Draft PDS-01, RESNET/ICC 850-202x Update (Comment opens May 31, 2024)

Entry Date: June 10, 2024 at 12:46 PM

Full Name: Brian Christensen

Affiliation: Residential Energy Management Services

Address: 7605 Bergamo Ave Sarasota, Florida 34238

Phone Number: 9412034750

Email: brian@remsvc.com

Page Number: 11 of 29

Section/Table/Figure Number: 4.4.2 Determining Irrigated Area for the Reference Home

Comment Intent: Objection

Comment Type: Editorial

Comment:

The language in the text leading to Eq 4.4-2a and Eq 4.4-2b makes an odd distinction without apparent purpose.  The first refers to a “one- or two-family dwelling” while the second is a “detached or duplex dwelling”.  The rest of the descriptions makes what appears to be the real distinction, i.e. whether the lot size is above or below a specific threshold.
I suggest using the “one- or two-family dwelling” language for both entries, since it encompasses single-family detached, townhome, and duplex homes.

Proposed Change to Amendment:

• 4.4.2 Determining Irrigated Area for the Reference Home. Reference Home Irrigated Area shall be calculated as follows:

Where the Rated Home is a one- or two-family dwelling and the lot size of the Rated Home is less than 7,000 ft2, the Irrigated Area of the Reference Home shall be calculated as follows:

(Eq 4.4-2a)

Where the Rated Home is a detached or duplexone- or two-family dwelling dwelling and the Lot Size of the Rated home is greater than or equal to 7,000 ft2, the Irrigated Area of the Reference Home shall be calculated as follows:

                                                                     (Eq 4.4-2b)

Where:

Ref_Irr_Area= The size of the landscape that receives supplemental water in the Reference Home

Lot_Area= The size of the lot on which the Rated Home is being constructed

For multi-family building properties, the irrigated area for the Reference Home shall be the same as the Rated Home irrigated area.

Entry Date: July 2, 2024 at 9:48 AM

Full Name: Zac Mullins

Affiliation: Building Efficiency Resources, LLC

Address: PO Box 1769 Brevard, North Carolina 28712

Phone Number: 18003999620

Email: info@theber.com

Page Number: 25

Section/Table/Figure Number: 6.1.4.2.1

Comment Intent: Objection

Comment Type: General

Comment:

Section: 6.1.4.2.1 a-c :  With the intent of this section to align sampling procedures to MINHERS section 600.  The wording should be updated to reflect the coming changes to the sampling process effective July 1, 2025.  This will ensure that the procedure stays in line with MINHERS moving forward without another change needed. 

Proposed Change to Amendment:

a. Homes shall be grouped with up to seven per MINHERS section 602.5 in each sample set. 

b. The seven grouped homes per MINHERS section 602.5 shall have their irrigation systems installed within a 30-day 90-day period. 

c, The seven grouped homes per MINHERS section 602.5 homes shall have the same irrigation controller and emitter technology (spray vs. drip) 

Entry Date: July 11, 2024 at 12:06 PM

Full Name: Robert Pickering

Affiliation: ERG on behalf of EPA WaterSense

Address: 1600 Perimeter Park Drive, Suite 200 Morrisville, North Carolina 27560

Phone Number: 5713290243

Email: robert.pickering@erg.com

Page Number: 5

Section/Table/Figure Number: 3.2

Comment Intent: Not an Objection

Comment Type: General

Comment:

The standard needs to establish a definition for “multifamily.” This is a new term used in the standard within Sections 4.3.6, 4.4.2, 4.5.7, and 4.6. The definition should clearly indicate the characteristics of a multifamily building (e.g., minimum number of units, minimum number of floors).

(Note: Underlining was not an option in the comment template, so using bolding for new text).

Proposed Change to Amendment:

Multifamily building – a building with more than two dwelling units that are connected through shared demising walls, floors, ceilings, or common corridors.

Entry Date: July 11, 2024 at 12:07 PM

Full Name: Robert Pickering

Affiliation: ERG on behalf of EPA WaterSense

Address: 1600 Perimeter Park Drive, Suite 200 Morrisville, North Carolina 27560

Phone Number: 5713290243

Email: robert.pickering@erg.com

Page Number: 5

Section/Table/Figure Number: 3.2

Comment Intent: Not an Objection

Comment Type: General

Comment:

The standard needs to establish a definition for “duplex.” This is a new term used in the standard within Sections 4.4.2 and 4.6. The definition should clearly indicate that a duplex is not considered a multifamily building.

