures in the standard? Shouldn't Appendix A just reference chapter 8 for each of these tests?
Consistency and elminate confusion with have testing standards in two different sections
Reference Chapter 8 for each of the tests required in Appendix A
Comment #17Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Comment Type: EditorialComment:2.a. "Insulation installed in attics above ceilings..."Justification for Change:as written, this exception could be construced as applying to knee walls, which it clearly should notProposed Change:Insulation installed in attics on ceilings... OR Ceiling insulation below an attic...
2.a. "Insulation installed in attics above ceilings..."
as written, this exception could be construced as applying to knee walls, which it clearly should not
Insulation installed in attics on ceilings... OR Ceiling insulation below an attic...
Comment #18Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Comment Type: TechnicalComment:2.b. "Insulation installed under floors directly above an unvented crawl space must not require an air barrier on the exterior side."Justification for Change:since floors above unvented crawl are typically uninsulated, it's not clear whether this exception was meant to apply to vented crawls? (also, the phrase "must not require" further confuses the intent, as already noted in Comment #8) Proposed Change:unclear of intent so cannot propose new wording
2.b. "Insulation installed under floors directly above an unvented crawl space must not require an air barrier on the exterior side."
since floors above unvented crawl are typically uninsulated, it's not clear whether this exception was meant to apply to vented crawls? (also, the phrase "must not require" further confuses the intent, as already noted in Comment #8)
unclear of intent so cannot propose new wording
Comment #19Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Comment Type: EditorialComment:6.a. "Insulation installed in attics and ceilings must require an air barrier on the exterior or interior side." 6.b. "Insulation installed under floors that is directly above an unvented crawl space must not require an air barrier on the exterior side."Justification for Change:wording is confusing - exception 6.a. same as Comment #17, exception 6.b., same as Comment #18Proposed Change:see comment #17, #18
6.a. "Insulation installed in attics and ceilings must require an air barrier on the exterior or interior side."
6.b. "Insulation installed under floors that is directly above an unvented crawl space must not require an air barrier on the exterior side."
wording is confusing - exception 6.a. same as Comment #17, exception 6.b., same as Comment #18
see comment #17, #18
Comment #20Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 9-13Comment Type: TechnicalComment:As written, the new sections on insulation grading stipulate that Grade 3 insulation be modeled as uninsulated. This defeats the purpose of having a Grade 3 category! Also, the Standard makes it clear that only those areas that fail to meet Grade 3 installation criteria should be modeled as uninsulated, not the entire assembly, as currently written in the amendment. The new sections on reflective / radiant insulation appear to define 2 grading categories, with Grade 3 being superfluous. If the intent is to not give credit for areas with less than 90% coverage, then only 2 grades should be defined. A minor point: Standard refers to Grades I, II, and III, whereas amendment refers to Grades 1, 2 and 3.Justification for Change:References to Grade 3 being modeled as uninsulated are conflict with Section 303.4.1.4.2, Proposed Change:rewrite insulation grading sections to be consistent with Standard.
As written, the new sections on insulation grading stipulate that Grade 3 insulation be modeled as uninsulated. This defeats the purpose of having a Grade 3 category! Also, the Standard makes it clear that only those areas that fail to meet Grade 3 installation criteria should be modeled as uninsulated, not the entire assembly, as currently written in the amendment.
The new sections on reflective / radiant insulation appear to define 2 grading categories, with Grade 3 being superfluous. If the intent is to not give credit for areas with less than 90% coverage, then only 2 grades should be defined.
A minor point: Standard refers to Grades I, II, and III, whereas amendment refers to Grades 1, 2 and 3.
References to Grade 3 being modeled as uninsulated are conflict with Section 303.4.1.4.2,
rewrite insulation grading sections to be consistent with Standard.
Comment #21Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 11Comment Type: EditorialComment:3. Exception: Nonstandard cavity widths. Face-stapled reflective insulation should be cut to fit non-standard cavity widths. No exception is necessary since bullet 3 already stipulates that it must match the cavity width.Justification for Change:exception is unnecessaryProposed Change:delete exception for nonstandard cavity widths
3. Exception: Nonstandard cavity widths.
Face-stapled reflective insulation should be cut to fit non-standard cavity widths. No exception is necessary since bullet 3 already stipulates that it must match the cavity width.
exception is unnecessary
delete exception for nonstandard cavity widths
Comment #22Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 13Comment Type: EditorialComment:Framed Floors section does not address floors over unconditioned crawls and basements. Justification for Change:correct an omissionProposed Change:add paragraph that addresses floors over unconditioned crawls and basements
Framed Floors section does not address floors over unconditioned crawls and basements.
correct an omission
add paragraph that addresses floors over unconditioned crawls and basements
Comment #23Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 22Comment Type: GeneralComment:Confusing description: Ground source heat pumps - are coupled to the ground through the use of a water well sometimes the same well as used for domestic water (known as "open loop" which water or a water/antifreeze mixture is circulated (known as "closed loop"). Justification for Change:This paragraph is poorly written. No need to mention that some open loop GSHP's use the domestic water well.Proposed Change:Ground source heat pumps are coupled to the ground through a closed loop of horizontal or vertical tubing or through an open loop drawing water from a water well.
Confusing description:
Ground source heat pumps - are coupled to the ground through the use of a water well sometimes the same well as used for domestic water (known as "open loop" which water or a water/antifreeze mixture is circulated (known as "closed loop").
This paragraph is poorly written. No need to mention that some open loop GSHP's use the domestic water well.
Ground source heat pumps are coupled to the ground through a closed loop of horizontal or vertical tubing or through an open loop drawing water from a water well.
Comment #24Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 22Comment Type: GeneralComment:Ductless split heat pumps and air conditioners are missing from list of HVAC types. Justification for Change:see comment aboveProposed Change:Ductless air source heat pump - a split or packaged air source heat pump or air conditioner designed to be installed without an air distribution system. May provide heating and cooling, or cooling only.
Ductless split heat pumps and air conditioners are missing from list of HVAC types.
see comment above
Ductless air source heat pump - a split or packaged air source heat pump or air conditioner designed to be installed without an air distribution system. May provide heating and cooling, or cooling only.
Comment #25Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 25Comment Type: TechnicalComment:The section on instantaneous water heaters refers to RE (recovery efficiency) instead of EF. The Standard requires rater to record the EF factor (as evidenced by Table 303.8.1(4), which provides a default EF for instantaneous water heaters).Justification for Change:This omission is a carry forward from current version of Appendix AProposed Change:Check the unit's nameplate for EF or look up the EF rating in an appropriate efficiency rating directory. If the EF rating is not listed in the directory, use the appropriate default from Table 303..8.1(4).
The section on instantaneous water heaters refers to RE (recovery efficiency) instead of EF. The Standard requires rater to record the EF factor (as evidenced by Table 303.8.1(4), which provides a default EF for instantaneous water heaters).
This omission is a carry forward from current version of Appendix A
Check the unit's nameplate for EF or look up the EF rating in an appropriate efficiency rating directory. If the EF rating is not listed in the directory, use the appropriate default from Table 303..8.1(4).
Comment #26Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 25Comment Type: EditorialComment:Final 3 paragraphs of Instantaneous Water Heaters appear to be applicable to all water heaters. The 3rd pf these paragraphs should simply be deleted since distribution losses are not currently addressed in Chapter 3 (not reflected in the equations).Justification for Change:Editorial change. Delete superfluous information not currently addressed in Standard.Proposed Change:Move the following two paragraphs from page 25 to page 23, just below the main Domestic Water Heating header: Visually determine if the water heater is wrapped with exterior insulation. If so, measure thickness of the wrap and determine R-value. Determine whether water heater is located in conditioned or unconditioned space. Delete this paragraph: Determine whether pipe insulation is installed on all 3/4" or larger, non-recirculating hot water mains. Measure thickness of insulation and identify material to determine R-value.
Final 3 paragraphs of Instantaneous Water Heaters appear to be applicable to all water heaters. The 3rd pf these paragraphs should simply be deleted since distribution losses are not currently addressed in Chapter 3 (not reflected in the equations).
Editorial change.
Delete superfluous information not currently addressed in Standard.
Move the following two paragraphs from page 25 to page 23, just below the main Domestic Water Heating header:
Visually determine if the water heater is wrapped with exterior insulation. If so, measure thickness of the wrap and determine R-value.
Determine whether water heater is located in conditioned or unconditioned space.
Delete this paragraph:
Determine whether pipe insulation is installed on all 3/4" or larger, non-recirculating hot water mains. Measure thickness of insulation and identify material to determine R-value.
Comment #27Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 26Comment Type: TechnicalComment:Section of Solar Water Heating is missing information on backup heat. Justification for Change:backup heat for solar water heater must be modeledProposed Change:Add the following paragraph to section on Solar Water Heating: Determine type of backup heat (typically an integrated electric element in the solar storage tank but may be a separate water heater).
Section of Solar Water Heating is missing information on backup heat.
backup heat for solar water heater must be modeled
Add the following paragraph to section on Solar Water Heating:
Determine type of backup heat (typically an integrated electric element in the solar storage tank but may be a separate water heater).
Comment #28Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 27Comment Type: EditorialComment:Under Appliance section, the paragraph on clothes washers inadvertently refers to clothes dryers in four places.Justification for Change:editorial correctionProposed Change:Change references to 'clothes dryer' to 'clothes washer' in third paragraph on page 27.
Under Appliance section, the paragraph on clothes washers inadvertently refers to clothes dryers in four places.
editorial correction
Change references to 'clothes dryer' to 'clothes washer' in third paragraph on page 27.
Comment #29Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 29-30Comment Type: EditorialComment:In the Air Leakage section, bullets under Single Point Test are numbered incorrectly. Justification for Change:editorial correctionProposed Change:renumber bullets beginning at the bottom of page 29, starting from #1.
In the Air Leakage section, bullets under Single Point Test are numbered incorrectly.
renumber bullets beginning at the bottom of page 29, starting from #1.
Comment #30Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 31Comment Type: TechnicalComment:The 4th paragraph in Duct Leakage section indicates circumstances when no duct leakage test is required. Since the RESNET Standard is used by some programs that require a total leakage test regardless of leakage to the outside, it would be sufficient to simply specify the conditions for which ducts may be assumed to have no leakage to outside.Justification for Change:Potential conflict with programs that require total duct leakage testing. Proposed Change:When ducts are in conditioned space with 100% of the system visible and the system is fully ducted (i.e., no building cavities are used to transport air), the ducts may be assumed to have no leakage to outside the conditioned space.
The 4th paragraph in Duct Leakage section indicates circumstances when no duct leakage test is required. Since the RESNET Standard is used by some programs that require a total leakage test regardless of leakage to the outside, it would be sufficient to simply specify the conditions for which ducts may be assumed to have no leakage to outside.
Potential conflict with programs that require total duct leakage testing.
When ducts are in conditioned space with 100% of the system visible and the system is fully ducted (i.e., no building cavities are used to transport air), the ducts may be assumed to have no leakage to outside the conditioned space.
Comment #31Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 31Comment Type: TechnicalComment:The 4th paragraph under Duct Leakage section specifies that 100% of ducts must be visible. This often requires a judgement call and, as such, has generated lively discussion in the LinkedIn RESNET BPI forum. It would be helpful to clarify the intent of the "100% visible" requirement. For example, is it to ensure rater doesn't miss an obvious leak (although the Standard doesn't stipulate any duct system inspection), or is it because leaks from visible ducts are considered less consequential than leaks from hiddle ducts? For example, it's not clear if this requirement would be satisfied, or not, if ducts were visible at time of leakage test (e.g., at rough-in), but hidden after drywall is installed.Justification for Change:clarification of intent for the 100% visible requirementProposed Change:add appropriate modifications and conforming changes to Section 803.2
The 4th paragraph under Duct Leakage section specifies that 100% of ducts must be visible. This often requires a judgement call and, as such, has generated lively discussion in the LinkedIn RESNET BPI forum. It would be helpful to clarify the intent of the "100% visible" requirement. For example, is it to ensure rater doesn't miss an obvious leak (although the Standard doesn't stipulate any duct system inspection), or is it because leaks from visible ducts are considered less consequential than leaks from hiddle ducts? For example, it's not clear if this requirement would be satisfied, or not, if ducts were visible at time of leakage test (e.g., at rough-in), but hidden after drywall is installed.
clarification of intent for the 100% visible requirement
add appropriate modifications and conforming changes to Section 803.2
Comment #32Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 34-35Comment Type: TechnicalComment:Under Ventilation Airflow Settings, the sections on measuring flows into and out of grilles needs to be rewritten so as not to be specific to fan assisted flow meters. Justification for Change:Non-powered flow hoods are far more common than powered flow hoods. Non-powered hoods can be used to measure air flow rates in the expected ranges for most ventilation systems with adequate accuracy. Proposed Change:Rewrite initial paragraph(s) of each section (Flows into grilles, Flows out of grilles) so that either powered or non-powered flow hoods may be used.
Under Ventilation Airflow Settings, the sections on measuring flows into and out of grilles needs to be rewritten so as not to be specific to fan assisted flow meters.
Non-powered flow hoods are far more common than powered flow hoods. Non-powered hoods can be used to measure air flow rates in the expected ranges for most ventilation systems with adequate accuracy.
Rewrite initial paragraph(s) of each section (Flows into grilles, Flows out of grilles) so that either powered or non-powered flow hoods may be used.
Comment #33Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 2Paragraph / Figure / Table / Note: 8Comment Type: TechnicalComment: For the definition of "Conditioned, directly" suggest adding an attic option.Justification for Change: The definition for Conditioned, Directly does not include an attic option, while the other definitions do. To maintain consistency across definitions, recommend adding the attic scenario.
For the definition of "Conditioned, directly" suggest adding an attic option.
The definition for Conditioned, Directly does not include an attic option, while the other definitions do. To maintain consistency across definitions, recommend adding the attic scenario.
Comment #34Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 2Paragraph / Figure / Table / Note: 8Comment Type: TechnicalComment: For the definition of "Conditioned, directly" suggest deleting the words "or unintentionally".Justification for Change: Examples given here are for intentional conditioning.
For the definition of "Conditioned, directly" suggest deleting the words "or unintentionally".
Examples given here are for intentional conditioning.
Comment #35Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 3Paragraph / Figure / Table / Note: 2, 4Comment Type: TechnicalComment:Suggest changing basement/unvented crawlspace designations from Unconditioned, Conditioned- Indirectly, and Conditioned Directly to Unconditioned, Semi-Conditioned and Conditioned. Justification for Change:Unvented Crawlspaces/Basements may have ducts to temper them or act as a drying mechanism. These spaces are not designed to reach the set-point of the thermostat and sometimes do not have intentional returns. These spaces are semi-conditioned and should be treated as such in the calculations. Semi-Conditioned should include all basements/unvented crawlspaces with wall insulation that are indirectly or directly heated/cooled, but are not designed to reach the set-point. Proposed Change: Change unvented crawlspaces/basements to have the following classifications: 1. Unconditioned- do not include volume/floor area in calculations 2. Semi-conditioned- do not include in volume/conditioned floor area 3. Conditioned- Keep wording same as "Conditioned, directly"
Suggest changing basement/unvented crawlspace designations from Unconditioned, Conditioned- Indirectly, and Conditioned Directly to Unconditioned, Semi-Conditioned and Conditioned.
Unvented Crawlspaces/Basements may have ducts to temper them or act as a drying mechanism. These spaces are not designed to reach the set-point of the thermostat and sometimes do not have intentional returns. These spaces are semi-conditioned and should be treated as such in the calculations. Semi-Conditioned should include all basements/unvented crawlspaces with wall insulation that are indirectly or directly heated/cooled, but are not designed to reach the set-point.
Change unvented crawlspaces/basements to have the following classifications: 1. Unconditioned- do not include volume/floor area in calculations 2. Semi-conditioned- do not include in volume/conditioned floor area 3. Conditioned- Keep wording same as "Conditioned, directly"
Comment #36Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 4Paragraph / Figure / Table / Note: 2Comment Type: TechnicalComment:Delete "Note to divide basement and crawl…" Justification for Change:Already mentioned on Page 3.
Delete "Note to divide basement and crawl…"
Already mentioned on Page 3.
Comment #37Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Paragraph / Figure / Table / Note: 2 (Item 5)Comment Type: EditorialComment:Suggest changing "filled" to "fill" Justification for Change:Grammatical change
Suggest changing "filled" to "fill"
Grammatical change
Comment #38Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Paragraph / Figure / Table / Note: 2 (Item 5)Comment Type: TechnicalComment:Suggest removing "substantial" Justification for Change:There should be no gaps or voids. The word "substantial" is too vague.
Suggest removing "substantial"
There should be no gaps or voids. The word "substantial" is too vague.
Comment #39Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Item #2bComment Type: TechnicalComment:Suggest removing "unvented" Justification for Change:Should apply to all crawl space types, vented and unvented.
Suggest removing "unvented"
Should apply to all crawl space types, vented and unvented.
Comment #40Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Batt Insulation Item #3Comment Type: TechnicalComment:#4- Faced Staple Style batts should not be allowed to be side stapled unless required by code. Justification for Change:Side stapling causes compression and is not required by code throughout the country. If a faced batt is required a non-staple product may be a better choice (friction fit faced batt). Proposed Change: Should Read: #4 Side stapling is only allowed when required by code. When side stapled, compression is permitted only along edges to the depth of the stapling tab.
#4- Faced Staple Style batts should not be allowed to be side stapled unless required by code.
Side stapling causes compression and is not required by code throughout the country. If a faced batt is required a non-staple product may be a better choice (friction fit faced batt).
Should Read: #4 Side stapling is only allowed when required by code. When side stapled, compression is permitted only along edges to the depth of the stapling tab.
Comment #41Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Batt Insulation Item #5Comment Type: TechnicalComment:Remove "substantial" Justification for Change:There should be no gaps or voids. The word "substantial" is too vague.
Remove "substantial"
Comment #42Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: 3Comment Type: TechnicalComment:Blown Item #1- Fabric should be face stapled to studs. Justification for Change:Insulation will not be in contact with air barrier and cause thermal performance issues. If side stapling is required then a contractor will not use this product as cost will increase and thermal performance will decrease.
Blown Item #1- Fabric should be face stapled to studs.
Insulation will not be in contact with air barrier and cause thermal performance issues. If side stapling is required then a contractor will not use this product as cost will increase and thermal performance will decrease.
Comment #43Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Blown Insulation Item #7Comment Type: TechnicalComment:Remove "substantial" Justification for Change:There should be no gaps or voids. The word "substantial" is too vague.
Comment #44Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 9Paragraph / Figure / Table / Note: 4Comment Type: TechnicalComment:Remove "Grade 3 installations must be recorded and modeled as uninsulated." Justification for Change:Grade 3 insulation still provides some insulation value and should be counted as such. In addition, there could be potential problems with deemed savings programs. If you count Grade III as uninsulated, then deemed savings will be drastically overestimated.
Remove "Grade 3 installations must be recorded and modeled as uninsulated."
Grade 3 insulation still provides some insulation value and should be counted as such. In addition, there could be potential problems with deemed savings programs. If you count Grade III as uninsulated, then deemed savings will be drastically overestimated.
Comment #45Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 9Paragraph / Figure / Table / Note: 5Comment Type: TechnicalComment:For Items #2 and #4, add something to include the gaps and cracks around SIP panels (e.g. connections to floor systems) Justification for Change:Air leakage at connection between floor system and SIP panels is not addressed.
For Items #2 and #4, add something to include the gaps and cracks around SIP panels (e.g. connections to floor systems)
Air leakage at connection between floor system and SIP panels is not addressed.
Comment #46Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 10Paragraph / Figure / Table / Note: 2Comment Type: TechnicalComment:Grade 3 - Suggest removing "Grade 3 installations must be recorded and modeled as uninsulated." Justification for Change:Grade 3 insulation still provides some insulation value and should be counted as such. In addition, there could be potential problems with deemed savings programs. If you count Grade III as uninsulated, then deemed savings will be drastically overestimated.
Grade 3 - Suggest removing "Grade 3 installations must be recorded and modeled as uninsulated."
Comment #47Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 11Paragraph / Figure / Table / Note: Grade 3Comment Type: TechnicalComment:Grade 3 - Suggest removing "Grade 3 installations must be recorded and modeled as uninsulated." Justification for Change:Grade 3 insulation still provides some insulation value and should be counted as such. In addition, there could be potential problems with deemed savings programs. If you count Grade III as uninsulated, then deemed savings will be drastically overestimated.
Comment #48Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 12Paragraph / Figure / Table / Note: Grade 1, Item #2Comment Type: TechnicalComment:After "2% or less of the roof", propose adding "or gable walls." Add note that radiant barriers on gable walls shouldn't disturb attic ventilation. Comment also applies to Grade 2, Item #1. Justification for Change:There is research to suggest adding radiant barriers to gable walls to improve performance.
After "2% or less of the roof", propose adding "or gable walls." Add note that radiant barriers on gable walls shouldn't disturb attic ventilation. Comment also applies to Grade 2, Item #1.
There is research to suggest adding radiant barriers to gable walls to improve performance.
Comment #49Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 12Paragraph / Figure / Table / Note: Grade 3Comment Type: TechnicalComment:Grade 3 - Suggest removing "Grade 3 installations must be recorded and modeled as uninsulated." Justification for Change:Grade 3 insulation still provides some insulation value and should be counted as such. In addition, there could be potential problems with deemed savings programs. If you count Grade III as uninsulated, then deemed savings will be drastically overestimated.
Comment #50Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 12Paragraph / Figure / Table / Note: IRCCsComment Type: TechnicalComment:Propose adding the word "thermal" before emittance in first line of this section. Justification for Change:Typically this material is rated in terms of thermal emittance by the industry.
Propose adding the word "thermal" before emittance in first line of this section.
Typically this material is rated in terms of thermal emittance by the industry.
Comment #51Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 12Paragraph / Figure / Table / Note: IRCCsComment Type: TechnicalComment:RB Method 1 addresses vapor permeability by requiring the material be perforated. As with RB Method 1, this material too needs to address vapor permeability. Justification for Change:Need to address vapor permeability for this material.
RB Method 1 addresses vapor permeability by requiring the material be perforated. As with RB Method 1, this material too needs to address vapor permeability.
Need to address vapor permeability for this material.
Comment #52Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 12Paragraph / Figure / Table / Note: IRCCs #3Comment Type: TechnicalComment:Recommend removing #3. "The coating must be dry to the touch." Justification for Change:This requirement should be part of the manufacturer's instructions for installation. This item is not specified for any of the other liquid applied products.
Recommend removing #3. "The coating must be dry to the touch."
This requirement should be part of the manufacturer's instructions for installation. This item is not specified for any of the other liquid applied products.
Comment #53Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 14Paragraph / Figure / Table / Note: 3Comment Type: TechnicalComment:Delete this sentence: The insulation used is generally fiberglass batts, often folded in an L-shape and attached to the rim joist. Justification for Change:Ineffective insulation technique. Batts be should cut to fit cavity.
Delete this sentence: The insulation used is generally fiberglass batts, often folded in an L-shape and attached to the rim joist.
Ineffective insulation technique. Batts be should cut to fit cavity.
Comment #54Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 15Paragraph / Figure / Table / Note: 8Comment Type: TechnicalComment:Use a stud finder. Justification for Change:Difficult technique. Most people cannot locate a stud by knocking.
Use a stud finder.
Difficult technique. Most people cannot locate a stud by knocking.
Comment #55Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 21Paragraph / Figure / Table / Note: 10Comment Type: TechnicalComment:Use the model numbers to look up efficiency in a directory such as AHRI or by using manufacturers data. Justification for Change:Nameplates may not give the accurate efficiency for split systems and for other cases.
Use the model numbers to look up efficiency in a directory such as AHRI or by using manufacturers data.
Nameplates may not give the accurate efficiency for split systems and for other cases.
Comment #56Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 27Paragraph / Figure / Table / Note: 3Comment Type: TechnicalComment:Recommend separating dryer information from washer information. Justification for Change:Unclear
Recommend separating dryer information from washer information.
Unclear
Comment #57Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 27Paragraph / Figure / Table / Note: 6Comment Type: TechnicalComment:Recommend adding "sewer gases" to "Potential airborne contaminants such as fireplace ash, mold or asbestos." Justification for Change:Sewer gases are a common indoor air quality concern.
Recommend adding "sewer gases" to "Potential airborne contaminants such as fireplace ash, mold or asbestos."
Sewer gases are a common indoor air quality concern.
Comment #58Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 28Paragraph / Figure / Table / Note: 2Comment Type: TechnicalComment:Open garage door when conducting blower door test. Justification for Change:From a house leakage, IAQ, and combustion safety standpoint, we recommend keeping the garage door open while conducting the blower door test. You want to make sure you are testing the wall separating the house from the garage. We want to test the air barrier between the house and garage. In addition, you should be testing the air barrier that is aligned with the thermal envelope.
Open garage door when conducting blower door test.
From a house leakage, IAQ, and combustion safety standpoint, we recommend keeping the garage door open while conducting the blower door test. You want to make sure you are testing the wall separating the house from the garage. We want to test the air barrier between the house and garage. In addition, you should be testing the air barrier that is aligned with the thermal envelope.
Comment #59Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 31Paragraph / Figure / Table / Note: 6Comment Type: TechnicalComment:Delete paragraph Justification for Change:Ducts need to always be tested regardless if they are entirely in the conditioned space in order to ensure comfort and Energy Star compliance
Delete paragraph
Ducts need to always be tested regardless if they are entirely in the conditioned space in order to ensure comfort and Energy Star compliance
Comment #60Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 31Paragraph / Figure / Table / Note: 9Comment Type: TechnicalComment:Motorized dampers should not be closed Justification for Change:We want to test the entire duct system. Not just part of the system. If the dampers are closed you will be eliminating part of the system (zoned system or supply ventilation).
Motorized dampers should not be closed
We want to test the entire duct system. Not just part of the system. If the dampers are closed you will be eliminating part of the system (zoned system or supply ventilation).
Comment #61Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 32Paragraph / Figure / Table / Note: 11Comment Type: TechnicalComment:Duct system pressure should be measured with reference to outside. Justification for Change:Measuring to inside the building may give you an inaccurate test depending on duct location.
Duct system pressure should be measured with reference to outside.
Measuring to inside the building may give you an inaccurate test depending on duct location.
Comment #62Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 35Paragraph / Figure / Table / Note: 9Comment Type: TechnicalComment:What about other methods for testing airflow? (Applies to flows both in and out of vents). Recommend defining accuracy of equipment. +/- a % or a set CFM which ever is less. Justification for Change:Should define an accuracy range that is required. This will allow other equipment to be used.
What about other methods for testing airflow? (Applies to flows both in and out of vents). Recommend defining accuracy of equipment. +/- a % or a set CFM which ever is less.
Should define an accuracy range that is required. This will allow other equipment to be used.
Comment #63Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 35Paragraph / Figure / Table / Note: 9Comment Type: TechnicalComment:Remove "Open a window or door to the outside."Justification for Change:Having the window open is not a worst case test for ambient CO in the space during oven operation.
Remove "Open a window or door to the outside."
Having the window open is not a worst case test for ambient CO in the space during oven operation.
Comment #64Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 2Paragraph / Figure / Table / Note: Conditioned, direcltyComment Type: TechnicalComment:If we are defining directly conditioned space that is intentionally conditioned by means of a forced air heating or cooling system, hydronic heat, electric resistance, etc, then it is not "unintentionally" conditioned.Justification for Change:ClarityProposed Change:Remove "unintentionally"
If we are defining directly conditioned space that is intentionally conditioned by means of a forced air heating or cooling system, hydronic heat, electric resistance, etc, then it is not "unintentionally" conditioned.
Clarity
Remove "unintentionally"
Comment #65Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 4Paragraph / Figure / Table / Note: #3Comment Type: TechnicalComment:No air spaces "must be allowed" between different insulation types or systems. This is a poorly worded sentence and sounds like a sloppy translation into English. It can be made more direct and concise.Justification for Change:ClarityProposed Change:Reword to: No air spaces between different insulation types or systems.
No air spaces "must be allowed" between different insulation types or systems. This is a poorly worded sentence and sounds like a sloppy translation into English. It can be made more direct and concise.
Reword to: No air spaces between different insulation types or systems.
Comment #66Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Paragraph / Figure / Table / Note: Insulated Sheathing #5Comment Type: EditorialComment:"Sheathing joints must be 'durable' taped..." Is durable tape the same type of tape as duck tape?Justification for Change:ClarityProposed Change:Replace "durable" with "durably".
"Sheathing joints must be 'durable' taped..."
Is durable tape the same type of tape as duck tape?
Replace "durable" with "durably".
Comment #67Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Paragraph / Figure / Table / Note: Batt insulation #aComment Type: EditorialComment:"Insulation installed in attics above ceilings 'must not require' an air barrier on the exterior side." This is a poorly worded sentence and typical of the sentences that follow it.Justification for Change:ClarityProposed Change:Reword to: An air barrier is not required on the exterior side of insulation installed in attics above ceilings.
"Insulation installed in attics above ceilings 'must not require' an air barrier on the exterior side." This is a poorly worded sentence and typical of the sentences that follow it.
Reword to: An air barrier is not required on the exterior side of insulation installed in attics above ceilings.
Comment #68Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Batt insulation #bComment Type: EditorialComment:"Insulation installed under floors directly above an unvented crawl space 'must not require' and air barrier on the exterior side." Another poor translation into English. Are we trying to say that if you have a vented crawlspace it must have an air barrier on the exterior side?Justification for Change:clarityProposed Change:Reword to: An air barrier is not required on the exterior side of insulation installed under floors directly above an unvented crawl space, vented crawl space, or unconditioned basement.
"Insulation installed under floors directly above an unvented crawl space 'must not require' and air barrier on the exterior side." Another poor translation into English. Are we trying to say that if you have a vented crawlspace it must have an air barrier on the exterior side?
clarity
Reword to: An air barrier is not required on the exterior side of insulation installed under floors directly above an unvented crawl space, vented crawl space, or unconditioned basement.
Comment #69Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Batt insulation #cComment Type: EditorialComment:Poorly worded: Insulation installed in rim or band joists located in condtioned space 'must not require' an air barrier on the interior side. Justification for Change:ClarityProposed Change:Reword to: An air barrier on the interior side is not required for insulation installed in rim or band joists located in conditioned space.
Poorly worded: Insulation installed in rim or band joists located in condtioned space 'must not require' an air barrier on the interior side.
Reword to: An air barrier on the interior side is not required for insulation installed in rim or band joists located in conditioned space.
Comment #70Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Batt Insulation #3Comment Type: EditorialComment:Another poorly worded couple of sentences.Justification for Change:Conciseness and ClarityProposed Change:Reword to: Faced batts must be stapled to the face of the studs or side stapled to the studs with no buckling of the stapling tabs or be left unstapled. Tabless batts and friction fit products do not require stapling.
Another poorly worded couple of sentences.
Conciseness and Clarity
Reword to: Faced batts must be stapled to the face of the studs or side stapled to the studs with no buckling of the stapling tabs or be left unstapled. Tabless batts and friction fit products do not require stapling.
Comment #71Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Blown or Sprayed Loose Fill Insulation #aComment Type: TechnicalComment:Poorly worded and contradictory to the Batt insulation requirements. If batt insulation is not required to have an air barrier on the exterior side, why would loose fill insulation be required to have an air barrier on the exterior side?Justification for Change:ClarityProposed Change:Reword to: An air barrier on the interior side is required for insulation installed in attics and ceilings.
Poorly worded and contradictory to the Batt insulation requirements. If batt insulation is not required to have an air barrier on the exterior side, why would loose fill insulation be required to have an air barrier on the exterior side?
Reword to: An air barrier on the interior side is required for insulation installed in attics and ceilings.
Comment #72Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Blown... #bComment Type: TechnicalComment:Poorly wordedJustification for Change:ClarityProposed Change:Reword to: An air barrier on the exterior side is not required for insulation installed in floors that is directly above an unvented crawl space, vented crawl space or unconditioned basement.
Poorly worded
Reword to: An air barrier on the exterior side is not required for insulation installed in floors that is directly above an unvented crawl space, vented crawl space or unconditioned basement.
Comment #73Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Blown....#6cComment Type: EditorialComment:Poorly wordedJustification for Change:ClarityProposed Change:Reword to: An air barrier is not required on the interior side of insulation installed in rim or band joists located in conditioned space.
Reword to: An air barrier is not required on the interior side of insulation installed in rim or band joists located in conditioned space.
Comment #74Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7Paragraph / Figure / Table / Note: Open cell...#3Comment Type: EditorialComment:Poorly wordedJustification for Change:ClarityProposed Change:Reword to: SPF insulation is considered an air barrier if it is installed in contact with the substrate and at a minimum thickness to be air impermeable per ASTM E283 or E2178.
Reword to: SPF insulation is considered an air barrier if it is installed in contact with the substrate and at a minimum thickness to be air impermeable per ASTM E283 or E2178.
Comment #75Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7Paragraph / Figure / Table / Note: Open cell...#5Comment Type: TechnicalComment:This contradicts #4 before it. Is this sentence trying to say that you cannot fill the cavity to the face of the studs? #4 is looking for the insulation to contact the interior sheathing, but #5 is looking for the sheathing to stand 1/2 inch away from the insulation. Is the intention to keep the installed thickness of open cell SPF to at least 1/2 inch less than the stud cavity depth and preferably to the face of the studs for full contact with the interior sheathing?Justification for Change:ClarityProposed Change:Reword to: Open Cell SPF cavity insulation fill depth must be no greater than 1/2 inch from the face of the studs.
This contradicts #4 before it. Is this sentence trying to say that you cannot fill the cavity to the face of the studs? #4 is looking for the insulation to contact the interior sheathing, but #5 is looking for the sheathing to stand 1/2 inch away from the insulation. Is the intention to keep the installed thickness of open cell SPF to at least 1/2 inch less than the stud cavity depth and preferably to the face of the studs for full contact with the interior sheathing?
Reword to: Open Cell SPF cavity insulation fill depth must be no greater than 1/2 inch from the face of the studs.
