Draft PDS-01, RESNET/ACCA/ICC 310-202x Update

Proposed standard RESNET/ACCA/ICC 310-202x amends the 2020 edition of Standard 310. This second edition of the Standard will include minor updates and changes identified during implementation of the first edition.

This is the first public review draft, PDS-01, RESNET/ACCA/ICC 310-202x. It is submitted for public comment for 45 days, beginning August 16, 2024, and ending September 30, 2024. Only the changes shown in draft PDS-01 by strike-through and underline and red print are open for comment.

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Entry Date: August 16, 2024 at 11:10 AM

Full Name: Leo Jansen

Affiliation: Energy Efficient Homes Midwest, Inc.

Address: 30590 Lorain Rd N Olmsted, Ohio 44070

Phone Number: 3174106567

Email: leojansen@eehmidwest.com

Page Number: 4

Section/Table/Figure Number: Definition of Bedroom and Informative Note 2

Comment Intent: Objection

Comment Type:

The definition of a bedroom and the associated informative note that further defines what a bedroom is listed in Draft PDS-01, RESNET/ACCA/ICC 310-202x Update aligns with the current definition found in the published version of ANSI/RESNET/ICC 301-2022.  It DOES NOT align with the current definition of a bedroom found in ANSI/RESNET/ICC 850-2020.

There is a current discussion with the RESNET Standards Manager and several members of the standards writing community concerning whether or not the definition of a Bedroom should include a closet.  While the definition of a bedroom listed below does not include a closet, it is listed as a requirement in the informative note.  This creates confusion within the Rating Community as to whether or not a closet is required for a room to be counted as a bedroom, as informative notes are not supposed to be considered a standard requirement.  The modeled number of bedrooms has a huge impact on the Rating Model, affecting everything from annual energy use calculations, required ventilation targets, the number of ceiling fans required, etc.

As this matter is now being considered within Informative Note 2 of the proposed Draft PDS-01, RESNET/ACCA/ICC 310-202x Update, I would encourage the committee and the Standards Management Board to align the definition of a bedroom and any associated informative notes in all RESNET standards so that they are clear on the matter of whether or not a closet is required for a room to be counted as a bedroom.

 

Bedroom – For one- and two-family Dwellings and Townhouses, a room [1] or space 70 square feet of floor area or greater, with Egress Window or skylight, and doorway to the main body of the Dwelling Unit, that can be used for sleeping [2]. For all other Dwelling Units, a room [3] or space that can be used for sleeping. For all Dwelling or Sleeping Units, the number of Bedrooms shall not be less than one.

 

[2] (Informative Note) A “den,” “library,” “home office” or other similar rooms with a closet, Egress Window, and doorway to the main body of the Dwelling Unit as well as 70 square feet of floor area or greater are considered a Bedroom. However, living rooms, foyers, and other rooms not intended for sleeping are not. The number of rooms identified as Bedrooms is used to determine the number of occupants.

Comment:

I do not have a proposed change to suggest on this matter at this time, I mainly wanted to bring this issue to the committee’s attention and encourage them to address it with the RESNET Standards Management Board as well as the other RESNET Standards committees to find an agreed upon solution.

Proposed Change to Amendment:

Entry Date: August 26, 2024 at 6:27 PM

Full Name: Sharla Riead

Affiliation: EnergySmart Institute

Address: 11601 Orchard Rd. Kansas City, Missouri 64134

Phone Number: 816-678-8884

Email: sharla@energysmartinstitute.com

Page Number: 4

Section/Table/Figure Number: Informative note with superscript 3 about the definition of a Bedroom

Comment Intent: Objection

Comment Type:

I was on the committee that worked on updating the definition of a Bedroom.  The new definition is incorporated in Standard 301 currently out for public comment, but was not included in Standard 310.  The standards should be brought into alignment and use the same definition.  However, the definition was not updated in this version, so is not up for comment.  The committee that discussed this included representation and feedback for both standards.  One of the changes to be made was to remove the requirement for a closet from the informative note as that has led to inconsistencies in how bedrooms are counted.  The informative note should at least be updated.

Comment:

3(Informative Note) A “den,” “library,” “home office” or other similar rooms with an closet, Egress Window, and doorway to the main body of the  Dwelling Unit as well as 70 square feet of floor area or greater are considered a Bedroom.  However, living rooms, foyers and other rooms not intended for sleeping are not. The number of rooms identified as Bedrooms is used to determine the number of occupants.

Proposed Change to Amendment: