Code Change Recommendation Summary and Justification

The 2015 report prepared for the FBC titled “Investigation of the Effectiveness and Failure Rates of Whole-House Mechanical Ventilation Systems in Florida” provided recommendations for code changes. Since the recommendations may require revisions to a future edition of the Florida Building Code, each was analyzed using the criteria outlined in the currently adopted code modification form. The analysis was separated into two recommendation groups:

· Group 1: Do not require houses to become tighter than already specified by code. Consider increasing allowed leakage to 7 ACH50 in climate zones 1 and 2 (all of Florida).

· Group 2: Labels, Documentation, Operational Status Notification, Installation and Testing.

Group 1: a. Do not require houses to become tighter than already specified by code- no change from Florida 2014 or IECC 2015 (base code for Florida 2017).

Group 1: b. Increase allowed leakage to 7 ACH50 in climate zones 1 and 2 (all of Florida).

· Rationale: This recommendation is intended to limit negative impacts of mechanical ventilation failure by allowing slightly more leakage in homes than current code. This greater natural leakage may provide some small benefit of fresh air when mechanical systems fail.

· Fiscal Impact Statement

o Impact to local entity relative to enforcement of code (553.73(9)(b),F.S.): No additional code enforcement required.

o Impact to building and property owners relative to cost of compliance with code (553.73(9)(b),F.S.): No additional first cost to construct (may be less costly) and depending on ventilation requirement and method may be no more cost to operate.

o Impact to industry relative to the cost of compliance with code (553.73(9)(b),F.S.): No cost to affected industry.

o Impact to small business relative to the cost of compliance with code (553.73(9)(b),F.S.): No impact to small businesses.

· Requirements

o Has a reasonable and substantial connection with the health, safety, and welfare of the general public (553.73(9)(a)2,F.S.): This recommendation should increase the health, safety, and welfare of the general public.

o Strengthens or improves the code, and provides equivalent or better products, methods, or systems of construction (553.73(9)(a)3,F.S.): This recommendation strengthens the health and safety aspects of the code by limiting the negative impacts of mechanical ventilation failure.

o Does not discriminate against materials, products, methods, or systems of construction of demonstrated capabilities (553.73(9)(a)4,F.S.): This recommendation does not discriminate against materials, products, methods, or systems of construction of demonstrated capabilities.

o Does not degrade the effectiveness of the code (553.73(9)(a)5,F.S.): This recommendation slightly reduces the minimum tightness of the home but that has small to no energy penalty and is a good trade-off for the potential health benefits.

· Is the proposed code modification part of a prior code version? This recommendation modifies the 2014 Florida Energy Conservation Code airtightness requirement.

o 1. The provisions contained in the proposed amendment are addressed in the applicable international code? (553.73(7)(g),F.S.) The applicable international code is the same as the 2014 Florida Energy Conservation Code.

o 3. The proposed amendment was submitted or attempted to be included in the foundation codes to avoid resubmission to the Florida Building Code amendment process. (553.73(7)(g),F.S.): Report just completed. Will attempt to submit at the next available opportunity.

Group 2: Labels, Documentation, Operational Status Notification, Installation and Testing.

Require general labeling that:

o Indicates the home has a ventilation system

o Provides labels on key components of the ventilation system

§ Ducts labeled as ventilation system duct (including flow direction indication preferred)

§ Grilles noted as vent system intake or discharge

§ Dampers noted as ventilation system dampers

§ Key ventilation fan components labeled as appropriate (ERV as ERV, supply vent fan as such, etc.)

§ Ventilation controllers.

Require general summary documentation written for occupants that:

o Describes what a ventilation system is and how it differs from the air conditioning system

o Describes how to tell if the vent system is operable, and suggested frequency of verification (may require improvement in some systems currently on the market)

o Describes the location of ducts, dampers, ERV, fan units, filters, and control(s)

o Indicates recommended filter and intake/discharge grille(s) service frequency.