Comment #76Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7Paragraph / Figure / Table / Note: Closed cell SPF #3Comment Type: EditorialComment:Poorly wordedJustification for Change:ClarityProposed Change:Reword to: Closed cell SPF insulation is considered to be an air barrier when installed in contact with the substrate at a thickness of at least 1.5 inches.
Reword to: Closed cell SPF insulation is considered to be an air barrier when installed in contact with the substrate at a thickness of at least 1.5 inches.
Comment #77Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7Paragraph / Figure / Table / Note: Insulation GradingComment Type: TechnicalComment:Pictures are needed to demonstrate the Grading constraints similar to the current Appendix A.Justification for Change:A picture is worth a thousand words. It is easier to perform a visual comparison of the standard to the insulation you are looking at than to visualize what the standard is saying and then looking at the insulation in the house to compare it to your visualization.Proposed Change:Create Graded renderings similar to the current Appendix A with enough words in the caption to correctly correspond to the worded standard.
Pictures are needed to demonstrate the Grading constraints similar to the current Appendix A.
A picture is worth a thousand words. It is easier to perform a visual comparison of the standard to the insulation you are looking at than to visualize what the standard is saying and then looking at the insulation in the house to compare it to your visualization.
Create Graded renderings similar to the current Appendix A with enough words in the caption to correctly correspond to the worded standard.
Comment #78Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: allComment Type: GeneralComment:It is unfortunate that the amendment was published without indicating changes in strikeout/underline mode, leaving commenters to comb through the entire document in 30 days to determine what has changed. Proposed Change:In the future please post amendments to major sections in strikeout/underline mode for review.
It is unfortunate that the amendment was published without indicating changes in strikeout/underline mode, leaving commenters to comb through the entire document in 30 days to determine what has changed.
In the future please post amendments to major sections in strikeout/underline mode for review.
Comment #79Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5 & 6Comment Type: TechnicalComment:On page 5 of the proposed document, in exceptions a, b and c change the word “must” to “shall.”Justification for Change:Item 2 exception a, currently states, “Insulation installed in attics above ceilings must not require an air barrier on the exterior side.” As proposed this language would not allow an air barrier to be installed on the exterior side of the insulation. The language should permit the practice – but not mandate it. Changing the exception to say, “Insulation installed in attics above ceilings shall not be required to have an air barrier on the exterior side ” accomplishes this objective. This language allows attic insulation to be installed without an air barrier on the exterior side (as is typical for loose-fill insulation installed on attic floors) but the language does not prohibit installing an air barrier. Changing “shall” to “must” in the exceptions b and c has the same effect of prohibiting the practice – not just allowing it to not be done and does not significantly affect the performance of the insulation. Proposed Change:Batt Insulation: 1. Insulation must fill the cavity being insulated side to side, top to bottom. 2. Insulation must be enclosed on all six sides. (revise exceptions as shown) Exceptions: a. Insulation installed in attics above ceilings shall not be required to have an air barrier on the exterior side. b. Insulation installed under floors directly above an unvented crawl space shall not be required to have an air barrier on the exterior side. c. Insulation installed in rim or band joists located in conditioned space must not be required to have an air barrier on the interior side. d. (remains unchanged)
On page 5 of the proposed document, in exceptions a, b and c change the word “must” to “shall.”
Item 2 exception a, currently states, “Insulation installed in attics above ceilings must not require an air barrier on the exterior side.” As proposed this language would not allow an air barrier to be installed on the exterior side of the insulation.
The language should permit the practice – but not mandate it. Changing the exception to say, “Insulation installed in attics above ceilings shall not be required to have an air barrier on the exterior side ” accomplishes this objective. This language allows attic insulation to be installed without an air barrier on the exterior side (as is typical for loose-fill insulation installed on attic floors) but the language does not prohibit installing an air barrier.
Changing “shall” to “must” in the exceptions b and c has the same effect of prohibiting the practice – not just allowing it to not be done and does not significantly affect the performance of the insulation.
Batt Insulation:
1. Insulation must fill the cavity being insulated side to side, top to bottom. 2. Insulation must be enclosed on all six sides. (revise exceptions as shown)
Exceptions: a. Insulation installed in attics above ceilings shall not be required to have an air barrier on the exterior side. b. Insulation installed under floors directly above an unvented crawl space shall not be required to have an air barrier on the exterior side. c. Insulation installed in rim or band joists located in conditioned space must not be required to have an air barrier on the interior side. d. (remains unchanged)
Comment #80Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: AllParagraph / Figure / Table / Note: AllComment Type: GeneralComment:It appears that the proposed amendment eliminates all the illustrations in Appendix A. In the version of proposed changes to this appendix that were circulated to the technical committee circa January 2010 (none of which were incorporated here) the illustrations were not removed.Justification for Change:Although the illustrations are not complete and there may be many that are lacking, it is helpful for many people to visualize with pictures rather than words.Proposed Change: Please reinstate the illustrations in the appropriate places.
It appears that the proposed amendment eliminates all the illustrations in Appendix A. In the version of proposed changes to this appendix that were circulated to the technical committee circa January 2010 (none of which were incorporated here) the illustrations were not removed.
Although the illustrations are not complete and there may be many that are lacking, it is helpful for many people to visualize with pictures rather than words.
Please reinstate the illustrations in the appropriate places.
Comment #81Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7 & 8Comment Type: TechnicalComment:On pages 7 and 8 under the Grade 1 criteria for batts are addressed. Installing batt insulation under floors is typically done using wire supports. In order for these supports to hold batts within the floor cavity and firmly up against the floor sheathing it requires some force. This force would likely compress the batt more than ½” maximum required for Grade 1 in the area where it contacts the batt. For this reason NAIMA recommends allowing a ¾” compression for Grade 1 batts installed under floors.Justification for Change:Allowing a ¾” compression with wire supports for under floor insuation would allow insulation to be held firmly in palce and have negligible the energy performance of the home.Proposed Change:(add new exception to Grade 1 criteria for Batts or Loose-fill section) Exception: Batts installed under floors using wire supports shall not be compressed more than ¾ inch of the nominal insulation thickness.
On pages 7 and 8 under the Grade 1 criteria for batts are addressed. Installing batt insulation under floors is typically done using wire supports. In order for these supports to hold batts within the floor cavity and firmly up against the floor sheathing it requires some force. This force would likely compress the batt more than ½” maximum required for Grade 1 in the area where it contacts the batt. For this reason NAIMA recommends allowing a ¾” compression for Grade 1 batts installed under floors.
Allowing a ¾” compression with wire supports for under floor insuation would allow insulation to be held firmly in palce and have negligible the energy performance of the home.
(add new exception to Grade 1 criteria for Batts or Loose-fill section) Exception: Batts installed under floors using wire supports shall not be compressed more than ¾ inch of the nominal insulation thickness.
Comment #82Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: n/aComment Type: GeneralComment:The current draft does not contain any guidance on how to grade hybrid insulation systems. For example how does one grade a wall which is partially filled with spray foam and the remainder filled with loose-fill or batt insulation? These systems are becoming more widely used and the RESNET appendix should contain guidance on how to grade those systems.Justification for Change:Raters need guidance on grading hybrid systems.Proposed Change:Add language stating that hybrid systems be graded by their individual components and the overall grade should be the lowest of the individual components.
The current draft does not contain any guidance on how to grade hybrid insulation systems. For example how does one grade a wall which is partially filled with spray foam and the remainder filled with loose-fill or batt insulation? These systems are becoming more widely used and the RESNET appendix should contain guidance on how to grade those systems.
Raters need guidance on grading hybrid systems.
Add language stating that hybrid systems be graded by their individual components and the overall grade should be the lowest of the individual components.
Comment #83Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: allComment Type: GeneralComment:Consider an editorial review of the proposed language and changing the word “must” to “shall” in most cases. This is the commonly accepted term used in building codes and standards and will make the document more acceptable to the building code enforcement community.
Consider an editorial review of the proposed language and changing the word “must” to “shall” in most cases. This is the commonly accepted term used in building codes and standards and will make the document more acceptable to the building code enforcement community.
Comment #84Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7Paragraph / Figure / Table / Note: Batt and Loose-fill insulationComment Type: TechnicalComment:The first sentence allows up to 2% gaps or voids, but the second sentence says that voids are not allowed. If the intent is to only allow compression or lack of thickness to a certain degree, then the words gap and void should not be used as they denote an area that is completely missing insulation. Webster defines void as "containing nothing"Justification for Change:Clarity, if we want cavities to be fully insulated, top to bottom, side to side with no voids, then do not say you allow voids then say that you do not allow voids. Keep in mind that the Rater is evaluating the insulation installation, not performing the insulation installation, unless he fills out the RESNET standard disclosure stating so.Proposed Change:Reword to: When evaluating batt, or loose fill insulation, no more than 2% of the total insulated area (cavity) must be compressed more than 1/2 inch of the nominal thickness in any given location. Voids are not permitted.
The first sentence allows up to 2% gaps or voids, but the second sentence says that voids are not allowed. If the intent is to only allow compression or lack of thickness to a certain degree, then the words gap and void should not be used as they denote an area that is completely missing insulation. Webster defines void as "containing nothing"
Clarity, if we want cavities to be fully insulated, top to bottom, side to side with no voids, then do not say you allow voids then say that you do not allow voids. Keep in mind that the Rater is evaluating the insulation installation, not performing the insulation installation, unless he fills out the RESNET standard disclosure stating so.
Reword to: When evaluating batt, or loose fill insulation, no more than 2% of the total insulated area (cavity) must be compressed more than 1/2 inch of the nominal thickness in any given location. Voids are not permitted.
Comment #85Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 2Paragraph / Figure / Table / Note: 4th paragraphComment Type: TechnicalComment:The description "This is because the ambient temperature of the space is close to the outdoor ambient temperature or higher (in the case of attics in the cooling season)." is unnecesasry and confusing.Justification for Change:This content isn't needed in normative standard. Proposed Change:Delete the sentence
The description "This is because the ambient temperature of the space is close to the outdoor ambient temperature or higher (in the case of attics in the cooling season)." is unnecesasry and confusing.
This content isn't needed in normative standard.
Delete the sentence
Comment #86Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 2Paragraph / Figure / Table / Note: 5th paragraphComment Type: EditorialComment: "An unvented crawl space, basement or attic may be considered either unconditioned, indirectly conditioned, or fully conditioned, based on the following criteria:"; "fully condtioned" is not defined in the standard or in the following secitons. Justification for Change: Keep terminology consistent with definitions.Proposed Change: Change "fully" to "directly"
"An unvented crawl space, basement or attic may be considered either unconditioned, indirectly conditioned, or fully conditioned, based on the following criteria:"; "fully condtioned" is not defined in the standard or in the following secitons.
Keep terminology consistent with definitions.
Change "fully" to "directly"
Comment #87Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 2Paragraph / Figure / Table / Note: 7th paragraphComment Type: TechnicalComment:Criteria and examples for indirectly conditioned are confusing and inconsistent with the definition of "indirectly conditioned".Justification for Change:Make the language consistent with the long-standing definition of indirectly conditioned space.Proposed Change:Replace the paragraph with the following: "Conditioned, indirectly - In an indirectly conditioned space, heating and/or cooling is delivered to the space either through wall, floor, or ceiling assemblies, or by losses/gains from the heating/cooling system. An indirectly conditioned space typically lacks a functional thermostat. Indirectly conditioned spaces are considered conditioned space for the purposes of a rating. Indirectly conditioned spaces may be intentional or unintentional. Examples include a finished room that does not have distribution equipment or terminal devices; an unvented attic with large air leakage communication to the home; a vented or unvented attic with higher levels of insulation in the roof than in the attic floor and significant air leakage to conditioned space; a basement or crawlspace with higher levels of insulation in the exterior walls than in the ceiling; a basement, crawlspace, or other buffer space with uninsulated or unsealed mechanical equipment and/or HVAC distribution equipment. Indirectly conditioned spaces are typically between the temperature of the indoor conditioned space temperature and the outdoor ambient temperature.
Criteria and examples for indirectly conditioned are confusing and inconsistent with the definition of "indirectly conditioned".
Make the language consistent with the long-standing definition of indirectly conditioned space.
Replace the paragraph with the following: "Conditioned, indirectly - In an indirectly conditioned space, heating and/or cooling is delivered to the space either through wall, floor, or ceiling assemblies, or by losses/gains from the heating/cooling system. An indirectly conditioned space typically lacks a functional thermostat. Indirectly conditioned spaces are considered conditioned space for the purposes of a rating. Indirectly conditioned spaces may be intentional or unintentional. Examples include a finished room that does not have distribution equipment or terminal devices; an unvented attic with large air leakage communication to the home; a vented or unvented attic with higher levels of insulation in the roof than in the attic floor and significant air leakage to conditioned space; a basement or crawlspace with higher levels of insulation in the exterior walls than in the ceiling; a basement, crawlspace, or other buffer space with uninsulated or unsealed mechanical equipment and/or HVAC distribution equipment. Indirectly conditioned spaces are typically between the temperature of the indoor conditioned space temperature and the outdoor ambient temperature.
Comment #88Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 8Paragraph / Figure / Table / Note: Open-Cell PSF...Comment Type: TechnicalComment:This section is poorly worded and seems contradictory. Are voids allowed or not? The average thickness must be greater than the specified thickness but not less than 1 inch below the specified thickness or more than 3/4 inch below the specified thickness....If open cell SPF's R-value per inch is similar to fiberglass batts, why is its compression standard different?Justification for Change:Clarity, since we are looking at Grade I in this section, make it easy.Proposed Change:Reword this section to: No more than 2% of the insulated area must be more than 3/4 inch below the specified thickness. Voids are not permitted.
This section is poorly worded and seems contradictory. Are voids allowed or not? The average thickness must be greater than the specified thickness but not less than 1 inch below the specified thickness or more than 3/4 inch below the specified thickness....If open cell SPF's R-value per inch is similar to fiberglass batts, why is its compression standard different?
Clarity, since we are looking at Grade I in this section, make it easy.
Reword this section to: No more than 2% of the insulated area must be more than 3/4 inch below the specified thickness. Voids are not permitted.
Comment #89Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 2Paragraph / Figure / Table / Note: last paragraphComment Type: TechnicalComment: Conditioned space description is confusing and inconsistent with the definition. It also uses the term "fully conditioned" which is not defined. Justification for Change:Eliminate confusing cross-references and eliminate inconsistency of terminology and definitions.Proposed Change:Replace section as follows: "Conditioned, directly - In a directly conditioned space, heating and/or cooling is delivered to the space by intentional distribution equipment and/or terminal devices, and are typically maintained at the same or similar temperature as other above grade finished spaces. In some cases, in may be necessary to interview the owner about the temperature in the basement or attic during the heating and cooling seasons, and assess the potential for standby loss from the heating equipment and distribution system, e.g., jacket insulation, leakiness of ducts, insulation on distribution systems, etc. If basement, crawl space or attic is determined to be directly or indirectly conditioned, its walls and floor (for basement or crawlspace) or roofline (for attic) are considered part of the conditioned space boundary. In those cases, the floor between the house's ground floor and the conditioned basement or crawl space, or the ceiling between a conditioned attic and the conditioned space below is considered an interior boundary with no associated heat transfer. Determine volume of conditioned and indirectly conditioned space by multiplying floor area by ceiling height. The house may need to be split into different spaces with different ceiling heights and added to each other for both conditioned and indirectly conditioned spaces. For areas with vaulted ceilings or other irregular shapes, volume must be calculated geometrically."
Conditioned space description is confusing and inconsistent with the definition. It also uses the term "fully conditioned" which is not defined.
Eliminate confusing cross-references and eliminate inconsistency of terminology and definitions.
Replace section as follows: "Conditioned, directly - In a directly conditioned space, heating and/or cooling is delivered to the space by intentional distribution equipment and/or terminal devices, and are typically maintained at the same or similar temperature as other above grade finished spaces.
In some cases, in may be necessary to interview the owner about the temperature in the basement or attic during the heating and cooling seasons, and assess the potential for standby loss from the heating equipment and distribution system, e.g., jacket insulation, leakiness of ducts, insulation on distribution systems, etc.
If basement, crawl space or attic is determined to be directly or indirectly conditioned, its walls and floor (for basement or crawlspace) or roofline (for attic) are considered part of the conditioned space boundary. In those cases, the floor between the house's ground floor and the conditioned basement or crawl space, or the ceiling between a conditioned attic and the conditioned space below is considered an interior boundary with no associated heat transfer.
Determine volume of conditioned and indirectly conditioned space by multiplying floor area by ceiling height. The house may need to be split into different spaces with different ceiling heights and added to each other for both conditioned and indirectly conditioned spaces. For areas with vaulted ceilings or other irregular shapes, volume must be calculated geometrically."
Comment #90Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 8Paragraph / Figure / Table / Note: Closed cell SPFComment Type: TechnicalComment:Same type of confusion in this section as the open cell section. Justification for Change:ClarityProposed Change:Reword to: No more than 2% of the insulated area must be more than 1/2 inch below the specified thickness. Voids are not permitted.
Same type of confusion in this section as the open cell section.
Reword to: No more than 2% of the insulated area must be more than 1/2 inch below the specified thickness. Voids are not permitted.
