Arkansas HVACR NewsMagazine January 2020

Published by Arkansas HVACR Association

News Magazine January 2020

Arkansas’ First and Only HVACRNewsMagazine

Do you Have Sick Time Built into Your Pricing? Page 14

Page 7

Page 20

Bryan Orr Lifelong learner, proud technician and advocate for the HVAC/R Trade Talks • Combustion Air • Furnace Temperature Rise • Clocking a Gas Meter Page 44, 46, 50

Page 35


For Arkansans

Table of Contents

Chapter Meeting Schedule

PG 4

Editorial & Opinion Maumelle Fire Station #2 REVISITED

PG 7

Business Do You Have Sick Time Built Into Your Pricing by Bill Kinnard

PG 14

State, national, chapter news ACCA on MCA Free Trade Agreement

PG 17

PG 20

Energy Code : A Review of Provisions that Affect the HVACR Industry

PG 26

Energy Code Amendment Proposal Form The Future of Refrigerants Is Here : Jason Obrzut

PG 32

Education News Training Programs

PG 37

Rebate Programs & Incentives

PG 42

Tech News Bryan Orr : A Trilogy of Important Gas Appliance Training Combustion Air

PG 44

PG 46

Furnace Air Temperature Rise

PG 50

Clocking a Gas Meter

Unique Arkansas Featuring Arkansas Culture

PG 51

Roten’s Furniture in Marshall

Valentine’s Day is Almost Here

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chapter meetings

Central Chapter 4 th Tuesday 6:00 Meal : 6:30 Program Location: Whole Hog 2516 Cantrell Road Little Rock, AR 72202

February 25 March 24 April 28

Fort Smith Chaper 1 st Tuesday

January 7 February 4 March 3

5:30 Meal : 6:00 Program Location : Golden Corral 1801 S. Waldron Road Fort Smith

April 7 May 5

Hot Springs Chapter 1 st Thursday 6:00 Meal : 6:30 Program Location: Smokin’ in Style BBQ 2278 Albert Pike Hot Springs North Central Chapter 4 th Thursday 6:00 Meal : 6:30 Program Location : Western Sizzlin’ 905 Hwy 62 – 65 North Harrison

February 11 March 10 April 14

February 27 March 26 April 23

chapter meetings

North East Chapter 3 rd Tuesday

6:00 Meal : 6:30 Program Location : Western Sizzlin’ 2405 East Highland Jonesboro 870/ 336 - 4417

February 18 March 17 April 21

North West Chapter 2 nd Thursday

6:00 Meal : 6:30 Program Location: Golden Corral 2605 Pleasant Crossing Drive Rogers 479/986-9201 South Central/ Camden 1 st Thursday 6:00 Meal : 6:30 Program Location: Ouachita Partners for Economic Development 625 Adams Avenue Camden 870/ 836 - 9354

February 13 March 12 April 9

February 6 March 5 April 2

South West / Texarkana 3 rd Thursday

February 20 March 19 April 16 Call for meeting Location

6:00 Meal : 6:30 Program Location: Rotates between restaurants. Call for a meeting location. 501/487-8655

living conditions.” I will come back to this train of thought in a minute. Let’s now look at the data collected and information revealed since the last article. Much of the following data, some completed by others, was supplied by the engineer. Providing that information was not a breech of privacy as it would have been available via a “freedom of information” request had that been necessary. We greatly appreciate his openness. Three comprehensive reports are included in this article. They were completed by: 1. October 2, 2019: Innovative Solutions Group, Wade Wetzlere, PE 2. November 7, 2019 : Bunny Brown AIA 3. December 3, 2019: Healthy Homes of Louisiana Bobby Parks Items of note and potential problems: 1. Item (#1, #2, #3 investigators) HVAC fans in the on position Potential Problem: System has fresh air intake without outdoor temp or humidity monitoring. When the AC is off but the fan is on, it brings in high humidity without the opportunity for cooling / dehumidification thus raising the humidity level in the conditioned space. Even without fresh air, it The following are items noted in the reports:

