Staff
Analysis for Declaratory Statement Request DS-2014-075
Issue: Petitioner
seeks a declaratory statement of the Florida Building Code 2010. Specifically,
requesting clarification with regard to the classification of sunrooms due to
the addition of an A/C unit or heat pump that has a dehumidification mode.
Background:
Petitioner
Sprague Ownings, Senior Plans Examiner, County of Marion, Florida has put forth
a petition concerning a situation that has come forth regarding the use of
mini-split air conditioning units that are to be installed in a Category II
& III sunroom. An HVAC Contractor
has submitted an application to install a mini-split in a Category III
sunroom. The HVAC contractor is trying
to justify not having to reclassify the room as habitable (Category IV or V) by
producing paperwork that the unit has a dehumidication mode and the owner has
signed an affidavit that they will only use the unit in dehumidification mode.
The petitioner feels that this is a conversion to habitable space and would
have to comply with the Energy Conservation Code, the NEC 210-52 and 70, and
the floor would have to be raised to meet the minimum clearance from grade.
This
question was also submitted to The Building Officials Association. Their
response is attached (Informal Interpretation Report Number 7296) The BOAF
found that the introduction of air conditioning did turn these rooms into
habitable space. [Commentary: A
mini-split system that could provide cooling added to the sunroom would place
the room in category IV or V, depending on thermal isolation or lack thereof
from the primary structure. All applicable code requirements would apply. To be
exempt, the unit must be controlled by humidistat only.]
Summary:
It
is the petitioner’s belief that the answer to the questions is that the use of
a piece of equipment intended and listed for air conditioning changes the
classification from non-habitiable to habitable in all these conditions and
then requires compliance with the Energy Conservation Code and other applicable
codes for habitable rooms. The petitioner believes that this use of mini-split
unit or window units is an attempt to circumvent the intent of the code.
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Classification of Sunrooms
Florida Building Code,
Residential, section R301.2.1.1.2 Sunrooms.
Sunrooms
shall comply with AAMA/NPEA/NSA 2100 with the structural requirements and
testing provisions of Chapter 5.
AAMA
2100, Section 5.2.1 Wind Loads: Modify Section 5.2.1as follows:
5.2.1
Wind Loads: Basic wind speed (Vasd) in miles per hour (mph) shall be determined
in accordance with Section R301.2.1. Sunrooms including exposed structures,
components, cladding, and roof covering shall be designed to resist the wind
loads as established in Section R301.2.1.
For
the purpose of applying the criteria of the AAMA Standard for sunrooms based on
the intended use, sunrooms shall be categorized in one of the following
categories by the permit applicant, design professional or the property owner
where the sunroom is being constructed.
·
Category I: A roof or a covering of an outdoor space. The openings shall
be permitted to be enclosed with insect screening or 0.5 mm (20 mil) maximum
thickness plastic film. The space is
defined as nonhabitable and unconditioned.
·
Category II: A roof or a covering of an outdoor space with enclosed
walls. The openings are permitted to be enclosed with translucent or
transparent plastic or glass. The space
is defined as nonhabitable and unconditioned.
·
Category III: A roof or a covering of an outdoor space with enclosed walls.
The openings are permitted to be enclosed with translucent or transparent
plastic or glass. The sunroom complies with additional requirements for
forced-entry resistance, air-leakage resistance and water-penetration
resistance. The space is defined as nonhabitable
and unconditioned.
·
Category IV: A roof or a covering of an outdoor space with enclosed
walls. The sunroom is designed to be heated and/or cooled by a separate
temperature control or system and is thermally isolated from the primary
structure. The sunroom complies with additional requirements for forced-entry
resistance, water penetration resistance, air-leakage resistance, and thermal
performance. The space is defined as
habitable and conditioned.
·
Category V: A roof or a covering of an outdoor space with enclosed
walls. The sunroom is designed to be heated and/or cooled and is open to the
main structure. The sunroom complies with additional requirements for
forced-entry resistance, water-penetration resistance, air-leakage resistance,
and thermal performance. The space is
defined as habitable and conditioned.
Definition, Habitable Space:
HABITABLE
SPACE. A space in a structure for living, sleeping, eating or cooking.
Bathrooms, toilet compartments, closets, halls, screen enclosures, sunroom Categories
I, II and III as defined in the AAMA/NPEA/NSA 2100, storage or utility space
and similar areas are not considered habitable space.
Definition, Sunroom
Florida
Building Code, Section 1202.1, SUNROOM.
1.