Comment #91Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 8Paragraph / Figure / Table / Note: Grade 2 battComment Type: TechnicalComment:Are voids allowed or not? If voids are not allowed, do not say you can have 15% voids.Justification for Change:ClarityProposed Change:Reword the section: No more than 15% of the total insulated area (cavity) must be compressed more than 3/4 inch of the nominal insulation thickness in any given location. Voids are not permitted.
Are voids allowed or not? If voids are not allowed, do not say you can have 15% voids.
Reword the section: No more than 15% of the total insulated area (cavity) must be compressed more than 3/4 inch of the nominal insulation thickness in any given location. Voids are not permitted.
Comment #92Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 9Paragraph / Figure / Table / Note: Open cell SPFComment Type: TechnicalComment:same poor wording as batt and loose fill sectionJustification for Change:ClarityProposed Change:Reword to: No more than 15% of the insulated area must be more than 1 inch below the specified thickness. Voids are not permitted.
same poor wording as batt and loose fill section
Reword to: No more than 15% of the insulated area must be more than 1 inch below the specified thickness. Voids are not permitted.
Comment #93Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 9Paragraph / Figure / Table / Note: closed cell spfComment Type: TechnicalComment:same comments as open cell section aboveJustification for Change:ClarityProposed Change:Reword section: No more than 15% of the insulated area must be 1/2 inch below the specified thickness. Voids are not permitted.
same comments as open cell section above
Reword section: No more than 15% of the insulated area must be 1/2 inch below the specified thickness. Voids are not permitted.
Comment #94Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 4-13Paragraph / Figure / Table / Note: Insulation/gradingComment Type: TechnicalComment:(Note: this comment spans general, technical, and editorial.) This entire section as re-written seems to describe best practice requirements for new installations (whether new construction or new retrofits to be inspected), but is not useful for raters who are evaluating existing insulation. This was a shortcoming of the previous language in this section, but the new language has moved firmly in that direction. At a time when RESNET is trying to improve its image andreinforce the relevance of HERS ratings to existing homes and retrofits, and when other parts of the standard (air and duct leakage testing, and savings calculation proceduces for existing home retrofits) have been enhanced to reinforce and support that distinction, it is unfortunate to see this insulation grading section move in the opposite direction. The original intent of the grading system was primarily to provide a punitive--but not extreme--categorical guideline for inspecting and modeling less-than-ideal insulation installations, so as to provide an incentive for builders and installers to follow manufacturer's guidelines and widely accepted industry practices. There is language intended to convey that the use of grading is more discretionary for existing home installations, but that language was not consistent and many raters seem to believe that typical performance of a batt-insulated wall that was previously built would actually be represented well by Grade III, which in reality is likely to be too conservative. Conservative (in terms of predicting higher energy use) is good in a new work/compliance environment, but is counterproductive in assessing existing homes for retrofit work, because it leads to overestimating savings potential. Justification for Change:Continue to enhance RESNET's ongoing efforts to provide relevant distinctions between ratings used for compliance/new work/new construction and ratings used to assess existing home retrofits, rather than inhibit those efforts.Proposed Change:I will register a number of separate, specific changes that support this objective. Also note that the use of arabic numerals "1, 2 and 3" for the grades is inconsistent with the section on insulation grading in Section 303.4.1.4. If arabic numerals are to be used, that section must be amended correspondingly; I believe that specific change would editorial and could be made without further public comment process.
(Note: this comment spans general, technical, and editorial.) This entire section as re-written seems to describe best practice requirements for new installations (whether new construction or new retrofits to be inspected), but is not useful for raters who are evaluating existing insulation. This was a shortcoming of the previous language in this section, but the new language has moved firmly in that direction. At a time when RESNET is trying to improve its image andreinforce the relevance of HERS ratings to existing homes and retrofits, and when other parts of the standard (air and duct leakage testing, and savings calculation proceduces for existing home retrofits) have been enhanced to reinforce and support that distinction, it is unfortunate to see this insulation grading section move in the opposite direction. The original intent of the grading system was primarily to provide a punitive--but not extreme--categorical guideline for inspecting and modeling less-than-ideal insulation installations, so as to provide an incentive for builders and installers to follow manufacturer's guidelines and widely accepted industry practices. There is language intended to convey that the use of grading is more discretionary for existing home installations, but that language was not consistent and many raters seem to believe that typical performance of a batt-insulated wall that was previously built would actually be represented well by Grade III, which in reality is likely to be too conservative. Conservative (in terms of predicting higher energy use) is good in a new work/compliance environment, but is counterproductive in assessing existing homes for retrofit work, because it leads to overestimating savings potential.
Continue to enhance RESNET's ongoing efforts to provide relevant distinctions between ratings used for compliance/new work/new construction and ratings used to assess existing home retrofits, rather than inhibit those efforts.
I will register a number of separate, specific changes that support this objective.
Also note that the use of arabic numerals "1, 2 and 3" for the grades is inconsistent with the section on insulation grading in Section 303.4.1.4. If arabic numerals are to be used, that section must be amended correspondingly; I believe that specific change would editorial and could be made without further public comment process.
Comment #95Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 9Paragraph / Figure / Table / Note: Grade 3Comment Type: GeneralComment:Modeling Grade 3 insulation as uninsulated is an unfair penalty. The modeling should reflect the conditions present. More than 15% of the area compressed 1/2 to 1 inch is not an uninsulated space. The insulation R-value in those areas is reduced by the amount of compression or lack of fill and should be modeled at that R-value.Justification for Change:A confirmed rating is supposed to model what is present and can be modeled with R-value per inch tables and compression tables instead of defaulting to an R-0.Proposed Change:Allow modeling the Grade 3 areas using R-value per inch or R-value based on compression tables.
Modeling Grade 3 insulation as uninsulated is an unfair penalty. The modeling should reflect the conditions present. More than 15% of the area compressed 1/2 to 1 inch is not an uninsulated space. The insulation R-value in those areas is reduced by the amount of compression or lack of fill and should be modeled at that R-value.
A confirmed rating is supposed to model what is present and can be modeled with R-value per inch tables and compression tables instead of defaulting to an R-0.
Allow modeling the Grade 3 areas using R-value per inch or R-value based on compression tables.
Comment #96Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 9Paragraph / Figure / Table / Note: SIPs #2 and 4Comment Type: TechnicalComment:The Structural Insulated Panel Association does not require that gaps and penetrationsss must be air-sealed with expanding foam. Why is RESNET requiring this? From the SIPA website: "Voids All voids must be filled with appropriate sealants/panel adhesives manufactured to ensure against air movement and moisture intrusion into the building envelope."Justification for Change:RESNET should not dictate specific products when the manufacturing association it sites does not.Proposed Change:Reword using similar language as found on the SIPA website. Delete number 2 and roll it into 4 All gaps and penetrations through SIPs including windows, doors, and foundation or roof connections must be air-sealed with appropriate sealants/panel adhesives manufactured to ensure agains air movement and moisture intrusion into the building envelope per the SIPA website.
The Structural Insulated Panel Association does not require that gaps and penetrationsss must be air-sealed with expanding foam. Why is RESNET requiring this?
From the SIPA website:
"Voids All voids must be filled with appropriate sealants/panel adhesives manufactured to ensure against air movement and moisture intrusion into the building envelope."
RESNET should not dictate specific products when the manufacturing association it sites does not.
Reword using similar language as found on the SIPA website.
Delete number 2 and roll it into 4
All gaps and penetrations through SIPs including windows, doors, and foundation or roof connections must be air-sealed with appropriate sealants/panel adhesives manufactured to ensure agains air movement and moisture intrusion into the building envelope per the SIPA website.
Comment #97Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: Page 4Paragraph / Figure / Table / Note: Insulation: opening paragraphComment Type: TechnicalComment:The original language of the insulation grading section contained the phrase ""When it is possible to inspect insulation as installed (i.e., new construction)". The insulation grading system was created more to create a strong incentive in a new work, that is "inspectable", for installers to follow industry-standard techniques. It was never intended to be as punitive for existing home inspections, but the language indicating that was weak and unclear.Justification for Change:Enhance the distinction between inspections used for compliance purposes (new homes or new work inspections) and ones that are used to estimate existing home energy use for auditing or savings estimates. Proposed Change:Delete the paragraph under the heading "Insulation" and replace with the following: "For the purposes of compliance with new construction enengy codes, voluntary programs, or inspection of newly installed insulation retrofits, in order to meet the requirements of Grade 1 or Grade 2, insulation material must be installed according to the minimum general installation requirements, the minimum specific application requirements, and the minimum specific material requirements in this Appendix and the grading requirements for each type of insulation material. For the puropses of existing home energy audits or estimating existing home energy use for the purpose of savings estimates, Grade 2 shall be used as the default assumption for energy performance of any insulation, unless the installation is fully visible and a more detailed assessment is possible. "
The original language of the insulation grading section contained the phrase ""When it is possible to inspect insulation as installed (i.e., new construction)". The insulation grading system was created more to create a strong incentive in a new work, that is "inspectable", for installers to follow industry-standard techniques. It was never intended to be as punitive for existing home inspections, but the language indicating that was weak and unclear.
Enhance the distinction between inspections used for compliance purposes (new homes or new work inspections) and ones that are used to estimate existing home energy use for auditing or savings estimates.
Delete the paragraph under the heading "Insulation" and replace with the following:
"For the purposes of compliance with new construction enengy codes, voluntary programs, or inspection of newly installed insulation retrofits, in order to meet the requirements of Grade 1 or Grade 2, insulation material must be installed according to the minimum general installation requirements, the minimum specific application requirements, and the minimum specific material requirements in this Appendix and the grading requirements for each type of insulation material.
For the puropses of existing home energy audits or estimating existing home energy use for the purpose of savings estimates, Grade 2 shall be used as the default assumption for energy performance of any insulation, unless the installation is fully visible and a more detailed assessment is possible. "
Comment #98Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 4Paragraph / Figure / Table / Note: Minumum General Installation RequirementsComment Type: TechnicalComment:In item #2, the phrase "interior to and" conflicts with several of the specific application requirements below. Justification for Change:The phrase is unnecessary, because the relationship to interior or exterior air barriers are detailed in each of the application requirements below.Proposed Change: Delete "interior to and"
In item #2, the phrase "interior to and" conflicts with several of the specific application requirements below.
The phrase is unnecessary, because the relationship to interior or exterior air barriers are detailed in each of the application requirements below.
Delete "interior to and"
Comment #99Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 10Paragraph / Figure / Table / Note: Grade 2Comment Type: TechnicalComment:Why has Grade 2 for SIPs been reduced from "standard" insulation's 15% defects to 2% to 5%? Shouldn't insulation be graded similarly throughout the standard? How deep into the insulation within a SIP panel are cutouts for electrical boxes, pipes and other penetrations going? Is an electrical box or pipe penetration that has been sealed around a repaired area of damage and does not count towards the 2% to 5% allowable damage?Justification for Change:Clarity, with batt, blown or spray foam insulation, when electrical boxes and pipes are encountered and insulated behind and around, this is not counted against the installation grade. Why are cutouts that are surrounded by insulation being counted against the SIP's grade?Proposed Change:Align the standard with the earlier sections.
Why has Grade 2 for SIPs been reduced from "standard" insulation's 15% defects to 2% to 5%? Shouldn't insulation be graded similarly throughout the standard? How deep into the insulation within a SIP panel are cutouts for electrical boxes, pipes and other penetrations going? Is an electrical box or pipe penetration that has been sealed around a repaired area of damage and does not count towards the 2% to 5% allowable damage?
Clarity, with batt, blown or spray foam insulation, when electrical boxes and pipes are encountered and insulated behind and around, this is not counted against the installation grade. Why are cutouts that are surrounded by insulation being counted against the SIP's grade?
Align the standard with the earlier sections.
Comment #100Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 4Paragraph / Figure / Table / Note: Minumum General Installation RequirementsComment Type: TechnicalComment:In item #3, the prohibition on air spaces is extreme and does not accounnt for differences in performance from different situations (e.g. vented vs. unvented air space; whether the insulation layer(s) are or are not continuous). While sensible for new construction/compliance, it should be limited to that situation and allow for rater judgement for as-is insulation for existing home audits/ savings estimates. Justification for Change:For example: even a fully vented air space between wall sheathing and rigid insulation exterior to the air space does not entirely nullify the R-value of that rigid insulation layer. If it's 0F, I'd rather be wearing a down jacket with the zipper open and some air space between me and the jacket, than wearing nothing at all.Proposed Change:Add another exception: "For audits or savings estimates of as-is insulation in existing homes, a vented air space between insulation layers shall result in the exterior layer R-value of no more than 50% of its "normal" R-value. Unvented air spaces may be treated as reducing the exterior insulation layer to Grade 3, regardless of its other installed chararteristics."
In item #3, the prohibition on air spaces is extreme and does not accounnt for differences in performance from different situations (e.g. vented vs. unvented air space; whether the insulation layer(s) are or are not continuous). While sensible for new construction/compliance, it should be limited to that situation and allow for rater judgement for as-is insulation for existing home audits/ savings estimates.
For example: even a fully vented air space between wall sheathing and rigid insulation exterior to the air space does not entirely nullify the R-value of that rigid insulation layer. If it's 0F, I'd rather be wearing a down jacket with the zipper open and some air space between me and the jacket, than wearing nothing at all.
Add another exception: "For audits or savings estimates of as-is insulation in existing homes, a vented air space between insulation layers shall result in the exterior layer R-value of no more than 50% of its "normal" R-value. Unvented air spaces may be treated as reducing the exterior insulation layer to Grade 3, regardless of its other installed chararteristics."
Comment #101Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 4Paragraph / Figure / Table / Note: Minumum General Installation RequirementsComment Type: TechnicalComment:Item #4 does not recognize a reasonable course of action: to reduce the assumed "density and thickness" to that which results in a lower R-value. That logic is implied on P 7 under open cell foam, #5, exception; but this logic should be explicit and extended to the general requirements. Justification for Change:This language is typical of "minumum installation requirements" but not helpful for raters doing an assessment of an existing home with pre-existing insulation. Proposed Change:Add an exception for #4: "When the specific R-value is not required for compliance purposes, the R-value may be reduced to a value consistent with the actual density, thickness, or compression of the insulation material."
Item #4 does not recognize a reasonable course of action: to reduce the assumed "density and thickness" to that which results in a lower R-value. That logic is implied on P 7 under open cell foam, #5, exception; but this logic should be explicit and extended to the general requirements.
This language is typical of "minumum installation requirements" but not helpful for raters doing an assessment of an existing home with pre-existing insulation.
Add an exception for #4: "When the specific R-value is not required for compliance purposes, the R-value may be reduced to a value consistent with the actual density, thickness, or compression of the insulation material."
Comment #102Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 10Paragraph / Figure / Table / Note: SIPs grade 3Comment Type: EditorialComment:Grade 3 must be modeled as uninsulated. So, a house with 5+% defects that will perform tremendously better thermally and infiltration wise than a fiberglass insulated house with less than 15% defects must be modeled as uninsulated. I guess those planning on building SIP homes should not have electricity, cable, internet, phones, indoor plumbing, or mini-splits on exterior walls to insure that there are not more than 5% cutouts for electrical boxex, pipes and other penetrations.Justification for Change:Align the insulation standardsProposed Change:Model Grade 3 sections at the R-value per inch for the SIP insulating materials.
Grade 3 must be modeled as uninsulated. So, a house with 5+% defects that will perform tremendously better thermally and infiltration wise than a fiberglass insulated house with less than 15% defects must be modeled as uninsulated. I guess those planning on building SIP homes should not have electricity, cable, internet, phones, indoor plumbing, or mini-splits on exterior walls to insure that there are not more than 5% cutouts for electrical boxex, pipes and other penetrations.
Align the insulation standards
Model Grade 3 sections at the R-value per inch for the SIP insulating materials.
Comment #103Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Paragraph / Figure / Table / Note: Minimum Specific Material RequirementsComment Type: TechnicalComment: This heading should be changed so that the scope/intent is clearer.Justification for Change: Consistency with recommended distinction between compliance and as-is installation assessment by raters.Proposed Change: Add a subtitel under the heading "Minimum Specific Material Requirements." as follows: "For the purpose compliance, the following criteria apply for new installations to achieve Grade 1 or 2. For the purpose of an energy audit or assessment of pre-existing installations for estimating savings, the following criteria apply in order to assign Grade 1 to the material."
This heading should be changed so that the scope/intent is clearer.
Consistency with recommended distinction between compliance and as-is installation assessment by raters.
Add a subtitel under the heading "Minimum Specific Material Requirements." as follows: "For the purpose compliance, the following criteria apply for new installations to achieve Grade 1 or 2. For the purpose of an energy audit or assessment of pre-existing installations for estimating savings, the following criteria apply in order to assign Grade 1 to the material."
Comment #104Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 14Paragraph / Figure / Table / Note: Slab on GradeComment Type: TechnicalComment:"To identify slab perimeter insulation, look for a protective coating above grade as opposed to the usual exposed slab edge at any conditioned space(s)." We do not see many monolithic pours in the North East.Justification for Change:ClarityProposed Change:Reword this sentence: To identify exterior slab insulation on a monolithic pour, look for a protective coating above grade as opposed to the usual exposed slab edge at any conditioned space(s).