Maumelle Firestation # 2 Closed due to

Aspergillus Penicillium

A lot has happened since the original article about the Maumelle Fire Station appeared in the November issue. The station has reopened and homeowners in its service area are assured of the excellent level of service originally offered by the Department and this station. I had an opportunity to exchange emails with the engineer and he was very transparent about inspections into what was wrong with the project and frustrated in that he felt he had been maligned by my first article. Let me first say that I went out of my way not to name names and not to point a finger of blame on any one particular person. To the degree that he did not have authority on final inspections, I can understand his frustration to be included in the previous article’s statement, “poor design and installation of the HVAC system.” I would say that the previous article’s admonition to the HVAC industry applies to everyone involved in the Maumelle Fire Station. That admonition was, “We cannot install systems without regard to the whole of structural and

should also be noted that a fan in the on position can create re-evaporation of moisture on the coil and potential misting. 2. Item (#3 investigator) “One of the first issues noted … was a significant bypass of the HVAC units filtering systems. These bypasses were allowing dust and debre to bypass the filtering systems. Also, the dirtier the filters get, the more particulate would bypass the filter. The metal filler plates actually had a significant amount of filth…” Potential Problem: A poorly installed return air and filter system definitely allows unfiltered air to reach the coil. The result is an increasingly dirty coil. The dirty coil restricts air flow and reduces heat transfer. This is a cycle of increasing bad results. Even though the MFD, Maumelle Fire Department, may have been changing filters when the filters appeared dirty, dirt entering the system through the gaps in the return air was sufficient for HHL, Healthy Homes of Louisiana, to note “a significant amount of filth…” 3. Item (#2 investigator) “ The MFD stated this unit was only in the ON position for a short period of time on the initial evaluation due the coil being frozen and during this investigation due to the HVAC service contractor having shorted the system .” Potential Problem: Even though the MFD noted the unit was only in the “ON” position for a short time, all three investigators

found it in the on position on October 2, November 7, and December 3. So, someone must have been setting it in the “ON” position or it was never turned from “On” to “Auto”. Either way, it is important to recognize why it was in the “On” position in the first place. The MDF stated that the “coil was frozen”. Putting the fan in the “On” position is frequently done to help defrost the coil and keep the system operating when the unit is undercharged or there is restricted air flow and the service tech is a “day away”. So why was the coil frozen? Perhaps, the charge was low, perhaps the filthy coil was reducing air flow and heat transfer. We did not speak with the tech but one thing is sure, it was an HVAC screwup. Now it could be that the unit had a refrigerant leak from the factory or that the installer improperly brazed the copper tubing. In either of these possible scenarios, it is possible that the vacuum was either not performed or improperly performed. 4. Item (#2 investigator) “… humid air is entering through the un-insulated soffit…” Potential Problem: The reference is to the sealed attic. Actually the attic is suppose to be sealed but #2 investigator found areas of air leakage. The result should be the same, an attic that is within the thermal envelope of the structure; which, should also be an attic that is within the air barrier of the structure. Hot humid air was allowed to enter the attic creating the potential for high humidity.

Obviously, this condition was created by failure to properly seal. Perhaps it was a bad day for the installer, a pattern of negligence, or ignorance of the jobs importance. Whatever, it contributed to the overall problem. 5. (#1 & #3 investigator) Conditioned Air Supplied to Attic According to the engineer, “two 4” supply ducts and 6” return ducts in the attic were added per city’s request.” He and Healthy Homes’, Bobby Park, recommended that the attic supply and return air be sealed / closed. Bobby Park said, “…supply air vents…should NOT be supplying conditioned air to the attic space.” Potential Problem: With a system being supplied “fresh”, hot, humid air and the fan in the on position, investigators #1 and #3 are probably right. The system was pumping unconditioned outside air into the attic anytime the unit was not conditioning. In all likelihood, there was insufficient air being supplied to the attic to properly circulate and dehumidify the air had the fan not been in the on position. At a friction rate of 0.1, two 4” supplies would have only provided 78cfm. I don’t have the exact numbers on the volume of the attic so I can’t say unequivocally that 78cfm was insufficient. I can say that this is a large attic. The question could be, “Why did the city request that the supply air be added to the attic?” I can only speculate because the city inspector of record has retired; but, let me

interject. That inspector has a reputation of being tough; meaning, he wanted the jobs to be done right. I have no doubt that he thought he was doing the right thing---especially since the Health Department at the time was recommending that this be a potential solution to high humidity in encapsulated attics. By way of totally transparency, I included that method as a potential methodology in the January 2019 issue of the NewsMagazine. Also, let me note that in an industry meeting, Healthy Homes personnel said the introduction of conditioned air in an encapsulated space was not necessary but also interjected that it would be OK. It should also be noted that the conversation was regarding residential applications and there was no thought of fresh air being introduced into the system or that the encapsulated attic would not be perfectly sealed thus allowing hot, humid air to enter. Also, there was no thought of the fan being in the “on” position. 6. (#1, #2, and #3 investigators) Duct was not properly sealed. All three investigators found the duct to be improperly sealed and recommended “all the insulation gaps be corrected and taped secure.” Potential Problem: It was stated and pictures provided in the first article that the duct was not properly sealed and this was reiterated by all three investigators referenced in this article. Here there is no question as to who was at fault. The duct installers sealed some

