NAHB has voiced concern that the standard:
- Requires outdoor air to be blown or drawn into homes constantly, which may lead to mold and structural deterioration; add to heating, cooling and dehumidification costs; and make indoor air quality worse, not better
- Requires exhaust fans in kitchens and bases the requirements on kitchen volume, which cannot be determined where kitchen areas are open to other parts of the house
- Bans recirculating hoods
- Bases the size of downdraft exhaust fans on the volume of the room instead of on the ability of the fan to exhaust cooking odors, often requiring larger fans than necessary
- Requires quiet, expensive sone-rated fans but does not define “sone” and does not specify a particular method for calculating sones
- Requires clothes dryers to be exhausted directly to the outdoors, in effect banning new water- and energy-saving condensing models that have no exhaust
- Prohibits ducts and air handlers in garages unless an expensive duct leakage test is done, even where joints are sealed
- In many homes, requires testing of natural draft oil and gas fuel-burning equipment using a test designed for gas equipment that research has shown is unreliable in predicting flue malfunctions
- Requires testing of fireplaces using inappropriate factory tests and does not specify which test to use
NAHB also contends in the appeal that ASHRAE has failed to follow its own rules and procedures for standards development and has not reached a consensus of affected interests as required by the American National Standards Institute (ANSI).
NAHB believes the committee that has been developing the standard does not include a balance of interests and, in its pursuit of an overly aggressive agenda for residential ventilation, has disregarded significant concerns by NAHB, AGA, AHAM and others. These concerns have been raised and documented with the appropriate ASHRAE oversight committees to no avail, leaving NAHB no other option than to appeal.
Under ANSI requirements, ASHRAE cannot publish the standard until all appeals have been heard and decided by a special ASHRAE panel appointed by its board. A final decision could be made as early as October.
If the current appeals are denied by ASHRAE, NAHB and the other appellants will consider taking their appeals to ANSI, which could require ASHRAE to correct the many flaws in the ventilation standard before it is accredited by ANSI.
If appeals to ASHRAE and ANSI are disapproved, the standard would still need to be referenced by building codes or otherwise adopted by state and local jurisdictions before the requirements could be mandated.
NAHB believes that this will be difficult to do once the problems with the standard become apparent, when and if the standard is considered by code bodies.
For more information e-mail Dick Morris or call him at 800-368-5242 x8444.
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