(Note: Underlining was not an option in the comment template, so using bolding for new text).

Proposed Change to Amendment:

Duplex – A building made up of two attached single-family dwelling units that are connected through at least one shared demising wall, floor, ceiling, or common corridor. Also referred to as a two-family dwelling.

Entry Date: July 11, 2024 at 12:09 PM

Full Name: Robert Pickering

Affiliation: ERG on behalf of EPA WaterSense

Address: 1600 Perimeter Park Drive, Suite 200 Morrisville, North Carolina 27560

Phone Number: 5713290243

Email: robert.pickering@erg.com

Page Number: 5

Section/Table/Figure Number: 3.2

Comment Intent: Not an Objection

Comment Type: General

Comment:

Include Reverse Osmosis (RO) System reject water as a potential source of gray water. While water use from RO systems is not currently captured by this standard, it should be considered for future updates. RO systems are becoming more prevalent and can contribute to significant water use. The reject water from these systems is a suitable source of graywater.

(Note: Underlining was not an option in the comment template, so using bolding for new text).

Proposed Change to Amendment:

Gray Water—Waste discharged from lavatories, bathtubs, showers, clothes washers, and laundry trays and reject water from reverse osmosis systems.

Entry Date: July 11, 2024 at 12:10 PM

Full Name: Robert Pickering

Affiliation: ERG on behalf of EPA WaterSense

Address: 1600 Perimeter Park Drive, Suite 200 Morrisville, North Carolina 27560

Phone Number: 5713290243

Email: robert.pickering@erg.com

Page Number: 9

Section/Table/Figure Number: Equation 4.4-1a

Comment Intent: Not an Objection

Comment Type: Editorial

Comment:

The “pool use” variable formatting is inconsistent with the formatting in other equations (such as Eq 4.4-1b).

(Note: Underlining was not an option in the comment template, so using bolding for new text).

Proposed Change to Amendment:

Change to “pool_use”.

Entry Date: July 11, 2024 at 12:14 PM

Full Name: Robert Pickering

Affiliation: ERG on behalf of EPA WaterSense

Address: 1600 Perimeter Park Drive, Suite 200 Morrisville, North Carolina 27560

Phone Number: 5713290243

Email: robert.pickering@erg.com

Page Number: 10

Section/Table/Figure Number: 4.4.2

Comment Intent: Not an Objection

Comment Type: Editorial

Comment:

Language related to properties with lot size less than 7000 square feet is inconsistent with language related to properties with lot size greater than 7000 square feet. The first section applying to Eq 4.4-2a says “Where the Rated Home is a one- or two-family dwelling…”. The second section applying to Eq 4.4-2b says “Where the Rated Home is a detached or duplex dwelling…”. Terminology should be made consistent to ensure it is clear that these calculations apply to the same dwelling types, only with different lot sizes.

In addition, townhouses need to be addressed in the text ahead of Equations 4.4-2a and 4.4-2b. As written, townhouses (defined in Section 3.2 as a single-family dwelling unit) are not addressed. Suspect the intent is for townhomes to be addressed by the equations presented (rather than as multifamily).

(Note: Underlining was not an option in the comment template, so using bolding for new text).

Proposed Change to Amendment:

4.4.2 Determining Irrigated Area for the Reference Home. Reference Home Irrigated Area shall be calculated as follows:

Where the Rated Home is a one- or two-family dwelling detached, duplex, or townhouse dwelling and the lot size of the Rated Home is less than 7,000 ft2, the Irrigated Area of the Reference Home shall be calculated as follows:

(Eq 4.4-2a)

Where the Rated Home is a detached, or duplex, or townhouse dwelling and the Lot Size of the Rated home is greater than or equal to 7,000 ft2, the Irrigated Area of the Reference Home shall be calculated as follows:

(Eq 4.4-2b)

Entry Date: July 11, 2024 at 12:26 PM

Full Name: Robert Pickering

Affiliation: ERG on behalf of EPA WaterSense

Address: 1600 Perimeter Park Drive, Suite 200 Morrisville, North Carolina 27560

Phone Number: 5713290243

Email: robert.pickering@erg.com

Page Number: 15

Section/Table/Figure Number: 4.5.7.1

Comment Intent: Not an Objection

Comment Type: Technical

Comment:

Suggest moving the new Section 4.5.7.1 to a new section (Section 4.7) dedicated to alternative water use. While the standards committee may not be able to address other alternative water use at this time, establishing a stand-alone section for alternative water use would accommodate graywater use for other end uses (not just toilet flushing) and other forms of alternative water (e.g., rainwater harvesting) either now or in the future.