joints and left the rest unsealed. Why? Who knows. There is no excuse. So why did the inspector not catch it. Well, again I say that this inspector has an excellent reputation of ensuring that the HVAC installer follow code. The problem is, “How do inspectors ensure the ductwork is sealed with mastic or mastic tape according to code?” It is a balancing act between the absolute and the pragmatic. The only sure way to know if the entirety of the duct is properly sealed is to require an inspection prior to the installation of the insulation. This is cost prohibitive and not pragmatic. Inspectors frequently allow installation of the insulation and cut back in some areas to reveal the mastic. So, if the installers are lucky, they might not get caught. At this point, I am sure that the owner of the duct installation company does not think he was lucky. He got caught after the fact and that is the most expensive time. Another way to check for properly sealed duct is to require a “duct blaster” test. Fayetteville and Little Rock have led the way. In September 2018, Little Rock began requiring all duct in new residential construction be duct blaster tested. Even so, it is possible, though remote, that a duct system could pass the test but not be completely sealed with mastic or mastic tape. This is an area where the industry and inspection authorities need to confer, come up with a near fail-safe method, and then both sides support its

implementation. We can say unequivocally, duct installation on residential and small commercial applications has not had the respect or been given the importance that the building owner and homeowner deserves. 7. (#1, #2, and #3 investigators) Insulation on refrigerant lines was inadequate. “The insulation looked damaged and partially missing in places.” This was referring to the mini-split. Potential Problem: Refrigerant line insulation frequently gets damaged or the last inch or so gets left undone. Small? While it doesn’t look like much, cold pipes exposed to high humidity will condense and the moisture will drip or travel downhill. A small gap creating condensation can cause significant damage. This isn’t rocket science. It has to be properly insulated. This isn’t necessarily the matter of an unethical contractor. It may well be that the contractor or their employees don’t realize how important their job is. Even the little things matter. Even though there are other items to discuss; i.e., dampers that don’t close and so called appropriate levels of Aspergillus Penicillium, this article has already gone on too long. I know you agree. I don’t know how we get from where we are to where we need to be in the HVACR and construction industry. Perhaps I should not have OK! Enough! Enough!

grouped us all together in the last article. Perhaps I should not have said, “Maumelle fire house #2 is only three years old and suffers from the effects of poor design and installation of the HVAC system.” Perhaps it was designed perfectly and then redesigned to meet budget considerations. Perhaps I should not have included the city inspector. Perhaps I should not have referenced the Health Department. Perhaps I should not have implied that the HVACR industry needs continuing education which implies that we don’t know everything. Oh, let me be very sarcastic. Perhaps this whole thing is the fault of the Maumelle Fire Chief because he cared enough about his men and women to investigate the presence of mold and their reported health concerns. Maybe he overreacted and it is all his fault. Let’s forget that building owners and homeowners know very little about construction and ventilation and HVAC. Let’s blame the consumer when they want us to redesign to bring things into their budget. After all, you get what you pay for. (I have heard legislators openly proclaim, “Let the consumer beware.”) Yes, let’s point the finger of blame squarely where it belongs—the City of Maumelle. Please, don’t take this out of context or from the sarcastic spirit with which it was regurgitated. So what am I saying? I am saying that while we can find companies and

people to blame and perhaps absolve ourselves from responsibility, let’s look to a future where we do the following: 1. The Arkansas construction industry needs to have a consortium consisting of all the trades working together to vet code, practices, and complications we see in the field. We need an opportunity to see problems and opportunities from the other persons viewpoint. This does not need to be mandated but rather an informal group or non-profit dedicated to providing the best quality construction to our fellow Arkansans. We need to be proactive. 2. The HVACR industry needs a better training program for persons wanting to enter the trade; i.e., apprenticeship. 3. Arkansas needs a better method of licensing persons entering the HVACR industry; i.e., requiring an apprenticeship. 4. Arkansas needs to require continuing education for HVACR licensees. 5. Every trade needs to become a, “consultant rather than an equipment seller and installer.” We need to have the courage to say to the builder, building owner, and homeowner, “We will not redesign to a point that the system will not work with efficacy, efficiency, or safety.” Let me close by saying to all involved in the Maumelle Fire Station. It was not my intent to malign anyone. It was my intent to say, “Let’s work together. Let’s make sure this doesn’t happen again”


hours. Let’s look at the impact of this on your pricing.

Do you Have Sick Time Built into Your Pricing?