Require alarm(s) indicating failure of every component of the ventilation system

o Alarms could be visual, audio or both and should signal on the event of fan failure, damper failure, or when loss of control /communication occurs

o One example of a visual alarm notice (if occupant is educated) can even be the absence of an “operational” green light in the case where local low voltage or system voltage is lost due to failed transformer or a tripped circuit breaker.

Require intake grille or other vent collar heights to be at least 2 inches, mechanically attached to grille or vents, with seams and joints sealed with mastic or other code approved duct sealant.

Disallow filter locations that require ladders to access; consider exception to this if an alarm feature is implemented indicating a need for service.

Require either damper controlled passive or mechanical make-up air relief air to any home with high capacity kitchen exhaust fan with flow rates capable of 400 cfm or more regardless of combustion equipment; indoor house pressure with reference to outdoors should be tested (with kitchen exhaust fan running at its maximum flow rate) not to exceed 3 Pascals.

The builder must submit a test report for the mechanical ventilation system that indicates:

o the location of the system

o any air intake location

o any filter locations

o the control status as designed

o the tested cfm flow.

· Rationale: All recommendations are intended to increase the reliability and effectiveness of whole house mechanical ventilation systems in Florida. Based on the findings of the FBC study on whole house residential ventilation systems these items are necessary to assure the intent of the code is realized.

· Fiscal Impact Statement

o Impact to local entity relative to enforcement of code (553.73(9)(b),F.S.): Each recommendation would require additional code enforcement; estimate 15-30 minutes additional inspection time for all recommendations on homes containing whole-house mechanical ventilation systems.

o Impact to building and property owners relative to cost of compliance with code (553.73(9)(b),F.S.): All recommendations would likely require some additional cost to building and property owners; estimate $25-$100 per house, excluding kitchen make-up air.

o Impact to industry relative to the cost of compliance with code (553.73(9)(b),F.S.): Each recommendation would result in some cost to affected industry; estimated cost $15-$75 per house, excluding kitchen make-up air.

o Impact to small business relative to the cost of compliance with code (553.73(9)(b),F.S.): These are residential code recommendations, so no impact to small businesses unless the small business manufactures or sells affected equipment.

· Requirements

o Has a reasonable and substantial connection with the health, safety, and welfare of the general public (553.73(9)(a)2,F.S.): Each recommendation should increase the health, safety, and welfare of the general public.

o Strengthens or improves the code, and provides equivalent or better products, methods, or systems of construction (553.73(9)(a)3,F.S.): Each recommendation strengthens the code and provides better products and methods by providing a means to increase the reliability and effectiveness of whole house mechanical ventilation systems in the state.

o Does not discriminate against materials, products, methods, or systems of construction of demonstrated capabilities (553.73(9)(a)4,F.S.): None of the recommendations discriminate against materials, products, methods, or systems of construction of demonstrated capabilities; they should only improve affected products.

o Does not degrade the effectiveness of the code (553.73(9)(a)5,F.S.): Each of the recommendations increases the effectiveness of the code by providing a means to increase the reliability and effectiveness of mechanical ventilation systems in the state.

· Is the proposed code modification part of a prior code version? No.

o 1. The provisions contained in the proposed amendment are addressed in the applicable international code? (553.73(7)(g),F.S.) No.

o 2. The amendment demonstrates by evidence or data that the geographical jurisdiction of Florida exhibits a need to strengthen the foundation code beyond the needs or regional variation addressed by the foundation code and why the proposed amendment applies to the state. (553.73(7)(g),F.S.): These recommendations should be made at the foundation code level as well but the need for them has only been demonstrated in Florida and a few other locations. Unclear whether the base code committees will want more research for other parts of the nation. However, because we know the situation in Florida, for now this is justified as a Florida-specific recommendation.

3. The proposed amendment was submitted or attempted to be included in the foundation codes to avoid resubmission to the Florida Building Code amendment process. (553.73(7)(g),F.S.): Report just completed. Will attempt to submit at the next available opportunity.