"To identify slab perimeter insulation, look for a protective coating above grade as opposed to the usual exposed slab edge at any conditioned space(s)."
We do not see many monolithic pours in the North East.
Reword this sentence: To identify exterior slab insulation on a monolithic pour, look for a protective coating above grade as opposed to the usual exposed slab edge at any conditioned space(s).
Comment #105Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 15Paragraph / Figure / Table / Note: above grade wallsComment Type: EditorialComment:"Check for insulation at plumbing outlet under sink or, 'in order of preference,'....Whose preference is this? What if I want to look through the hole the dog chewed in the wall first....? Justification for Change:remove opinions, if this is a safety issue, say that.Proposed Change:Remove "in order of preference" if for safety, replace with, "in order of relative safety"
"Check for insulation at plumbing outlet under sink or, 'in order of preference,'....Whose preference is this? What if I want to look through the hole the dog chewed in the wall first....?
remove opinions, if this is a safety issue, say that.
Remove "in order of preference" if for safety, replace with, "in order of relative safety"
Comment #106Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Paragraph / Figure / Table / Note: Insulated SheathingComment Type: TechnicalComment:Item 1. The requirement to tape all edges and joints _may_ make sense as a Grade 1 requirement, but certainly not for Grade 2. Grade 2 is defined in the modeling process in 303.4.1.4.2 as if there were "_no insulation R-value for 2% of the insulated surface area_". The actual R-value penalty for not taping seams when insulatation boards are tightly fitted to each other should be an order of magnitude smaller than that, so assigning Grade 2 in that case sholud be highly conservative. Also the taping requirement is inappropriate for assessing pre-existing installations. Finally, taping is inappropriate for fibrous exterior rigid insulation. Justification for Change: There is no corresponding requirement to tape or seal pieces of cavity insulation to adjoining insulation or to adjacent framing in order to attain grade 1 or 2; only that it be in substantial contact. Further, this requirement would be inappropriate for applications of rigid insulation on interior surfaces, Proposed Change: Change heading from "Insulated Sheathing" to "Continuous Rigid Insulation" and eliminate item #1. Change "Sheathing" to "Insulation" in item #3. Delete the second sentence under item #4 "Only the joints.... air sealed".
Item 1. The requirement to tape all edges and joints _may_ make sense as a Grade 1 requirement, but certainly not for Grade 2. Grade 2 is defined in the modeling process in 303.4.1.4.2 as if there were "_no insulation R-value for 2% of the insulated surface area_". The actual R-value penalty for not taping seams when insulatation boards are tightly fitted to each other should be an order of magnitude smaller than that, so assigning Grade 2 in that case sholud be highly conservative. Also the taping requirement is inappropriate for assessing pre-existing installations. Finally, taping is inappropriate for fibrous exterior rigid insulation.
There is no corresponding requirement to tape or seal pieces of cavity insulation to adjoining insulation or to adjacent framing in order to attain grade 1 or 2; only that it be in substantial contact. Further, this requirement would be inappropriate for applications of rigid insulation on interior surfaces,
Change heading from "Insulated Sheathing" to "Continuous Rigid Insulation" and eliminate item #1. Change "Sheathing" to "Insulation" in item #3. Delete the second sentence under item #4 "Only the joints.... air sealed".
Comment #107Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Paragraph / Figure / Table / Note: Insulated SheathingComment Type: TechnicalComment:Item 5 is not relevant to the energy assessment of the building.Justification for Change:Specific non-energy requirements for new installation of products is inappropriate for a normative standard on inspection requirements for a HERS rating of "minimum rated features"Proposed Change:Delete item 5.
Item 5 is not relevant to the energy assessment of the building.
Specific non-energy requirements for new installation of products is inappropriate for a normative standard on inspection requirements for a HERS rating of "minimum rated features"
Delete item 5.
Comment #108Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 24-24Paragraph / Figure / Table / Note: instantaneous water heatersComment Type: TechnicalComment:The section above states to look up the EF rating, but the instantaneous section says to look at a nameplate for recovery efficiency. Recovery efficiency is not used in the modeling software REM/Rate for instantaneous DHW, but Energy Factor is.Justification for Change:correct modeling mistakesProposed Change:Add the same language to the instantaneous DHW section for EF as in the storage tank DHW with the reminder that a 92% adjustment is to be made until the software can catch up.
The section above states to look up the EF rating, but the instantaneous section says to look at a nameplate for recovery efficiency. Recovery efficiency is not used in the modeling software REM/Rate for instantaneous DHW, but Energy Factor is.
correct modeling mistakes
Add the same language to the instantaneous DHW section for EF as in the storage tank DHW with the reminder that a 92% adjustment is to be made until the software can catch up.
Comment #109Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: AllComment Type: GeneralComment:I agree with the commenter that the language used throughout "Must" or "must not" as referencing insulation materials or installation practice is inappropriate and confusing. It sounds like a best-practice standard for installers of insulation rather than guidance for a rater inspecting both new and pre-existing work. Proposed Change: Per the previous commenter, or similar.
I agree with the commenter that the language used throughout "Must" or "must not" as referencing insulation materials or installation practice is inappropriate and confusing. It sounds like a best-practice standard for installers of insulation rather than guidance for a rater inspecting both new and pre-existing work.
Per the previous commenter, or similar.
Comment #110Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 27-41Paragraph / Figure / Table / Note: Onsite testingComment Type: EditorialComment:Chapter 8 was created for a reason. The onsite testing section should be listed as such and given a reference to Chapter 8. There is no reason to repeat Chapter 8 unless Chapter 8 will be deleted and incorporated into Appendix A.Justification for Change:There is no point to copying the Chapter 8 onsite testing protocols in Appendix A.Proposed Change:Reference Chapter 8, do not copy it.
Chapter 8 was created for a reason. The onsite testing section should be listed as such and given a reference to Chapter 8. There is no reason to repeat Chapter 8 unless Chapter 8 will be deleted and incorporated into Appendix A.
There is no point to copying the Chapter 8 onsite testing protocols in Appendix A.
Reference Chapter 8, do not copy it.
Comment #111Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 20-25Paragraph / Figure / Table / Note: DefinitionsComment Type: EditorialComment:Appendix B is the definitions/glossary section and all definitions should be moved there.Justification for Change:There is no point in repeating sections.Proposed Change:Move the definitions to Appendix B
Appendix B is the definitions/glossary section and all definitions should be moved there.
There is no point in repeating sections.
Move the definitions to Appendix B
Comment #112Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: First list item #4Comment Type: TechnicalComment: Side stapled batts, even when stapled according to this guidline, may result in too much compression to correctly qualify as Grade 1. Justification for Change: This needs to be changed for clarity and consistency with the other grading requirements.Proposed Change: At the end of item #4, add the following sentence: "If the compression exeeds the total allowed for the cavity depth under "Insulation Grading: Grade 1", then Grade 2 must be assigned.
Side stapled batts, even when stapled according to this guidline, may result in too much compression to correctly qualify as Grade 1.
This needs to be changed for clarity and consistency with the other grading requirements.
At the end of item #4, add the following sentence: "If the compression exeeds the total allowed for the cavity depth under "Insulation Grading: Grade 1", then Grade 2 must be assigned.
Comment #113Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: Blown or Sprayed... item #1Comment Type: TechnicalComment: Item 1; if containment fabric is installed such that insulation does not fill the cavity, the insulation R-value should be adjusted accordingly. Justification for Change: Again, this sounds like a best-practice installation guide for new work rather than guidance for raters to assess what actually exists.Proposed Change:Add the following at the end of the sentence: "; except that the insulation R-value may be reduced according to the actualy installed thickness."
Item 1; if containment fabric is installed such that insulation does not fill the cavity, the insulation R-value should be adjusted accordingly.
Again, this sounds like a best-practice installation guide for new work rather than guidance for raters to assess what actually exists.
Add the following at the end of the sentence: "; except that the insulation R-value may be reduced according to the actualy installed thickness."
Comment #114Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 6Paragraph / Figure / Table / Note: #7 at end of pageComment Type: EditorialComment: Item #7 should not be indented. Proposed Change: Correct formatting.
Item #7 should not be indented.
Correct formatting.
Comment #115Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7Paragraph / Figure / Table / Note: Open Cell _and_ Closed Cell, items #1Comment Type: TechnicalComment: The installer training requirement is inappropriate for grading pre-exsting installations. It may be difficult to verify even for new installations, and (if the material othewise meets the installation criteria) should probably not be a requirement.Justification for Change:This requirement is appropriate for program guidance in a compliance situation, but is beyond the scope of raters assessment of energy performance. Proposed Change: Delete items #1 from both sections. At the very minimum, establish this requirement as a pre-requisite for Grade 1 only and only for compliance purposes for both types of spray foam.
The installer training requirement is inappropriate for grading pre-exsting installations. It may be difficult to verify even for new installations, and (if the material othewise meets the installation criteria) should probably not be a requirement.
This requirement is appropriate for program guidance in a compliance situation, but is beyond the scope of raters assessment of energy performance.
Delete items #1 from both sections. At the very minimum, establish this requirement as a pre-requisite for Grade 1 only and only for compliance purposes for both types of spray foam.
Comment #116Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7Paragraph / Figure / Table / Note: Open Cell ... insulation item #4Comment Type: TechnicalComment:This requirement is not relevant to energy performance that the raters are assessing. Justification for Change:Limit the normative standard on assessing minimum rated features to those qualities that affect the energy performance. Proposed Change:Delete item #4.
This requirement is not relevant to energy performance that the raters are assessing.
Limit the normative standard on assessing minimum rated features to those qualities that affect the energy performance.
Delete item #4.
Comment #117Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7Paragraph / Figure / Table / Note: Open Cell ... insulation item #5Comment Type: TechnicalComment:Even for new installations, the 1/2" limit is arbitrary and may conflict with legitimate designs. Justification for Change:The requirement to fill the cavity to within 1/2" only applies if the intended R-value requires that level of fill.Proposed Change:Eliminate #5. If a statement is made in the general requiremens allowing for assessing a lower R-value when installed insulation thickness dictates, this is unnecessary.
Even for new installations, the 1/2" limit is arbitrary and may conflict with legitimate designs.
The requirement to fill the cavity to within 1/2" only applies if the intended R-value requires that level of fill.
Eliminate #5. If a statement is made in the general requiremens allowing for assessing a lower R-value when installed insulation thickness dictates, this is unnecessary.
Comment #118Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7 and elsewhereComment Type: GeneralComment:Please return pictures for insulation grading. Appendix A's greatest value, from a training and enforcement perspective, is in clarifying application of the standards. Pictures and examples are very important for clarifying technical standards. The insulation grading pictures would be especially missed, but other pictures from throughout appendix A are also valuable. When in doubt, add pictures. Please don't eliminate them.Justification for Change: Pictures are essential.Proposed Change: Return pictures to Appendix A. If the old illustrations are misaligned with new standards, then please amend the pictures and release them concurrently.
Please return pictures for insulation grading. Appendix A's greatest value, from a training and enforcement perspective, is in clarifying application of the standards. Pictures and examples are very important for clarifying technical standards.
The insulation grading pictures would be especially missed, but other pictures from throughout appendix A are also valuable.
When in doubt, add pictures. Please don't eliminate them.
Pictures are essential.
Return pictures to Appendix A. If the old illustrations are misaligned with new standards, then please amend the pictures and release them concurrently.
Comment #119Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 8Paragraph / Figure / Table / Note: Insulation Grading guidanceComment Type: TechnicalComment:There's a contradiction between limitting the percentage of voids (15% for grade 2) and the statement that "voids through interior to exterior of the intended insulation areas must not be permitted" Assessing insulation installation quality requires being able to determine thresholds for modeling and other calculations. As a worst case interpretation of the grading guidance listed, I might say that any insulation, installed in a cavity with voids extending from the interior to the exterior of the intended insulation, fails the criteria for grades 1 or 2, and as grade 3, it must be modeled as uninsulated.Justification for Change: Insulation grading recommendations are internally inconsistent, with regard to voids.Proposed Change: rewrite insulation grading language to give clear percentages for thresholds of gaps and/or compression for each level. Modeling guidance must be consistent with chapter 3.
There's a contradiction between limitting the percentage of voids (15% for grade 2) and the statement that "voids through interior to exterior of the intended insulation areas must not be permitted"
Assessing insulation installation quality requires being able to determine thresholds for modeling and other calculations.
As a worst case interpretation of the grading guidance listed, I might say that any insulation, installed in a cavity with voids extending from the interior to the exterior of the intended insulation, fails the criteria for grades 1 or 2, and as grade 3, it must be modeled as uninsulated.
Insulation grading recommendations are internally inconsistent, with regard to voids.
rewrite insulation grading language to give clear percentages for thresholds of gaps and/or compression for each level.
Modeling guidance must be consistent with chapter 3.
Comment #120Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 17Paragraph / Figure / Table / Note: External Shade ScreensComment Type: EditorialComment: Please clarify what sort of screen samples are used, and how they are rated, in determining the SC of the screen. Having guidance about how to rate screens, including references such as the ASHRAE transactions, can help the rater.Justification for Change: This seems to be a legacy procedure that never got fleshed out. Without more detail, it's hard to follow and hard to teach.Proposed Change: Strike this section or provide clarifying tables and descriptions.
Please clarify what sort of screen samples are used, and how they are rated, in determining the SC of the screen. Having guidance about how to rate screens, including references such as the ASHRAE transactions, can help the rater.
This seems to be a legacy procedure that never got fleshed out. Without more detail, it's hard to follow and hard to teach.
Strike this section or provide clarifying tables and descriptions.
Comment #121Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 8Paragraph / Figure / Table / Note: First paragraphComment Type: TechnicalComment:"...must not be missing or compressed more than 1/2 inch of the nominal..." Compression of more than 1/2" means something very different if the rated thickness is 3 1/2" vs 12". As the requirements below for open- or closed-cell sprayed foam vary due to the differing range of R-value per inch of the materials, some adjustment should be made in this requirement for thicker installations. Justification for Change: For consistency in overall impact, thickness of batt or loose-fill should be accounted for in setting limits for compression or missing thickness.Proposed Change: Change to "...missing or compressed more than 1/2 inch per 6 inches of the nominal..."
"...must not be missing or compressed more than 1/2 inch of the nominal..." Compression of more than 1/2" means something very different if the rated thickness is 3 1/2" vs 12". As the requirements below for open- or closed-cell sprayed foam vary due to the differing range of R-value per inch of the materials, some adjustment should be made in this requirement for thicker installations.
For consistency in overall impact, thickness of batt or loose-fill should be accounted for in setting limits for compression or missing thickness.
Change to "...missing or compressed more than 1/2 inch per 6 inches of the nominal..."
Comment #122Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7Paragraph / Figure / Table / Note: subtitle under "Insulation Grading"Comment Type: EditorialComment: Related to a previous comment: "Insulated Sheathing" is a sub-set of a range of rigid insulation applications. Subtitle and subsections below should be changed accordingly.Justification for Change:For consistency and completeness, all rigid insulation applications should be included.Proposed Change: Change "Insulated Sheathing" in subtitle and elsewhere within this section to "Rigid Insulation"
Related to a previous comment: "Insulated Sheathing" is a sub-set of a range of rigid insulation applications. Subtitle and subsections below should be changed accordingly.
For consistency and completeness, all rigid insulation applications should be included.
Change "Insulated Sheathing" in subtitle and elsewhere within this section to "Rigid Insulation"
Comment #123Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 8Paragraph / Figure / Table / Note: Open-Cell Polyurethane...Comment Type: TechnicalComment:The parenthetical phrase at end of section heading "(cavity not filled and not trimmed)" only applies to some of the subsequent paragraph.Justification for Change: Some of the requirements in this paragraph apply even if the insulation fills the cavity and has been trimmed. The last two sentences apply in those cases, although the second-to-last sentence is arguably unnecessary due to the general requirements.Proposed Change:Delete parenthetical phrase in heading. Replace paragraph with: "When assessing open-cell polyurethane spray foam that does not fill the cavity, the average of all thickness measurements must be greater than the specified thickness required to obtain the specified R-value. No more than 2% of the insulated area must contain voids or be more than ¾ inch below the specified thickness. The minimum installed thickness must not be less than 1 inch below the specified thickness any point, or the R-value shall be adjusted to reflect less thickness. In all open-cell spray foam installations, voids extending from the interior to the exterior of the intended insulation areas must not be permitted."
The parenthetical phrase at end of section heading "(cavity not filled and not trimmed)" only applies to some of the subsequent paragraph.
Some of the requirements in this paragraph apply even if the insulation fills the cavity and has been trimmed. The last two sentences apply in those cases, although the second-to-last sentence is arguably unnecessary due to the general requirements.
Delete parenthetical phrase in heading. Replace paragraph with: "When assessing open-cell polyurethane spray foam that does not fill the cavity, the average of all thickness measurements must be greater than the specified thickness required to obtain the specified R-value. No more than 2% of the insulated area must contain voids or be more than ¾ inch below the specified thickness. The minimum installed thickness must not be less than 1 inch below the specified thickness any point, or the R-value shall be adjusted to reflect less thickness. In all open-cell spray foam installations, voids extending from the interior to the exterior of the intended insulation areas must not be permitted."