If you have five techs in the field and each is out sick 3 days throughout the year, that’s 15 days that you

won’t bill out. When they are there, not all of their time is billable. On average, your service techs will bill out about 50% of their time and installers will bill out about 30% of their time. If you’re not watching it, the problem is worse. For our example,

As I rarely ever get sick!

In my 35-year career, I can count the number of days I have been out sick on one hand. Last week however, I had to add one to that total. As

the owner of a growing company I struggle to leave the office but I knew it was the best thing to do. I really wasn’t being productive and I certainly didn’t want to get my team sick.

we will say these 5 team members are a mix of service and install. We will use an average of 35% non-billable. When we do that math, 15 days X 8 hours per

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day X 65% billable for a total of 78 billable hours that you won’t bill out.

As I was driving home, I started thinking about the conversation I have with business owner’s day in and day out. They tell me “I don’t get sick” so “I don’t need sick days.” Rare as it may be, the reality is there are going to be days that you just can’t make it in or your team can’t make it in. If we don’t account for this, even occasional absences can impact profitability. The rate you bill per hour is based on the number of hours that you think you are going to bill out this year. If you don’t have sick time for you and your team built into your pricing, it can be very costly. Sure, you don’t have to pay them their wages but that’s not the biggest part of the calculation. You also can’t bill out those

As we indicated earlier, it’s more than just the wages that you didn’t have to pay. It’s the hours you won’t bill out. You also need to take into account revenue per billable hour. This is all revenue brought in compared to all hours billed out. The average company, whether two team members or 200, will have a revenue per billable hour between $125 and $175 per hour. If we average this out at $150 per hour, then the math is $150 per hour X 78 hours we won’t bill out for a total of $11,700. That means $11,700 will not be available to help offset overhead expenses. For a recent company I worked with, this meant a one full


percentage point reduction in net profit of the company at the end of the year.

Let’s take that one step farther and do the math with our whole team averaging 35% non-billable. 5 techs X 8 hours per day X 65% billable time per day X 240 working days per

Even a duck can be under the weather

year is a total of 6,240 billable hours. Now we have to subtract those 78 sick hours from this total. That means we will really only have 6,162 billable hours. If you spread that lost revenue of $11,700 across these remaining billable hours, you would have to increase your labor rate by $1.90 / hour to make up the difference. Make sure you are calculating your hourly rate correctly. Your team is going to get sick. You are going to get sick. Not looking at this realistically can cost you thousands per year and mean the difference between profitability and losing money.

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trade agreements, including with China, that could remove more tariffs that impact the HVACR industry.” For more information about ACCA, please contact Deb Weiner, ACCA Manager of Communications at or 703-824-8862.

ACCA Statement on U.S., Mexico, Canada Free-Trade Agreement Arlington, VA (December 11, 2019) The Air Conditioning Contractors of America (ACCA) released the following statement from ACCA President and CEO Barton James on the bipartisan U.S., Mexico, Canada free trade agreement (USMCA): “ACCA is pleased that the President and Congress have reached a bipartisan deal on the USMCA. Tariffs on products and materials from Mexico and Canada have contributed to price increases as high as 20 percent on HVACR products. ACCA supports trade agreements that ensure the HVACR industry is not subject to tariffs. This agreement is long overdue and ACCA appreciates President Trump’s leadership that brought our trading partners to the table and pushed Congress to take action. ACCA hopes this agreement paves the way for more bipartisan legislation in Congress, including tax extenders, infrastructure funding, and passage of federal legislation to ensure a unified HFC refrigerant phasedown schedule. ACCA also hopes that the USMCA leads to

ACCA is a non-profit association serving more than 60,000 professionals and 4,000 businesses in the indoor environment and energy services community. Our member firms are the nation's most professional contracting businesses, serving residential and commercial customers in every state. With roots stretching back a century, ACCA was incorporated in its present form nearly 50 years ago. Today, ACCA sets the standards for quality comfort systems, provides leading- edge education for contractors and their employees, and fights for the interests of professional contractors throughout the nation. Learn more about ACCA here. Air Conditioning Contractors of America Association, Inc. 2800 Shirlington Rd, Suite 300 Arlington, VA 22206 (703) 575-4477