A room with roof panels that include sloped glazing that is a one-story
structure added to an existing dwelling with an open or glazed area in excess
of 40 percent of the gross area of the sunroom structure’s exterior walls and
roof.
2.
A one-story structure added to a dwelling with solid roof panels without
sloped glazing. The sunroom walls may have any configuration, provided the open
areas with operable or fixed glass or windows or side hinged or sliding glass
doors of the longer wall and one additional wall is equal to at least 65
percent of the area below 6 foot 8 inches (2032 mm) of each wall, measured from
the floor. For the purposes of this code the term sunroom as used herein shall
include conservatories, sunspaces, solariums, and porch or patio covers or
enclosures.
Florida Building Code, Energy
Conservation, Section 503.2.4.3.3 Humidistatic control.
Where
humidification, or dehumidification, or both is provided, the following shall
be met:
1.
At least one humidity control device shall be provided for each humidity
control system.
2.
Controls shall be provided capable of preventing simultaneous operation
of humidification and dehumidification equipment.
2012 Supplement to the
Florida Building Code, Energy Conservation concerning Exempt Buildings
Section
101.4.8.
Exempt buildings. Buildings exempt from the provisions of the Florida Building Code, Energy Conservation,
include existing buildings except those considered renovated buildings, changes
of occupancy type, or previously unconditioned buildings to which comfort
conditioning is added. Exempt buildings
include those specified in Sections 101.4.8.1 through 101.4.8.5.
101.4.8.5. Buildings designed for
purposes other than general space comfort conditioning. Any building where heating or cooling systems
are provided which are designed for purposes other than general space comfort
conditioning. Buildings included in this exemption include:
5. Buildings containing a system(s) designed and
sold for dehumidification purposes only and controlled only by a humidistat. No
thermostat shall be installed on systems thus exempted from this code.
National
Electrical Code, 2011, 210.52 Dwelling Unit Receptacle Outlets. This section provides
requirements for 125-volt, 15- and 20-ampere receptacle outlets.
National
Electrical Code, 2011, 210.70 Lighting Outlets Required. Lighting outlets shall be
installed in accordance with 210.70 (A)(1), (A)(2), and (A)(3).
(1) Habitable Rooms. At least one wall switch-controlled lighting
outlet shall be installed in very habitable room and bathroom.
(2) Additional Locations. Additional lighting outlet shall be installed
in accordance with (A)(2)(a), (A)(2)(b), and (A)(2)(c).
(3)Storage or Equipment Spaces. For attics, underfloor spaces, utility
rooms, and basements, at least one lighting outlet containing a switch or
controlled by a wall switch shall be installed where these spaces are used for
storage or contain equipment requiring servicing.
AAMA/NPEA/NSA
2100-02. Section 7.7
7.7 Electrical
7.7.1 Exit and Stairway Illumination: All sunrooms shall provide stairway and
egress illumination as required by local code.
Exception: Category I sunrooms are not required to have exit lighting.
7.7.2 Receptacle Outlets: Receptacle outlets in Category IV and IV sunrooms
must be installed such that no space along a wall line is in excess of 1.8 m
(6ft) from a receptacle outlet. Any wall space that is 610 mm (24 in.)
receptacle or wider must be served by a receptacle outlet in this manner. Fixed panels of sliding doors are not
considered wall line. Where the installation of a typical wall receptacle
outlet is not possible, a floor receptacle installed within 460 mm (18 in.) of
the wall line may be installed to serve this space.
Exception: Category I, II, and III sunrooms
are exempt from requirements for receptacle outlets.
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BOAF Informal Interpretation
Report Number 7296 (next page)
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Staff
Analysis:
Questions:
1.)
Does the use of a mini-split or other equipment that is listed as an A/C unit
or heat pump that has a dehumidification mode and a promised to only run in the
dehumidication mode exempt the reclassification of a Category I, II, or III
sunroom to a IV or V?
Answer:
The answer is No. As per sections
R301.2.1.1.2 of the 2010 Florida Building Code, Residential, a mini split
system that could provide cooling or heating to the sunroom would place the
room in category IV or V, depending on thermal isolation or lack thereof from
the primary structure. All applicable
code requirements would apply. To be
exempt, the unit must be controlled by a humidistat as required by Section
101.4.8.5(5) of the 2010 Florida Building Code, Energy Conservation.
2.)
Does a dehumidification mode and signed affidavit to only run the unit in
dehumification mode circumvent the listing & labeling intent and circumvent
all other application code requirement.
Answer:
See answer to question #1.