Further, the section should define uses of alternative water by the source and use and for each combination should describe an equation for calculating the a) the available water b) the effective yield, and c) how this is applied to offset potable water use.

(Note: Underlining was not an option in the comment template, so using bolding for new text).

Proposed Change to Amendment:

(Delete and Replace 4.5.7.1 with the following).

4.7 Alternative Water Use for the Rated Home
Where a Rated Home has alternative water, the amount of alternative water shall be calculated and reduce the Rated Home’s water use in accordance with Table 4.7.1
Table 4.7.1 Calculations for Types of Alternative Water Use
Columns:
· Type of Alternative Water- Source
· Type of Alternative Water- Use
· Offset Calculation- Source
· Offset Calculation- Effective Yield
· Offset Calculation- Offset
Row 1
· Type of Alternative Water- Source: Grey water collected from plumbing products and appliances
· Type of Alternative Water- Use: Flushing of toilets
· Offset Calculation- Source: Calculated as the sum of all end use sources (e.g. shower, lav faucets, clotheswashers) for the rated home. If not all potential sources of a similar fixture type feed the system, the water from that end use use should be equally divided across the number of fixture type present in the Rated Home (e.g., if one of two showers are connected to the gray water system, only half of daily shower water use would be eligible to be counted as gray water).
· Offset Calculation- Effective Yield: 80%
· Offset Calculation- Offset: Total of source times the effective yield applied to (but not to exceed) toiletgpd.

Entry Date: July 11, 2024 at 12:43 PM

Full Name: Robert Pickering

Affiliation: ERG on behalf of EPA WaterSense

Address: 1600 Perimeter Park Drive, Suite 200 Morrisville, North Carolina 27560

Phone Number: 5713290243

Email: robert.pickering@erg.com

Page Number: 16

Section/Table/Figure Number: 4.6

Comment Intent: Not an Objection

Comment Type: Editorial

Comment:

Remove new language in Section 4.6 ahead of the equations. The outdoor water use equation for the rated home should apply to all dwelling/building types (including townhouses and multifamily). If the intent is to add the clarifying “detached and duplex dwelling units”, then a separate equation would need to be added that would apply to multifamily units/buildings.

If language isn’t removed, then similar edits should be made here as suggested in Section 4.4.2 to include townhouses and a new equation would need to be added for multifamily.

(Note: Underlining was not an option in the comment template, so using bolding for new text).

Proposed Change to Amendment:

4.6. Determining Outdoor Water Use for the Rated Home. The Rated Home Outdoor Water Use shall be calculated as follows:

Where the Rated Home is a detached or duplex dwelling and has an Automatic Irrigation System, Outdoor Water Use shall be calculated as follows:

(Eq 4.6-1)

Where the Rated Home is a detached or duplex dwelling and does not have an Automatic Irrigation System, Outdoor Water Use shall be calculated as follows:

(Eq 4.6-2)

Entry Date: July 15, 2024 at 6:14 PM

Full Name: Edward Osann

Affiliation: self

Address: 5475 31 Street NW Washington, District of Columbia 20015

Phone Number: 3015354013

Email: eosann@starpower.net

Page Number: 10

Section/Table/Figure Number: 4.4.2

Comment Intent: Not an Objection

Comment Type: Technical

Comment:

It is unclear wjhy the two paragraphs of this section are using different language to describe (non-multi-family) rated homes situated on lots less than or greater than 7000 sf.

Proposed Change to Amendment:

Harmonize these two clauses:

Where the Rated Home is a one- or two-family dwelling and the lot size of the Rated Home is less than 7,000 ft2

And

Where the Rated Home is a detached or duplex dwelling and the Lot Size of the Rated home is greater than or equal to 7,000 ft2,