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amendment form follows this article or can be found on the Landing Page or at this link, Arkansas Amendment Form.doc Blower Door Testing Whole house blower door testing will be required. A third party tester is an option and will be determined by the code official. A city or code authority would make that decision via local ordinance. Of course, this is also something the State could mandate as part of the adoption process. A whole house blower door requirement puts the HVAC person in a position of having their work tested at final. Not a problem if the duct was tested at rough-in and passed unless someone damaged the duct during the finishing process. Every contractor would appreciate the opportunity to repair a problem; however, when between floors, it can be very expensive. The question is, who pays for the repair if the duct passed at rough-in and failed at final? Was the rough-in duct test flawed or was the duct damaged between rough-in and final? R402.4.1.2 Testing. The building or dwelling unit shall be tested and verified as having an air leakage rate not exceeding five air changes per hour in Climate Zones 1 and 2, and three air changes per hour in Climate Zones 3 through 8. Testing shall be conducted in accordance with RESNET/ICC 380 , ASTM E 779 or ASTM E 1827 and reported at a pressure of 0.2 inch w.g. (50 Pascals). Where required by the code official , testing shall be conducted by an approved third party. …

Energy Code ICC 2018 Possible Changes to Arkansas Code The Arkansas Energy Office is conducting open meetings and inviting persons that have signed up as “Stake Holders”. Any person wanting to be involved can be placed on a contact list. Contact Tim Quetsch, Energy Office at The next “Stake Holder” meeting is January 29 th from 9:00 to 11:00 a.m., 5301 Northshore Drive, North Little Rock, Arkansas Commission Room. The following is a partial list of issues that will affect the residential HVAC industry. Persons having an interest in the International Energy Code should purchase a copy from ICC. The link to the IECC is conservation-coder.html The Arkansas Energy Office has also made the 2009 as well as the 2018 available at their landing page, ilding.aspx Readers should also note that the 2018 IECC, International Energy Conservation Code, may be adopted in total or with amendments. If there are specific items that you want modified or eliminated, you should attend the meetings and make your opinion known. You can also send email or letters to Tim Quetsch, Arkansas Energy Office, 5301 Northshore Drive North Little Rock 72113. A copy of the

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Programmable Thermostat Required This section probably does not change much as virtually all new construction is already using some version of a programmable thermostat. IECC Code Provision R403.1.1 Programmable thermostat. The thermostat controlling the primary heating or cooling system of the dwelling unit shall be capable of controlling the heating and cooling system on a daily schedule to maintain different temperature setpoints at different times of the day.

R-8 Duct Insulation The 2018 IECC would require R-8 duct insulation on all duct >=3” in diameter and located in the attic. This was a defining issue in 2015 but due to condensation problems, many have already moved toward R-8. insulated to an R -value of not less than R-8 for ducts 3 inches (76 mm) in diameter and larger and not less than R-6 for ducts smaller than 3 inches (76 mm) in diameter. Supply and return ducts in other portions of the building shall be insulated to not less than R-6 for ducts 3 inches (76 mm) in diameter and not less than R-4.2 for ducts smaller than 3 inches (76 mm) in diameter. Sealed Air Handler Every installer knows how much air leaks through the air handler. The IECC will reduce the allowable amount to 2% of the total design airflow rate. A 3 ton unit @ 400 cfm/ton could then leak 24cfm or about the same amount as a 3.4” round pipe at a friction of 0.1. As you can see, this isn’t an egregious requirement for the manufacturers. In fact, one could say, “Where is the improvement?” R403.3.1 Insulation (Prescriptive). Supply and return ducts in attics shall be IECC Code Provision R403.3.2.1 Sealed air handler. Air handlers shall have a manufacturer’s designation for an air leakage of not greater than 2 percent of the design airflow rate when tested in accordance with ASHRAE 193 .

HP Supplementary Heat Control This was a big issue in 2014. Now most HP thermostats have it built in.

IECC Code Provision R403.1.2 Heat pump supplementary heat (Mandatory).

Duct Sealing 20 18 IECC references the International Mechanical Code which the HVACR Program is presently preparing to update. Interested persons should contact the Arkansas Department of Labor and Licensing at 501-682-9188. Heat pumps having supplementary electric-resistance heat shall have controls that, except during defrost, prevent supplemental heat operation when the heat pump compressor can meet the heating load. R403.3.2 Sealing (Mandatory). Ducts, air handlers and filter boxes shall be sealed. Joints and seams shall comply with either the International Mechanical Code or International Residential Code , as applicable.

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Duct Testing / Duct Blaster Test

training. The Association was approved and provided training to over 100 trainees. Other recognized providers are RESNET and BPI. The 2018 IECC does not require third party testing but that is an option available to the state as well as cities and code authorities. HVAC companies must attend and participate in these “Stakeholder” meetings as well as their city council meetings if they want the option of self- certification. It should be noted that there are advantages for both self-certification as well as third party. Allowable Duct Leakage The allowable duct leakage is reduced in the 2018 IECC. One could argue that if the duct is installed with mastic or mastic tape according to code, why would it leak? Also, while the code R403.3.4 Duct leakage (Prescriptive). The total leakage of the ducts, where measured in accordance with Section R403.3.3 , shall be as follows: 1.Rough-in test: The total leakage shall be less than or equal to 4 cubic feet per minute (113.3 L/min) per 100 square feet (9.29 m 2 ) of conditioned floor area where the air handler is installed at the time of the test. Where the air handler is not installed at the time of the test, the total leakage shall be less than or equal to 3 cubic feet per minute (85 L/min) per 100 square feet (9.29 m 2 ) of conditioned floor area. 2.Postconstruction test: Total leakage shall be less than or equal to 4 cubic feet per minute (113.3 L/min) per 100 square feet (9.29 m 2 ) of conditioned floor area.