Comment #124Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 8Paragraph / Figure / Table / Note: Insulated SheathingComment Type: TechnicalComment: Besides changing the section heading to "Rigid Insulation" as previously noted, the statement that installaitons need to meet the other requirements above is unnecessary, and inconsistent with the other sections above and below. Justification for Change: The minimum specific material requirements are stated previously in the insulation assessment section immediately previous, and don't need to be referenced here.Proposed Change: Delete the first sentence "Insulated sheathing... requirements above".
Besides changing the section heading to "Rigid Insulation" as previously noted, the statement that installaitons need to meet the other requirements above is unnecessary, and inconsistent with the other sections above and below.
The minimum specific material requirements are stated previously in the insulation assessment section immediately previous, and don't need to be referenced here.
Delete the first sentence "Insulated sheathing... requirements above".
Comment #125Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 8-9Paragraph / Figure / Table / Note: Grade 2 (Moderate Defects)Comment Type: TechnicalComment:The statement that "Voids through interior to exterior of the intended insulation areas must not be permitted." as stated, is inappropriate in this section. This occurs at the end of each of the three separate sub paragraphs (batt/loose, open cell, and closed cell). Justification for Change: The statement is inconsistent with the intent of the grading system and is in conflict with the modeling requirements in seciton 303.4.1.4.2. that Grade II (2) be modeled "...such that there is no insulation R-value for 2% of the insulated surface area..."Proposed Change: Change the final sentence in three places to: "Voids extending from the interior to the exterior of the intended insulation may not exceed 2% of the surface area. "
The statement that "Voids through interior to exterior of the intended insulation areas must not be permitted." as stated, is inappropriate in this section. This occurs at the end of each of the three separate sub paragraphs (batt/loose, open cell, and closed cell).
The statement is inconsistent with the intent of the grading system and is in conflict with the modeling requirements in seciton 303.4.1.4.2. that Grade II (2) be modeled "...such that there is no insulation R-value for 2% of the insulated surface area..."
Change the final sentence in three places to: "Voids extending from the interior to the exterior of the intended insulation may not exceed 2% of the surface area. "
Comment #126Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 3 - 4Paragraph / Figure / Table / Note: Measuring Building ComponentsComment Type: EditorialComment:This section of appendix A is inconsistent in language, procedure, and tone. Paragraph 1 appears to be for measuring Conditioned Floor Area, and references ANSI Z765-2005, etc, but doesn't clarify that. Paragraph 2 suggests that only conditioned basements and crawl spaces have their walls hand floors measured. Paragraph 3 applies the same rule of outside measurements (exterior measurements, to the nearest linear inch, to the nearest square foot) to all components no matter what type, no matter how big. Rounding errors could compound quickly on multiple windows using this method. The use of exterior measurements only, is inconsistent with the guidance for measuring walls in paragraph 6. Paragraph 7 suggests a bizarre method of determining area of a ceiling using the measured perimeter. Paragraph 8 ironically suggests that in some cases, it may be necessary to calculate dimensions geometrically.Justification for Change: The Measuring Building Components section appears to be a distillation from the existing Appendix A, without editing for clarity or consistency. As proposed, it is not helpful.Proposed Change: Write a section on measuring building components from scratch. I would be happy to serve on a subcommittee that is given that job.
This section of appendix A is inconsistent in language, procedure, and tone.
Paragraph 1 appears to be for measuring Conditioned Floor Area, and references ANSI Z765-2005, etc, but doesn't clarify that.
Paragraph 2 suggests that only conditioned basements and crawl spaces have their walls hand floors measured.
Paragraph 3 applies the same rule of outside measurements (exterior measurements, to the nearest linear inch, to the nearest square foot) to all components no matter what type, no matter how big. Rounding errors could compound quickly on multiple windows using this method. The use of exterior measurements only, is inconsistent with the guidance for measuring walls in paragraph 6.
Paragraph 7 suggests a bizarre method of determining area of a ceiling using the measured perimeter.
Paragraph 8 ironically suggests that in some cases, it may be necessary to calculate dimensions geometrically.
The Measuring Building Components section appears to be a distillation from the existing Appendix A, without editing for clarity or consistency. As proposed, it is not helpful.
Write a section on measuring building components from scratch. I would be happy to serve on a subcommittee that is given that job.
Comment #127Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 9Paragraph / Figure / Table / Note: Grade 3 (Substantial Defects)Comment Type: TechnicalComment: This section is incomplete and inconsistent with the intent of the grading system, and is in conflict with section 303.4.1.4.2.Justification for Change: The statement is inconsistent with the intent of the grading system and is in conflict with the modeling requirements in section 303.4.1.4.2. that Grade III (or 3) be modeled "...such that there is no insulation R-value for 5% of the insulated surface area...". There is a tremendous difference between an insulated surface with 5% of the insulation missing, and a completely uninsulated surface. If there is consensus that new installations that don't meet Grade 2 should simply not be tolerated, then that statement should be made specifically in connection with rating inspections for the purpose of compliance; however, I believe that such a determination should be at the discretion of the program author, sponsor, or code body and not by RESNET. In any case, to assess performance of pre-existing insulation with significant voids and defects and model it reasonably, A blanket requirement that grade 3 is recorded and modeled "no insulation" would lead to significant over-estimation of existing home energy use, and gross over-prediction of savings, particularly from retrofitting insulation to that assembly.Proposed Change: Delete existing section (2 sentences) and replace with the following: "Installations not complying with the general installation and material requirements, and the requirements for Grade 1 or Grade 2 above must be considered a Grade 3 installation. Voids extending from the interior to exterior of the intended insulation in excess of 5% do not meet the requirements of Grade 3; in such cases, the full area of uninsulated areas must be counted separately from the insulated areas, and recorded as uninsulated."
This section is incomplete and inconsistent with the intent of the grading system, and is in conflict with section 303.4.1.4.2.
The statement is inconsistent with the intent of the grading system and is in conflict with the modeling requirements in section 303.4.1.4.2. that Grade III (or 3) be modeled "...such that there is no insulation R-value for 5% of the insulated surface area...". There is a tremendous difference between an insulated surface with 5% of the insulation missing, and a completely uninsulated surface. If there is consensus that new installations that don't meet Grade 2 should simply not be tolerated, then that statement should be made specifically in connection with rating inspections for the purpose of compliance; however, I believe that such a determination should be at the discretion of the program author, sponsor, or code body and not by RESNET. In any case, to assess performance of pre-existing insulation with significant voids and defects and model it reasonably, A blanket requirement that grade 3 is recorded and modeled "no insulation" would lead to significant over-estimation of existing home energy use, and gross over-prediction of savings, particularly from retrofitting insulation to that assembly.
Delete existing section (2 sentences) and replace with the following: "Installations not complying with the general installation and material requirements, and the requirements for Grade 1 or Grade 2 above must be considered a Grade 3 installation. Voids extending from the interior to exterior of the intended insulation in excess of 5% do not meet the requirements of Grade 3; in such cases, the full area of uninsulated areas must be counted separately from the insulated areas, and recorded as uninsulated."
Comment #128Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 1-40Paragraph / Figure / Table / Note: AllComment Type: GeneralComment: Consider proposing changed sections of appendix A, separately and individually. This is one of the most valuable sections for a rater, and deserves to be a strong document throughout. The specific changes to Chapter 8, the Conditioned Floor Area interpretation, new appliance minimum rated features, and possible insulation grading standards, are all good reasons for amending the relevant sections of the appendix. However, this draws into focus the many parts that are not improved, and which deserve the attention. Looking at the number of comments on various sections (and looking at all the specific paragraphs I think deserve comment, but that I don't have time for), I think delegating amendments for each of those sections is in order. Proposing each section individually would make the reviewing process easier and more productive, I believe. Justification for Change: Amending the entire appendix is difficult and necessarily incomplete.Proposed Change: Reject the proposed amendment, and amend specific sections as they are rewritten and re-edited.
Consider proposing changed sections of appendix A, separately and individually. This is one of the most valuable sections for a rater, and deserves to be a strong document throughout. The specific changes to Chapter 8, the Conditioned Floor Area interpretation, new appliance minimum rated features, and possible insulation grading standards, are all good reasons for amending the relevant sections of the appendix.
However, this draws into focus the many parts that are not improved, and which deserve the attention. Looking at the number of comments on various sections (and looking at all the specific paragraphs I think deserve comment, but that I don't have time for), I think delegating amendments for each of those sections is in order.
Proposing each section individually would make the reviewing process easier and more productive, I believe.
Amending the entire appendix is difficult and necessarily incomplete.
Reject the proposed amendment, and amend specific sections as they are rewritten and re-edited.
Comment #129Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 9Paragraph / Figure / Table / Note: entire section on SIP panelsComment Type: TechnicalComment: This is more like a new construction specification than guidance for rater assessment. The criteria as stated may be difficult to inspect even for new installations, and are not useful for inspection of pre-existing SIP structures. Justification for Change:The procedures need to provide guidance for raters assessing pre-existing structures. The statement that Grade 3 Installations be recorded and modeled as uninsulated is impractical, inconsistent with section 303.4.1.4.2, and inappropriate for modeling of existing homes or developing savings estimates.Proposed Change: At a minimum, remove the statement that Grade 3 Installations be recorded and modeled as uninsulated. Also, make it clear that the criteria for Grade 1 and 2 are intended as applying to new construction and/or new installations.
This is more like a new construction specification than guidance for rater assessment. The criteria as stated may be difficult to inspect even for new installations, and are not useful for inspection of pre-existing SIP structures.
The procedures need to provide guidance for raters assessing pre-existing structures. The statement that Grade 3 Installations be recorded and modeled as uninsulated is impractical, inconsistent with section 303.4.1.4.2, and inappropriate for modeling of existing homes or developing savings estimates.
At a minimum, remove the statement that Grade 3 Installations be recorded and modeled as uninsulated. Also, make it clear that the criteria for Grade 1 and 2 are intended as applying to new construction and/or new installations.
Comment #130Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 10-11Paragraph / Figure / Table / Note: Reflective InsulationComment Type: TechnicalComment:For reflective products it must be made clear that insulation performance other than reflective air spaces per ASHRAE, or assemblies (per ASTM C1224), must be limited to the actual R-value of the material itself in accordance with standard R-vaule tests. Justification for Change: This can be confusing for raters, and it must be made clear that marketing claims of "equivalent R-value" can not be automaticalyl substituted for the R-value of "reflective" materials themselves. Without clarification, it's not clear that the limitations from the previous section apply to the "reflective products" in this section.Proposed Change:Change item #7 to the following: "The R-value for reflective insulation and radiant barriers installed in assemblies without an air space (for example, under slabs) shall be limited to the R-values of the material itself as tested per ASTM C518 or ASTM C177. In general, these material R-values must be used unless assemblies meet the specific requirements for sealed air spaces (using R-vaules per ASHRAE Fundamentals) or entire assemblies (for assemblies rated in accordance with ASTM C1224) as stated above."
For reflective products it must be made clear that insulation performance other than reflective air spaces per ASHRAE, or assemblies (per ASTM C1224), must be limited to the actual R-value of the material itself in accordance with standard R-vaule tests.
This can be confusing for raters, and it must be made clear that marketing claims of "equivalent R-value" can not be automaticalyl substituted for the R-value of "reflective" materials themselves. Without clarification, it's not clear that the limitations from the previous section apply to the "reflective products" in this section.
Change item #7 to the following: "The R-value for reflective insulation and radiant barriers installed in assemblies without an air space (for example, under slabs) shall be limited to the R-values of the material itself as tested per ASTM C518 or ASTM C177. In general, these material R-values must be used unless assemblies meet the specific requirements for sealed air spaces (using R-vaules per ASHRAE Fundamentals) or entire assemblies (for assemblies rated in accordance with ASTM C1224) as stated above."
Comment #131Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 11Paragraph / Figure / Table / Note: Reflective Insulation - item 5Comment Type: TechnicalComment:The performance of the product as a vapor retarder does not affect inspectors assessment of minimum rated features.Justification for Change:This normative appendix should be limited to guidance on minimum rated features as they affect energy performance. Proposed Change:Delete the first sentence: "When reflective insulation is to serve as a vapor retarder... face-stapled."
The performance of the product as a vapor retarder does not affect inspectors assessment of minimum rated features.
This normative appendix should be limited to guidance on minimum rated features as they affect energy performance.
Delete the first sentence: "When reflective insulation is to serve as a vapor retarder... face-stapled."
Comment #132Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 11Paragraph / Figure / Table / Note: Reflective Insulation - Grade 1-3 criteriaComment Type: TechnicalComment:The criteria for grade 1, 2 and 3 are far less stringent for radiant matierials than for insulation. 2% of area uninsulated (compared with 0% for insulation products) for grade 1; 2-10% missing insulation for grade 2.Justification for Change:The criteria shown are in direct conflict with the requirements above for reflective air spaces that "the enclosed airspaces must be sealed cavities which do not to allow air flow in out of the cavity" or " The assembly that is tested for thermal resistance must be representative of the field assembly". Proposed Change:Set the grade 1 criteria to be "no gaps in the insulation are tolerated"; set the grade 2 criteria to allow no more than 2% gaps in reflective insulation. Grade 3 should be limited to 5%, and the statement that grade 3 must be recorded and modeled as uninsulated should be deleted as per my previous comments.
The criteria for grade 1, 2 and 3 are far less stringent for radiant matierials than for insulation. 2% of area uninsulated (compared with 0% for insulation products) for grade 1; 2-10% missing insulation for grade 2.
The criteria shown are in direct conflict with the requirements above for reflective air spaces that "the enclosed airspaces must be sealed cavities which do not to allow air flow in out of the cavity" or " The assembly that is tested for thermal resistance must be representative of the field assembly".
Set the grade 1 criteria to be "no gaps in the insulation are tolerated"; set the grade 2 criteria to allow no more than 2% gaps in reflective insulation. Grade 3 should be limited to 5%, and the statement that grade 3 must be recorded and modeled as uninsulated should be deleted as per my previous comments.
Comment #133Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 12-13Paragraph / Figure / Table / Note: Attic RBs and IRCCsComment Type: TechnicalComment:The criteria for grade 1, 2 and 3 are far less stringent for radiant matierials than for insulation: 2% of area uninsulated (compared with 0% for insulation products) for grade 1; 3-10% and 2-10% missing insulation for grade 2, respectively.Justification for Change:These criteria shown are in direct conflict with the requirements above for reflective air spaces that "the enclosed airspaces must be sealed cavities which do not to allow air flow in out of the cavity"; or "The assembly that is tested for thermal resistance must be representative of the field assembly". Proposed Change:In both sections, set the grade 1 criteria to be "no gaps in the insulation are tolerated"; set the grade 2 criteria to allow no more than 2% gaps in reflective insulation. Grade 3 should be limited to 5%, and the statement that grade 3 must be recorded and modeled as uninsulated should be deleted as per my previous comments.
The criteria for grade 1, 2 and 3 are far less stringent for radiant matierials than for insulation: 2% of area uninsulated (compared with 0% for insulation products) for grade 1; 3-10% and 2-10% missing insulation for grade 2, respectively.
These criteria shown are in direct conflict with the requirements above for reflective air spaces that "the enclosed airspaces must be sealed cavities which do not to allow air flow in out of the cavity"; or "The assembly that is tested for thermal resistance must be representative of the field assembly".
In both sections, set the grade 1 criteria to be "no gaps in the insulation are tolerated"; set the grade 2 criteria to allow no more than 2% gaps in reflective insulation. Grade 3 should be limited to 5%, and the statement that grade 3 must be recorded and modeled as uninsulated should be deleted as per my previous comments.
Comment #134Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 14Paragraph / Figure / Table / Note: Slab on Grade "Covered" and "Exposed"Comment Type: TechnicalComment:The properties of "covered" and "exposed" are not defined anywhere in the rating standard, and no guidance as to the modeling of these properties is given.Justification for Change: Allow software providers to define a range of floor coverings for slabs and model typical R-values for those materials, just as they do for other floors.Proposed Change: Delete these two sections. Add "Make a note of any floor finish or covering on the surface of the concrete slab."
The properties of "covered" and "exposed" are not defined anywhere in the rating standard, and no guidance as to the modeling of these properties is given.
Allow software providers to define a range of floor coverings for slabs and model typical R-values for those materials, just as they do for other floors.
Delete these two sections. Add "Make a note of any floor finish or covering on the surface of the concrete slab."
Comment #135Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 17Paragraph / Figure / Table / Note: Window glazing type - number of panesComment Type: TechnicalComment:The second bullet "look at reflections" is incomplete.Justification for Change: More guidance should be provided.Proposed Change:Change to: "Look at reflections from a slight angle with a pinpoint light source (a mini-mag light with the reflector removed iworks well). Double-paned windows will show four reflections (one for each surface of each pane)."
The second bullet "look at reflections" is incomplete.
More guidance should be provided.
Change to: "Look at reflections from a slight angle with a pinpoint light source (a mini-mag light with the reflector removed iworks well). Double-paned windows will show four reflections (one for each surface of each pane)."
