Duct Tightness Testing Commentary

After Reviewing the proposed changes to Section N1103.3.3 (R403.3.3) I have the following comments:

It appears that all references to duct tightness testing limits have been redacted out of the text, and there have not been any added testing limits suggested to be placed into the code. There should be a testing threshold added in to the code to ensure energy efficiency at some level.  As an national average, existing homes can lose as much as 20 percent of each energy dollar due to duct leakage.  For the code testing to have any impact on energy efficiency, reasonable thresholds must be placed in the code for compliance. 

Most states that adopt a similar code require some type of certification and training to ensure that the person engaged in testing is qualified to perform such types of testing.  I would suggest making it a requirement that any person performing duct tightness testing should be accredited by a nationally recognized agency, such as RESNET or BPI.  This will ensure consistency and accuracy in the code testing findings, and a level of assurance that the testing is being performed by a professional.

Lastly, I would add that the testing agent should be a third party, and not have any involvement in the financial success of the building the tester is testing.  This will also ensure accurate and fair testing for all parties concerned.