Duct Testing has been on the horizon for over a year even in areas where blower door whole housing testing was not required. Little Rock began requiring duct testing September, 2018. Fortunately, they allowed self- certification as long as the person testing had completed a recognized A written report of the results of the test shall be signed by the party conducting the test and provided to the code official . R403.3.3 Duct testing (Mandatory). Ducts shall be pressure tested to determine air leakage by one of the following methods: 1.Rough-in test: Total leakage shall be measured with a pressure differential of 0.1 inch w.g. (25 Pa) across the system, including the manufacturer’s air handler enclosure if installed at the time of the test. Registers shall be taped or otherwise sealed during the test. 2.Postconstruction test: Total leakage shall be measured with a pressure differential of 0.1 inch w.g. (25 Pa) across the entire system, including the manufacturer’s air handler enclosure. Registers shall be taped or otherwise sealed during the test. Exceptions: 1.A duct air-leakage test shall not be required where the ducts and air handlers are located entirely within the building thermal envelope . 2.A duct air-leakage test shall not be required for ducts serving heat or energy recovery ventilators that are not integrated with ducts serving heating or cooling systems.

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provides a rough in or at final test option, there is a big question as to which the HVAC dealer should select. If my numbers are right, there is a penalty for running the test when the air handler is in place due to the code allowing 2% leakage for the air handler. Check it out and tell me what you find. Building Cavities Though a common practice in the past, this does not represent a change to what we have been doing since 2015. Duct Buried in Insulation For almost two decades, some have championed ducts in attics being suspended. That was the plan for the Arkansas 2014 code but the Energy Office allowed ducts to be on or between ceiling joists as an additional option. The option to “lay” or suspend was a result of the Association providing data that proved there would be less loss or gain in the duct if it were on the ceiling with attic insulation surrounding it. The 2018 IECC minimum insulation is a function of meeting the insulation requirement of the conditioned space. Of course the duct is still required to have a minimum of R-8 per 403.3.1 and meet the vapor barrier standard. R403.3.5 Building cavities (Mandatory). Building framing cavities shall not be used as ducts or plenums.

R403.3.6 Ducts buried within ceiling insulation.

Pipe Insulation Refrigerant as well as condensate lines must have R-3 or greater. R403.4 Mechanical system piping insulation (Mandatory). Mechanical system piping capable of carrying fluids greater than 105°F (41°C) or less than 55°F (13°C) shall be insulated to an R -value of not less than R-3. Where supply and return air ducts are partially or completely buried in ceiling insulation, such ducts shall comply with all of the following: 1.The supply and return ducts shall have an insulation R -value not less than R-8. 2.At all points along each duct, the sum of the ceiling insulation R -value against and above the top of the duct, and against and below the bottom of the duct, shall be not less than R-19, excluding the R -value of the duct insulation. 3.In Climate Zones 1A, 2A and 3A, the supply ducts shall be completely buried within ceiling insulation, insulated to an R -value of not less than R-13 and in compliance with the vapor retarder requirements of Section 604.11 of the International Mechanical Code or Section M1601.4.6 of the International Residential Code , as applicable. Exception: Sections of the supply duct that are less than 3 feet (914 mm) from the supply outlet shall not be required to comply with these requirements.

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Pipe Insulation Protection Everyone has seen exposed insulated refrigerant lines run up the outside of a wall into the attic to the evaporator. 403.4.1 would now require that they be protected from weather. I am not sure how it applies to lines in the attic that are exposed to sunlight via “whirly birds”. We know how the sun destroyed vinyl backed duct insulation in the past so it will be interesting to see how code authorities interpret this issue. R403.4.1 Protection of piping insulation. Piping insulation exposed to weather shall be protected from damage, including that caused by sunlight, moisture, equipment maintenance and wind. The protection shall provide shielding from solar radiation that can cause degradation of the material. Adhesive tape shall be prohibited. Ducts in Conditioned Space Having read this section many times, I am not sure how it has any substantive benefit or harm to our industry. It provides a definition of conditioned space but it doesn’t appear to provide much if any options to the designer.