Comment #136Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 17Paragraph / Figure / Table / Note: Window glazing type - tint or low-e coatingComment Type: TechnicalComment:The second bullet regarding the "match test" is incorrect and misleading. Also evidence of field-applied window films should be added.Justification for Change:Low-e or tinted coatings do not add additional reflections; each pane of glass will show two reflections (one for each surface). Suspended films may appear as an additional single reflection, but suspended films are not common.Proposed Change:Replace bullet item with: "Look at color of reflections with pinpoint light source: The color of a reflection from a glass surface with a low-e coating is typically different than the other surfaces. It may have a green, blue, orange tint compared with the others. Note that the low-e surface is always on the outer surface of the inside pane or the inner surface of the outside pane of glass." Add bullet at end: "Look for signs of window-film application at edges of glass (peeling or imperfectly cut edges)."
The second bullet regarding the "match test" is incorrect and misleading. Also evidence of field-applied window films should be added.
Low-e or tinted coatings do not add additional reflections; each pane of glass will show two reflections (one for each surface). Suspended films may appear as an additional single reflection, but suspended films are not common.
Replace bullet item with: "Look at color of reflections with pinpoint light source: The color of a reflection from a glass surface with a low-e coating is typically different than the other surfaces. It may have a green, blue, orange tint compared with the others. Note that the low-e surface is always on the outer surface of the inside pane or the inner surface of the outside pane of glass."
Add bullet at end: "Look for signs of window-film application at edges of glass (peeling or imperfectly cut edges)."
Comment #137Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 18Paragraph / Figure / Table / Note: Exterior shadingComment Type: TechnicalComment: External shading may be important to avoid overestimating retrofit savings in existing homes.Justification for Change: Provide better guidance for existing home assessments and energy savings estimates.Proposed Change:Add the following at end of section: "Note that external shading is excluded from the HERS index calculation but is important for retrofit savings estimates."
External shading may be important to avoid overestimating retrofit savings in existing homes.
Provide better guidance for existing home assessments and energy savings estimates.
Add the following at end of section: "Note that external shading is excluded from the HERS index calculation but is important for retrofit savings estimates."
Comment #138Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 18Paragraph / Figure / Table / Note: DoorsComment Type: TechnicalComment:Heat transfer test is inappropriate for determining door R-valueJustification for Change:The final paragraph is misleading and impossible to apply in mild weather conditions. The use of defaults is more appropriate than such a subjective test.Proposed Change:Delete the words "temperature transfer ," from the 2nd paragraph; delete the final paragraph "Heat transfer-...hollow door."
Heat transfer test is inappropriate for determining door R-value
The final paragraph is misleading and impossible to apply in mild weather conditions. The use of defaults is more appropriate than such a subjective test.
Delete the words "temperature transfer ," from the 2nd paragraph; delete the final paragraph "Heat transfer-...hollow door."
Comment #139Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 27-31Paragraph / Figure / Table / Note: Air leakage testingComment Type: TechnicalComment: There are a number of inconsistencies between this section and section 802.2 of the standard. It is not clear why this section does not simply reference 802.2; the idea that Appendix A could be used as a standalone document is difficult to justify considering the difficulties in maintaining two nearly identical, parallel sections within the same standard. Under #3 Crawlspaces, #4 Attics, the terms "conditioned" and "unconditioned"are used ambiguously; in 802.2 the term used is "inside [outside] the conditioned space boundary" which is clear and well-defined in the standard. In # 14 the treatment of evaporative coolers ("must be covered or sealed") conflicts with 802.2.13. The final sentence after item #18 (dryers) is out of order and should be part of #10, though the language differs slightly from 802.2.9. Beginning at the bottom of P29, the numbering is mixed up. The statement at the bottom of p30 then refers readers to "the procedures in Chapter 8". this is inconsistent with the preceding section that mostly repeats section 202.2. Justification for Change:Sections 802.2, 802.5, 802.6 and 802.7 constitute inspection procedures and should be referenced in Appendix A.Proposed Change: Delete the entire section and replace with a reference to Sections 802.2, 802.5, 802.6 and 802.7. I think it's unnecessary, but if it is desired to repeat the sections so that Appendix A can be used as a standalone document, then these sections could be copied here, complete and "as-is", including section numbers (and indented or shaded to stand apart, with a note that they are repeated for the convenience of the user).
There are a number of inconsistencies between this section and section 802.2 of the standard. It is not clear why this section does not simply reference 802.2; the idea that Appendix A could be used as a standalone document is difficult to justify considering the difficulties in maintaining two nearly identical, parallel sections within the same standard.
Under #3 Crawlspaces, #4 Attics, the terms "conditioned" and "unconditioned"are used ambiguously; in 802.2 the term used is "inside [outside] the conditioned space boundary" which is clear and well-defined in the standard.
In # 14 the treatment of evaporative coolers ("must be covered or sealed") conflicts with 802.2.13.
The final sentence after item #18 (dryers) is out of order and should be part of #10, though the language differs slightly from 802.2.9.
Beginning at the bottom of P29, the numbering is mixed up.
The statement at the bottom of p30 then refers readers to "the procedures in Chapter 8". this is inconsistent with the preceding section that mostly repeats section 202.2.
Sections 802.2, 802.5, 802.6 and 802.7 constitute inspection procedures and should be referenced in Appendix A.
Delete the entire section and replace with a reference to Sections 802.2, 802.5, 802.6 and 802.7. I think it's unnecessary, but if it is desired to repeat the sections so that Appendix A can be used as a standalone document, then these sections could be copied here, complete and "as-is", including section numbers (and indented or shaded to stand apart, with a note that they are repeated for the convenience of the user).
Comment #140Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 31 - 34Paragraph / Figure / Table / Note: Duct leakageComment Type: TechnicalComment:This secton repeats, almost verbatim, the requirements of 803.3-803.7, but without section numbers. The difficulty in maintaining large sections of similar but not identical text in two areas of the standard is hard to justify, when a simple reference to the relevant sections would suffice.Justification for Change:Sections 803.3 - 803.7 constitute inspection procedures and should be referenced in Appendix A.Proposed Change:Delete the entire section and replace with a reference to Sections 803.3 - 803.7. I think it's unnecessary, but if it is desired to repeat the sections so that Appendix A can be used as a standalone document, then these sections could be copied here, complete and "as-is", including section numbers (and indented or shaded to stand apart, with a note that they are repeated for the convenience of the user).
This secton repeats, almost verbatim, the requirements of 803.3-803.7, but without section numbers. The difficulty in maintaining large sections of similar but not identical text in two areas of the standard is hard to justify, when a simple reference to the relevant sections would suffice.
Sections 803.3 - 803.7 constitute inspection procedures and should be referenced in Appendix A.
Delete the entire section and replace with a reference to Sections 803.3 - 803.7. I think it's unnecessary, but if it is desired to repeat the sections so that Appendix A can be used as a standalone document, then these sections could be copied here, complete and "as-is", including section numbers (and indented or shaded to stand apart, with a note that they are repeated for the convenience of the user).
Comment #141Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 34Paragraph / Figure / Table / Note: flows into grilles (section)Comment Type: TechnicalComment:Bag deflation method should be added to this section.Justification for Change:I have used the bag deflation method to measure air flows into grilles, and find it somewhat easier and more repeatable than the bag inflation method for air flows out of grilles.Proposed Change: Add "bag deflation method" to this section (equivalent to the bag inflation method shown in the subequent section, but beginning with the bag full and measuring the time it takes to fully deflate.)
Bag deflation method should be added to this section.
I have used the bag deflation method to measure air flows into grilles, and find it somewhat easier and more repeatable than the bag inflation method for air flows out of grilles.
Add "bag deflation method" to this section (equivalent to the bag inflation method shown in the subequent section, but beginning with the bag full and measuring the time it takes to fully deflate.)
Comment #142Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 34Paragraph / Figure / Table / Note: Ventilation Air Flow TestingComment Type: TechnicalComment: Some ventilation systems have dedicated pressure-measurement ports or accessories to allow "direct" measurement of air flows within the equipment or primary (trunk) ducts. These systems should be noted and allowed as a measurement alternative.Justification for Change: The use of manufacturer's instructions and accessories to measure air flow should be allowed.Proposed Change: Add paragrah as follows to the opening section: "The use of dedicated pressure-measurement ports or accessories provided by ventilation equipment manufacturers to allow "direct" measurement of air flows within the equipment or primary (trunk) ducts may be used as an alternative to flow measurements at grilles. Manufacturer's instructions shall be followed."
Some ventilation systems have dedicated pressure-measurement ports or accessories to allow "direct" measurement of air flows within the equipment or primary (trunk) ducts. These systems should be noted and allowed as a measurement alternative.
The use of manufacturer's instructions and accessories to measure air flow should be allowed.
Add paragrah as follows to the opening section: "The use of dedicated pressure-measurement ports or accessories provided by ventilation equipment manufacturers to allow "direct" measurement of air flows within the equipment or primary (trunk) ducts may be used as an alternative to flow measurements at grilles. Manufacturer's instructions shall be followed."
Comment #143Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 37Paragraph / Figure / Table / Note: Comprehensive Home Energy RatingComment Type: EditorialComment:The title of this section sholud be changed to "combustion appliance testing". Justification for Change: Other sections of the standard may indicate when these tests are required; those criteria need not be limited to a statement or section heading here.Proposed Change:Change the heading and opening paragraph to the following: "Combustion Appliance Testing" "If combustion appliance testing is required (such as for a Comprehensive Home Energy Rating) the following procedures shall be followed."
The title of this section sholud be changed to "combustion appliance testing".
Other sections of the standard may indicate when these tests are required; those criteria need not be limited to a statement or section heading here.
Change the heading and opening paragraph to the following:
"Combustion Appliance Testing" "If combustion appliance testing is required (such as for a Comprehensive Home Energy Rating) the following procedures shall be followed."
Comment #144Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 37-40Paragraph / Figure / Table / Note: Combustion Appliance Tests Comment Type: TechnicalComment:This entire section duplicates sections 806-808 (but with inconsistencies). Those sections should be mentioned here by reference, rather than repeated here (almost) verbatim. Justification for Change:Although already noted for the air leakage and duct test procedures, the difficulty in maintaning two separate but subsantially similar sections of the standard is far more obvious in this case. Ironically, even while this Appendix is out for public comment, the technical committee is in the process of voting on a substantial revision to sections 806-809, which if adopted would necessitate re-writing and re-vetting this section of Appendix A. A simple cross-refrence is much easier to promulgate and maintain. Proposed Change:Delete this section and refer to sections 806-808. If necessary, provide an exact duplicate (including section numbers) set apart from the rest of the appendix A text with shading or an indent, and note that the section is repeated for the convenience of the user. Such section would be automatically updated whenever the referenced sections were amended (and someone would need to remember to do that).
This entire section duplicates sections 806-808 (but with inconsistencies). Those sections should be mentioned here by reference, rather than repeated here (almost) verbatim.
Although already noted for the air leakage and duct test procedures, the difficulty in maintaning two separate but subsantially similar sections of the standard is far more obvious in this case. Ironically, even while this Appendix is out for public comment, the technical committee is in the process of voting on a substantial revision to sections 806-809, which if adopted would necessitate re-writing and re-vetting this section of Appendix A. A simple cross-refrence is much easier to promulgate and maintain.
Delete this section and refer to sections 806-808. If necessary, provide an exact duplicate (including section numbers) set apart from the rest of the appendix A text with shading or an indent, and note that the section is repeated for the convenience of the user. Such section would be automatically updated whenever the referenced sections were amended (and someone would need to remember to do that).
Comment #145Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 4Paragraph / Figure / Table / Note: 1Comment Type: TechnicalComment:Exterior Insulation “Minimum General Installation Requirements: “2. Insulation must be integral to or interior to and in substantial and permanent contact with the primary air barrier.” (p. 4) Insulation that is exterior to and in substantial and permanent contact with the primary air barrier should also be acceptable. For example, a floor over unconditioned space insulated with batts that are held against the subfloor by means of staves.Justification for Change:Exterior insulation is already permitted and the proposed language would contradict this.Proposed Change: “2. Insulation must be integral to or interior to and in substantial and permanent contact with the primary air barrier, except for floor insulation in contact with an interior air barrier” (p. 4)
Exterior Insulation
“Minimum General Installation Requirements:
“2. Insulation must be integral to or interior to and in substantial and permanent contact with the primary air barrier.” (p. 4)
Insulation that is exterior to and in substantial and permanent contact with the primary air barrier should also be acceptable. For example, a floor over unconditioned space insulated with batts that are held against the subfloor by means of staves.
Exterior insulation is already permitted and the proposed language would contradict this.
“2. Insulation must be integral to or interior to and in substantial and permanent contact with the primary air barrier, except for floor insulation in contact with an interior air barrier” (p. 4)
Comment #146Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Paragraph / Figure / Table / Note: 1Comment Type: TechnicalComment: Insulated floors “Minimum Specific Application Requirements: “1. Insulation installed in framed floor assemblies must be in substantial and permanent contact with the subfloor.” (p. 5) The ENERGY STAR Homes program allows insulation to be installed at the exterior surface of the cavity under circumstances: “Fully-aligned air barriers may be installed at the exterior surface of the floor cavity in all Climate Zones if the insulation is installed in contact with this exterior air barrier and the perimeter rim and band joists of the floor cavity are also sealed and insulated to comply with the fully-aligned air barrier requirements for walls.” Can this allowance be explicitly added to the Appendix?Justification for Change: Essentially, this alternate detail creates a “tub”-shaped insulation installation that should be equally effective with insulation that’s in contact with the subfloor. Proposed Change: “1. Insulation installed in framed floor assemblies must be in substantial and permanent contact with the subfloor or fully-aligned air barriers may be installed at the exterior surface of the floor cavity in all Climate Zones if the insulation is installed in contact with this exterior air barrier and the perimeter rim and band joists of the floor cavity are also sealed and insulated to comply with the fully-aligned air barrier requirements for walls.”
Insulated floors
“Minimum Specific Application Requirements:
“1. Insulation installed in framed floor assemblies must be in substantial and permanent contact with the subfloor.” (p. 5)
The ENERGY STAR Homes program allows insulation to be installed at the exterior surface of the cavity under circumstances: “Fully-aligned air barriers may be installed at the exterior surface of the floor cavity in all Climate Zones if the insulation is installed in contact with this exterior air barrier and the perimeter rim and band joists of the floor cavity are also sealed and insulated to comply with the fully-aligned air barrier requirements for walls.” Can this allowance be explicitly added to the Appendix?
Essentially, this alternate detail creates a “tub”-shaped insulation installation that should be equally effective with insulation that’s in contact with the subfloor.
“1. Insulation installed in framed floor assemblies must be in substantial and permanent contact with the subfloor or fully-aligned air barriers may be installed at the exterior surface of the floor cavity in all Climate Zones if the insulation is installed in contact with this exterior air barrier and the perimeter rim and band joists of the floor cavity are also sealed and insulated to comply with the fully-aligned air barrier requirements for walls.”
Comment #147Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 5Paragraph / Figure / Table / Note: 1Comment Type: TechnicalComment: Baffling at eaves “Air permeable insulation installed in ventilated attics and sloped roofs must have an effective air barrier (wind block, air chute, or eave baffle) installed at the eave or soffit edge that extends up and beyond the surface of the insulation or to the ridge vent to prevent air movement through the insulation.” (p. 5) The ENERGY STAR Homes program allows air barriers to only be installed in bays that have soffit vents, as long as the air barrier is tabbed and prevents wind washing of adjacent bays. Can this allowance also be added to the Appendix?Justification for Change: Wind baffles are primarily required where soffit vents are located. Tabbed baffles can prevent wind washing of adjacent bays.Proposed Change: “Air permeable insulation installed in ventilated attics and sloped roofs must have an effective air barrier (wind block, air chute, or eave baffle) installed at each bay with an eave or soffit edge, or a tabbed baffle in each bay with a vent, that will also prevent wind washing of insulation in adjacent baysthat extends up and beyond the surface of the insulation or to the ridge vent to prevent air movement through the insulation.” (p. 5)
Baffling at eaves
“Air permeable insulation installed in ventilated attics and sloped roofs must have an effective air barrier (wind block, air chute, or eave baffle) installed at the eave or soffit edge that extends up and beyond the surface of the insulation or to the ridge vent to prevent air movement through the insulation.” (p. 5)
The ENERGY STAR Homes program allows air barriers to only be installed in bays that have soffit vents, as long as the air barrier is tabbed and prevents wind washing of adjacent bays. Can this allowance also be added to the Appendix?
Wind baffles are primarily required where soffit vents are located. Tabbed baffles can prevent wind washing of adjacent bays.
“Air permeable insulation installed in ventilated attics and sloped roofs must have an effective air barrier (wind block, air chute, or eave baffle) installed at each bay with an eave or soffit edge, or a tabbed baffle in each bay with a vent, that will also prevent wind washing of insulation in adjacent baysthat extends up and beyond the surface of the insulation or to the ridge vent to prevent air movement through the insulation.” (p. 5)
Comment #148Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: ThroughoutParagraph / Figure / Table / Note: ThroughtComment Type: EditorialComment: “Must not require” Throughout the proposed amendments, “Must not require” should be clarified. Does it mean that the treatment that follows is not required, but is permitted, or does it mean that what follows is prohibited? For example: “Insulation installed in attics above ceilings must not require an air barrier on the exterior side.”Justification for Change: The intent of the phrase "must not require" is unclear.Proposed Change: No proposed change suggested, becuase the intent of the current phrase is unclear.
