Public Comment
in regards to Pool Pumps and Motors
July 30, 2013
Submitted by
Section:
R101.4.3 of the FBC – Energy Conservation
Background:
The 2010 FBC – Energy Conservation included Table
101.4.1 Nonexempt Existing Buildings, which provided requirements for
renovations, specifically equipment found in Section 403, which included pool
pumps and motors. The renovations
portion of this table provided that only when the cost exceeded 30% of the
assessed value of the structure would Section 403 requirements apply. Further, the Commission provided a guidance document
titled “Energy Code Guidelines for Existing Building Replacement Systems,”
which clearly provided that pool filtration pumps only were required to meet
Section 403.9.4 of the code if they were part of a renovation job where total
cost exceeded 30% of the assessed value of the pool structure. Table 101.4.1 was
not brought forward in the 2013 Code. As
the 2013 Code currently stands, it is unclear on what is required when it comes
to replacement pool filtration pumps and motors; therefore, the following
public comment would appear to fall under the glitch category “unintended
results from the integration of previously adopted Florida-specific amendments
with the model code.”
Proposed Modification:
R101.4.3 Additions, alterations, renovations or
repairs. Additions,
alterations, renovations or repairs to an existing building, building system or
portion thereof shall conform to the provisions of this code as they relate to
new construction without requiring the unaltered portion(s) of the existing
building or building system to comply with this code. Additions, alterations,
renovations or repairs shall not create an unsafe or hazardous condition or
overload existing building systems. An addition shall be deemed to comply with
this code if the addition alone complies or if the existing building and
addition comply with this code as a single building.
Exception:
The
following need not comply provided the energy use of the building is not
increased:
1.
Storm windows installed over existing fenestration.
2.
Glass only replacements in an existing sash and frame.
3.
Surface applied window film on existing fenestration assemblies.
4.
Existing ceiling, wall or floor cavities exposed during construction provided
that these cavities are filled with insulation.
5.
Construction where the existing roof, wall or floor cavity is not exposed.
6.
Reroofing for roofs where neither the sheathing nor the insulation is exposed.
Roofs without insulation in the cavity and where the sheathing or insulation is
exposed during reroofing shall be insulated either above or below the
sheathing.
7.
Replacement of existing doors that separate conditioned space from the
exterior shall not require the installation of a vestibule or revolving door, provided,
however, that an existing vestibule that separates a conditioned space from
the exterior shall not be removed,
8.
Alterations that replace less than 50 percent of the luminaires in a space, provided that such alterations do not increase the
installed interior lighting power.
9.
Alterations that replace only the bulb and ballast within the existing
luminaires in a space provided that the alteration does not increase the
installed interior lighting power.
10.
Swimming pool filtration pumps and motors.
Rationale: This modification would make it
clear that when replacing filtration pumps and motors, Section R403.9
(specifically the requirements found in APSP-15 in regards to pool filtration
pumps and motors) does not apply.
APSP-15 provisions addressing pool filtration pumps and motors would
only apply for new construction. The
current 2010 code provides this same exception only when the total cost of the renovations
does not exceed 30% of the assessed value of the pool. This proposal simply makes a blanket
exemption for replacement filtration pumps and motors because in most cases a
pool renovation will not exceed 30% of the assessed value of the pool and it
gives the consumer a choice. Further,
this proposal provides a clearer approach on what pool pump and motor energy
efficiency requirements are provided for replacements versus new construction,
providing clarity for utility companies offering pump rebates and for energy
raters needing to have a clear understanding of the minimum pool requirements
for rating programs.