Mechanical Ventilation Mechanical ventilation has become a huge part of our industry’s concern. The IECC references the Mechanical Code and it is recommended that questions be addressed to Mechanical Code Inspectors. 2.3.The ceiling insulation R -value installed against and above the insulated duct is greater than or equal to the proposed ceiling insulation R -value, less the R -value of the insulation on the duct. R403.3.7 Ducts located in conditioned space. For ducts to be considered as inside a conditioned space, such ducts shall comply with either of the following: 1.The duct system shall be located completely within the continuous air barrier and within the building thermal envelope. 2.The ducts shall be buried within ceiling insulation in accordance with Section R403.3.6 and all of the following conditions shall exist: 2.1.The air handler is located completely within the continuous air barrier and within the building thermal envelope. 2.2.The duct leakage, as measured either by a rough-in test of the ducts or a post- construction total system leakage test to outside the building thermal envelope in accordance with Section R403.3.4 , is less than or equal to 1.5 cubic feet per minute (42.5 L/min) per 100 square feet (9.29 m 2 ) of conditioned floor area served by the duct system.

Code Protects the Consumer Provides a Level Playing Field

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Equipment Sizing 2018 IECC requires systems to be sized by Manual J load calculation and S equipment sizing. Manual S will take us to a better understanding of equipment matching and Sensible Heat Ratio. R403.7 Equipment sizing and efficiency rating (Mandatory). Heating and cooling equipment shall be sized in accordance with ACCA Manual S based on building loads calculated in accordance with ACCA Manual J or other approved heating and cooling calculation methodologies. New or replacement heating and cooling The intricacies of each of these codes varies from simple to a bit more complicated; THEREFORE, it is imperative that each person take advantage of the “Stakeholder” meetings. If attending is impossible, one should submit their opinions to the Arkansas Energy Office. You can mail or email. It would be best to use the following Arkansas Amendment Form.doc equipment shall have an efficiency rating equal to or greater than the minimum required by federal law for the geographic location where the equipment is installed.

Whole-house Mechanical Ventilation Whole house ventilation has become the responsibility of the HVAC contractor. It is an area that we are struggling to comply with. There is significant debate and many have defaulted to Energy Recovery Ventilation systems. Of course, that is an expensive add on. When ventilation systems use the furnace or air handler blower to move air, the blower must be an ECM. If the ventilation system has its own blower it must comply with code efficiency standards. R403.6 Mechanical ventilation (Mandatory). The building shall be provided with ventilation that complies with the requirements of the International Residential Code or International Mechanical Code , as applicable, or with other approved means of ventilation. Outdoor air intakes and exhausts shall have automatic or gravity dampers that close when the ventilation system is not operating. R403.6.1 Whole-house mechanical ventilation system fan efficacy. Fans used to provide whole-house mechanical ventilation shall meet the efficacy requirements of Table R403.6.1 . Exception: Where an air handler that is integral to tested and listed HVAC equipment is used to provide whole-house mechanical ventilation, the air handler shall be powered by an electronically commutated motor.

Just click on the blue link above, compete the form, and submit to

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ENERGY CODE AMENDMENT PROPOSAL FORM Send completed forms to or to ARKANSAS ENERGY OFFICE ATTN: Tim Quetsch 5301 Northshore Drive North Little Rock, AR 72118-5317 NAME: DATE: ORGANIZATION/POSITION: EMAIL: TELEPHONE: ADDRESS: CODE: 2018 International Energy Conservation Code CHECK ONE: Revise section to read as follows: Add new section to read as follows: Delete section and substitute the following: Delete without substitution: LINE THROUGH MATERIAL TO BE DELETED: UNDERLINE MATERIAL TO BE ADDED

SECTION: DESCRIPTION: Additional Attached Pages



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ENERGY CODE AMENDMENT PROPOSAL FORM Send completed forms to or to ARKANSAS ENERGY OFFICE ATTN: Tim Quetsch 5301 Northshore Drive North Little Rock, AR 72118-5317 NAME: Tim Quetsch DATE: 11/20/2019 ORGANIZATION/POSITION: Arkansas Energy Office-Engineer EMAIL: TELEPHONE: 501-548-4651 ADDRESS: 4170 M.L.K. Jr. Blvd #5, Fayetteville, AR 72704 CODE: 2018 International Energy Conservation Code CHECK ONE: Revise section to read as follows: Add new section to read as follows: Delete section and substitute the following: Delete without substitution: LINE THROUGH MATERIAL TO BE DELETED: UNDERLINE MATERIAL TO BE ADDED

SECTION: R101.1 DESCRIPTION: Additional Attached Pages

R101.1 Title. This code shall be known as the Energy Conservation Code of [NAME OF JURISDICTION] Arkansas Energy Code for New Building Construction and shall be cited as such. It is referred to herein as "this Code" or "the Arkansas Energy Code."