“Must not require”
Throughout the proposed amendments, “Must not require” should be clarified. Does it mean that the treatment that follows is not required, but is permitted, or does it mean that what follows is prohibited? For example: “Insulation installed in attics above ceilings must not require an air barrier on the exterior side.”
The intent of the phrase "must not require" is unclear.
No proposed change suggested, becuase the intent of the current phrase is unclear.
Comment #149Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 10Comment Type: GeneralComment: SPF installer training “Open cell spray polyurethane foam (SPF) insulation: “1. Installers must meet the manufacturer’s recommended training requirements and must complete the online health and safety training for SPF provided by the Center for Polyurethanes Industry.” “Closed-cell spray polyurethane foam (SPF) insulation: “1. Installers must meet the manufacturer’s recommended training requirements and must complete the online health and safety training for SPF provided by the Center for Polyurethanes Industry.” Will Raters be required to verify this as part of conducting a Rating? How? RESNET should not introduce a requirement that will not be recorded during a rating and that Raters will not be able to verify. It is recommended that RESNET remove this requirement or include it only as a recommendation.Justification for Change: RESNET should not introduce a requirement that will not be recorded during a rating and that Raters will not be able to verify.Proposed Change: It is recommended that RESNET remove this requirement or include it only as a recommendation.
SPF installer training
“Open cell spray polyurethane foam (SPF) insulation:
“1. Installers must meet the manufacturer’s recommended training requirements and must complete the online health and safety training for SPF provided by the Center for Polyurethanes Industry.”
“Closed-cell spray polyurethane foam (SPF) insulation:
Will Raters be required to verify this as part of conducting a Rating? How? RESNET should not introduce a requirement that will not be recorded during a rating and that Raters will not be able to verify. It is recommended that RESNET remove this requirement or include it only as a recommendation.
RESNET should not introduce a requirement that will not be recorded during a rating and that Raters will not be able to verify.
It is recommended that RESNET remove this requirement or include it only as a recommendation.
Comment #150Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 7 and 11Comment Type: TechnicalComment: Reflective insulation in nonstandard cavity widths p. 11: “Reflective Insulation in Ceilings, Walls and Floors: “When face-stapled, the material width must match the framing width (e.g. 16” wide material is used for 16” on-center framing). “Exception: Nonstandard cavity widths.” (p. 7) RESNET should not exempt nonstandard cavity widths from this requirement. If the material width does not match the framing width, products will not be installed properly and will not perform as intended (or consistent with the test data or calculations used to determine the assembly’s R-value). If RESNET retains the exemption, RESNET should define “nonstandard”. Does it mean nonstandard with respect to a particular wall assembly, or to prevailing wall construction types in a market?Justification for Change:If the material width does not match the framing width, products will not be installed properly and will not perform as intended (or consistent with the test data or calculations used to determine the assembly’s R-value).Proposed Change: Remove the exception or, if RESNET retains the exemption, RESNET should define “nonstandard”.
Reflective insulation in nonstandard cavity widths
p. 11: “Reflective Insulation in Ceilings, Walls and Floors:
“When face-stapled, the material width must match the framing width (e.g. 16” wide material is used for 16” on-center framing).
“Exception: Nonstandard cavity widths.” (p. 7)
RESNET should not exempt nonstandard cavity widths from this requirement. If the material width does not match the framing width, products will not be installed properly and will not perform as intended (or consistent with the test data or calculations used to determine the assembly’s R-value). If RESNET retains the exemption, RESNET should define “nonstandard”. Does it mean nonstandard with respect to a particular wall assembly, or to prevailing wall construction types in a market?
If the material width does not match the framing width, products will not be installed properly and will not perform as intended (or consistent with the test data or calculations used to determine the assembly’s R-value).
Remove the exception or, if RESNET retains the exemption, RESNET should define “nonstandard”.
Comment #151Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 3Comment Type: EditorialComment:The 3rd paragraph on page 3 refers to a "fully conditioned" basement, crawl space or attic. Suggest changing to "directly conditioned"Justification for Change:consistent use of terminologyProposed Change:If basement, crawl space or attic is determined to be directly conditioned...
The 3rd paragraph on page 3 refers to a "fully conditioned" basement, crawl space or attic. Suggest changing to "directly conditioned"
consistent use of terminology
If basement, crawl space or attic is determined to be directly conditioned...
Comment #152Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: n/aComment Type: TechnicalComment:Thermal resistance Raters sometimes find it challenging to identify the correct thermal resistance of insulation materials for several reasons. First, manufacturers’ thermal performance claims are not always consistent. The R-value claimed for a product on a website or other marketing materials may be different from the R-value listed on the fact sheet (“tech sheet” or “spec sheet”) or the product packaging. The Federal Trade Commission has issued clear guidance on how thermal resistance claims must be made for insulation products (16 CFR Part 460). While the FTC can and does enforce these regulations, that enforcement occurs after violations have occurred; there is no body that reviews and approves manufacturers’ claims before their products are permitted to enter the market. The intensely competitive nature of the home insulation market, combined with some organizations’ limited ability to appropriately interpret and accurately characterize their products’ performance, leads to improper thermal performance claims. Second, R-value claims may not be accurate. Marketers sometimes lack the technical ability to accurately interpret and convey test results or calculations in a way that enables Raters to determine whether or not the conditions of the testing are representative of those in the Rated homes or consistent with FTC labeling regulations. For example, manufacturers sometimes make “effective” or “performance” R-value claims based on the impact of characteristics other than resistance to heat flow, such as reduced air infiltration or thermal mass benefits. If these “performance” R-values are not clearly differentiated from (FTC-compliant) R-values, Raters may use them in their modeling, not knowing that they are overstating the actual thermal resistance or that thermal mass impacts vary by climate. As another example, sometimes the R-values claimed for reflective insulation products include the thermal resistance not only of the enclosed airspace, but of adjacent materials like OSB sheathing or drywall. When the materials included in the calculations are not clearly stated, Raters can inadvertently double-count the thermal resistance of layers when calculating an assembly’s U-value. Third, Raters do not always use product-specific information. Some Raters rely on lists of typical insulation values for types of insulation materials that may be found in training materials, technical standards, rules of thumb transmitted through training, or default values listed in rating software. Finally, Raters sometimes round R-values, for example deeming a product with an R-value of 2.6 to have an R-value of 3. The proposed amendments to Appendix A will significantly improve the consistency and accuracy of Rater R-value determinations, especially for reflective insulation products. RESNET should refine the guidance for reflective insulation to more clearly convey where Raters should obtain R-value information, what information they should look for to be confident in its accuracy, and how to use those R-values in their calculations and ratings. Determining Thermal Resistance for Reflective Insulation Raters should obtain the R-values for reflective insulation materials from either the product packaging or from the product’s fact sheet. The Rater must verify that the R-value claim meets the following criteria: 1. It explains the number and thickness of air spaces that the claim is based on; 2. It explains the direction of heat flow that the claim is based on; 3. It is either based on calculations consistent with the 2009 ASHRAE Handbook of Fundamentals, or on testing consistent with ASTM C1224; and 4. If the R-value is less than R-10, it is rounded to the nearest tenth (e.g., R-1.6, no R-2). Next, the Rater must use this information to verify that the number and thickness of the airspaces and the direction of heat flow in the rated home are consistent with those listed for the product. RESNET should clarify how Raters should account for heat flow. Manufacturer claims are based on one particular direction of heat flow, but in homes the direction of heat flow may change over the course of a year and even day, depending on the climate location. In the case of walls, heatflow should be considered horizontal, and the R-value will not vary by climate or season. There is some difference in the R-value that should be assigned to reflective insulation in attics (e.g., cathedralized ceilings, reflective chutes in rafter bays) based on the direction of heat flow, and there is a significant difference in floors. Finally, when calculating and modeling, Raters should calculate R-values to the nearest tenth, and should take care to include only the benefits of the reflective insulation and air space in the rating software and not to double-count for other materials that may be referenced in promotional materials and/or already accounted for in the rating software (e.g., exterior air films, siding, OSB). Determining Thermal Resistance for Mass Insulation Raters should obtain the R-values for mass insulation materials from either the product packaging or from the product’s fact sheet. The Rater must verify that the R-value claim meets the following criteria: 1. It is accompanied by the details relevant to the performance of each type of material, adapted from 16 CFR § 460.12 and 16 CFR § 460.13, as follows: Batts and blankets: R-value, thickness Loose-fill insulation: Minimum settled thickness, initial installed thickness, maximum net coverage area, number of bags per 1,000 square feet, and minimum weight per square foot at R-values of 13, 19, 22, 30, 38, and 49. Boardstock: R-value, thickness Spray Polyurethane Foam: R-value at 3.5 inches 2. It is based on ASTM C518 or ASTM C177; and 3. If the R-value is less than R-10, it is rounded to the nearest tenth (e.g., R-1.6, no R-2). When calculating and modeling, Raters should calculate R-values to the nearest tenth.Justification for Change:The proposed amendments to Appendix A will significantly improve the consistency and accuracy of Rater R-value determinations, especially for reflective insulation products. RESNET should refine the guidance for reflective insulation to more clearly convey where Raters should obtain R-value information, what information they should look for to be confident in its accuracy, and how to use those R-values in their calculations and ratings.Proposed Change: Determining Thermal Resistance for Reflective Insulation Raters should obtain the R-values for reflective insulation materials from either the product packaging or from the product’s fact sheet. The Rater must verify that the R-value claim meets the following criteria: 1. It explains the number and thickness of air spaces that the claim is based on; 2. It explains the direction of heat flow that the claim is based on; 3. It is either based on calculations consistent with the 2009 ASHRAE Handbook of Fundamentals, or on testing consistent with ASTM C1224; and 4. If the R-value is less than R-10, it is rounded to the nearest tenth (e.g., R-1.6, no R-2). Next, the Rater must use this information to verify that the number and thickness of the airspaces and the direction of heat flow in the rated home are consistent with those listed for the product. RESNET should clarify how Raters should account for heat flow. Manufacturer claims are based on one particular direction of heat flow, but in homes the direction of heat flow may change over the course of a year and even day, depending on the climate location. In the case of walls, heatflow should be considered horizontal, and the R-value will not vary by climate or season. There is some difference in the R-value that should be assigned to reflective insulation in attics (e.g., cathedralized ceilings, reflective chutes in rafter bays) based on the direction of heat flow, and there is a significant difference in floors. Finally, when calculating and modeling, Raters should calculate R-values to the nearest tenth, and should take care to include only the benefits of the reflective insulation and air space in the rating software and not to double-count for other materials that may be referenced in promotional materials and/or already accounted for in the rating software (e.g., exterior air films, siding, OSB). Determining Thermal Resistance for Mass Insulation Raters should obtain the R-values for mass insulation materials from either the product packaging or from the product’s fact sheet. The Rater must verify that the R-value claim meets the following criteria: 1. It is accompanied by the details relevant to the performance of each type of material, adapted from 16 CFR § 460.12 and 16 CFR § 460.13, as follows: Batts and blankets: R-value, thickness Loose-fill insulation: Minimum settled thickness, initial installed thickness, maximum net coverage area, number of bags per 1,000 square feet, and minimum weight per square foot at R-values of 13, 19, 22, 30, 38, and 49. Boardstock: R-value, thickness Spray Polyurethane Foam: R-value at 3.5 inches 2. It is based on ASTM C518 or ASTM C177; and 3. If the R-value is less than R-10, it is rounded to the nearest tenth (e.g., R-1.6, no R-2). When calculating and modeling, Raters should calculate R-values to the nearest tenth.
Thermal resistance
Raters sometimes find it challenging to identify the correct thermal resistance of insulation materials for several reasons. First, manufacturers’ thermal performance claims are not always consistent. The R-value claimed for a product on a website or other marketing materials may be different from the R-value listed on the fact sheet (“tech sheet” or “spec sheet”) or the product packaging. The Federal Trade Commission has issued clear guidance on how thermal resistance claims must be made for insulation products (16 CFR Part 460). While the FTC can and does enforce these regulations, that enforcement occurs after violations have occurred; there is no body that reviews and approves manufacturers’ claims before their products are permitted to enter the market. The intensely competitive nature of the home insulation market, combined with some organizations’ limited ability to appropriately interpret and accurately characterize their products’ performance, leads to improper thermal performance claims.
Second, R-value claims may not be accurate. Marketers sometimes lack the technical ability to accurately interpret and convey test results or calculations in a way that enables Raters to determine whether or not the conditions of the testing are representative of those in the Rated homes or consistent with FTC labeling regulations. For example, manufacturers sometimes make “effective” or “performance” R-value claims based on the impact of characteristics other than resistance to heat flow, such as reduced air infiltration or thermal mass benefits. If these “performance” R-values are not clearly differentiated from (FTC-compliant) R-values, Raters may use them in their modeling, not knowing that they are overstating the actual thermal resistance or that thermal mass impacts vary by climate. As another example, sometimes the R-values claimed for reflective insulation products include the thermal resistance not only of the enclosed airspace, but of adjacent materials like OSB sheathing or drywall. When the materials included in the calculations are not clearly stated, Raters can inadvertently double-count the thermal resistance of layers when calculating an assembly’s U-value.
Third, Raters do not always use product-specific information. Some Raters rely on lists of typical insulation values for types of insulation materials that may be found in training materials, technical standards, rules of thumb transmitted through training, or default values listed in rating software.
Finally, Raters sometimes round R-values, for example deeming a product with an R-value of 2.6 to have an R-value of 3.
The proposed amendments to Appendix A will significantly improve the consistency and accuracy of Rater R-value determinations, especially for reflective insulation products. RESNET should refine the guidance for reflective insulation to more clearly convey where Raters should obtain R-value information, what information they should look for to be confident in its accuracy, and how to use those R-values in their calculations and ratings.
Determining Thermal Resistance for Reflective Insulation
Raters should obtain the R-values for reflective insulation materials from either the product packaging or from the product’s fact sheet. The Rater must verify that the R-value claim meets the following criteria:
1. It explains the number and thickness of air spaces that the claim is based on; 2. It explains the direction of heat flow that the claim is based on; 3. It is either based on calculations consistent with the 2009 ASHRAE Handbook of Fundamentals, or on testing consistent with ASTM C1224; and 4. If the R-value is less than R-10, it is rounded to the nearest tenth (e.g., R-1.6, no R-2).
Next, the Rater must use this information to verify that the number and thickness of the airspaces and the direction of heat flow in the rated home are consistent with those listed for the product. RESNET should clarify how Raters should account for heat flow. Manufacturer claims are based on one particular direction of heat flow, but in homes the direction of heat flow may change over the course of a year and even day, depending on the climate location. In the case of walls, heatflow should be considered horizontal, and the R-value will not vary by climate or season. There is some difference in the R-value that should be assigned to reflective insulation in attics (e.g., cathedralized ceilings, reflective chutes in rafter bays) based on the direction of heat flow, and there is a significant difference in floors.
Finally, when calculating and modeling, Raters should calculate R-values to the nearest tenth, and should take care to include only the benefits of the reflective insulation and air space in the rating software and not to double-count for other materials that may be referenced in promotional materials and/or already accounted for in the rating software (e.g., exterior air films, siding, OSB).
Determining Thermal Resistance for Mass Insulation
Raters should obtain the R-values for mass insulation materials from either the product packaging or from the product’s fact sheet. The Rater must verify that the R-value claim meets the following criteria:
1. It is accompanied by the details relevant to the performance of each type of material, adapted from 16 CFR § 460.12 and 16 CFR § 460.13, as follows:
2. It is based on ASTM C518 or ASTM C177; and 3. If the R-value is less than R-10, it is rounded to the nearest tenth (e.g., R-1.6, no R-2).
When calculating and modeling, Raters should calculate R-values to the nearest tenth.
Comment #153Amendment: Proposed Amendment on On-Site Inspection Procedures for Minimum Rated FeaturesPage Number: 2Comment Type: TechnicalComment:The first section "Conditioned Space" primarily deals with Conditioned Floor Area. Suggest changing the section title to "Conditioned Floor Area". Also, the explanations for Unconditioned, Indirectly Conditioned, and Directly Conditioned spaces are inconsistent with definitions given in Appendix B.Justification for Change:eliminate confusion in an area that is already very confusingProposed Change:change section title to "Conditioned Floor Area", and rewrite explanations of unconditioned, indirectly conditioned and directly conditioned spaces so be consistent with definitions given in Appendix B
The first section "Conditioned Space" primarily deals with Conditioned Floor Area. Suggest changing the section title to "Conditioned Floor Area".
Also, the explanations for Unconditioned, Indirectly Conditioned, and Directly Conditioned spaces are inconsistent with definitions given in Appendix B.
eliminate confusion in an area that is already very confusing
change section title to "Conditioned Floor Area", and rewrite explanations of unconditioned, indirectly conditioned and directly conditioned spaces so be consistent with definitions given in Appendix B
Return to Proposed Amendment on On-Site Inspection Procedures for Minimum Rated Features