REASON/INTENT/REFERENCED STANDARDS: Administrative edit to match the title referenced elsewhere in Arkansas state law.


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REFRIGERANT PHASEOUT R- 22 ( a hydrochlorofluorocarbon; HCFC) is still being phased out under the Montreal Protocol Treaty, but efforts are already underway to phase out hydrofluorocarbon (HFC) refrigerants, like R 410 A. R- 22 was phased out because it is an ozone depleting substance. R 410 A is going to be phased out because it has a high global warming potential (GWP).

NATIONAL EFFORTS The HVACR Industry, including the national contractor association – the Air Conditioning Contractors of America – are seeking a national phaseout schedule instead of a state- by-state approach. These efforts are being addressed with Members of Congress; who must give the EPA clear authority to address the phase-down schedules. Currently, the EPA does not believe it has the authority to regulate refrigerants that have high global warming potentials because Section 608 of the Clean Air Act is for ozone depleting substances. This could lead to the open-sale of refrigerants to consumers.

STATE EFFORTS Without a federal mandate, many states will implement their own phase-down schedules; creating a patchwork of refrigerant regulations and different types of refrigerants available in each state. California has already adopted a phaseout schedule, and New York, Washington, Maryland, Illinois, and a number of other states are following suit, but they have different schedules.

CONTRACTOR CONCERNS The replacements to HFCs will likely include a mix of flammable and mildly flammable refrigerants (designated as A 3 / A 2 / and A 2 L by ASHRAE Standard 34 ), and ACCA is working to address a number of concerns, including: Will contractors/technicians be required to have HAZMAT certifications to transport these products and will they be required to stop at rail crossings? How will we guarantee that contractors and technicians are trained on the safe use and handling of flammable refrigerants? How will consumers be certain that their system was properly charged and not compromised with mixed refrigerants?

ACCA EFFORTS ACCA has begun the development of a flammable refrigerant educational program to address the training concerns. There are still too many unanswered questions about the use of the next generation of refrigerants; how they are to be safely applied in the field, what sensors/controls may be required, maximum quantities of refrigerant that may be used in a conditioned space, etc. A hasty state-by-state approach to phasing out HFC refrigerants is dangerous for contractors, technicians, consumers, and every building that contains an air conditioning system. By giving the EPA the authority to implement the HFC phaseout, there is more certainty that there will be uniformity in the phase-out schedules, training, transportation issues, the codes process, and the other areas of concern to the HVACR industry.

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There are some organizations that are using this phaseout as a sales tactic to force customers to purchase new equipment. They are telling their customers that once the total phase-out takes effect, system parts, including compressors and refrigerant, will no longer be available. The truth of the matter is that is perfectly legal to service, repair, or charge R-22 equipment after January 1, 2020. According to manufacturers, there is a stockpile of virgin R-22 that can meet the demands of the industry for at least 5 years. There is a steady supply of reclaimed R-22 that can meet system needs for at least another decade. Also, there are a number of R-22 alternative/replacement refrigerants that can be safely and effectively charged into existing R-22 equipment. There is no need for panic, but plans should be made for the future replacement of these systems. R-410A, an HFC refrigerant blend, has been successfully used as the next- generation refrigerant in newly installed comfort cooling equipment. When it was released, there was considerable push back from some in the industry. “Those pressures are too high!”, “I am not going back to school to learn how to work with a new refrigerant!”, “What do you mean charge as a liquid?!” Shortly after the R- 410A rollout, students, technicians, and contractors alike took the necessary educational steps to understand and safely handle and work with R-410A. Those who took classes and received training before the R-410A release had a much smoother transition to the new refrigerant. The scouts’ motto “Be

The Future of Refrigerants is Here Heating and cooling are parts of our everyday lives and are essential to our comfort. Many HVACR professionals have been lulled into a false sense of security since, up until the early 1990s, our industry has undergone very few regulatory and oversight changes. The Montreal Protocol was seen as a major jolt to our “status quo” mentality. Since the Montreal Protocol, there has been a flurry of new regulations as well as changes to existing guidelines, processes and procedures aimed at creating more energy-efficient equipment that is less harmful to our environment and its occupants. R-22, for example, which has been used reliably in comfort cooling equipment for generations, is an ozone depleting substance (ODS) and, as a result of regulatory changes, its production and importation will be terminated as of January 1, 2020.

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