Monday, April 21, 2014

Insulation Guideline Update - Interim Review of Analysis

Posted by Webmaster on 26. October 2007 11:00

Memo to Insulation Fact Sheet StakeholdersPDF, Oct. 2007
Download Adobe Acrobat.

Posted By: Tech Admin from Technologists Inc.

October 26, 2007 11:00 AM

Dear Stakeholders, DOE through its Oak Ridge National Laboratory will be conducting a new analysis regarding the recommended residential insulation levels. Please see the attached ORNL letter that requests your comments regarding cost data. Please post your comments below so that all stakeholders can see your thoughts and can respond if desired. Comments are due by November 21, 2007. Also, for your reference you may look at the previous round of comments below. Thank You. Marc LaFrance, US DOE Technology Development Manager, 202-586-9142


Replied By: from

November 21, 2007

Therese Stovall
Senior Research Engineer
Oak Ridge National Laboratories
Bethel Valley Rd.
PO Box 2008
Oak Ridge, TN 37831

Subject: Owens Corning Comments on DOE Insulation Level Recommendations

Dear Ms. Stovall:

Thank you for the opportunity to comment on the Interim Review of DOE Insulation Level Recommendation memorandum of October 23, 2007. The North American Insulation Manufacturers Association (NAIMA) has submitted comments on behalf of our industry in response to your request for stakeholder review of the update to the DOE R-value recommendations.

Our comments today briefly address:

1. Do the stakeholders agree that the installed insulation costs used are reasonable? If not, please provide supportable alternate suggestions.

We have compared the proposed ORNL insulation cost data to three publicly available sources of construction cost data: R.S. Means 2007, the BNi Building News 2008 Cost Book and the ASHRAE Standard 90.2 insulation cost data from 2003. We see some instances where ORNL s installed costs for glass fiber insulation are unexpectedly below those of the other sources. Underestimated insulation costs could affect the overall credibility of the DOE recommendations. We recommend that ORNL recheck the estimated costs for reasonableness and consistency and consider using the Std. 90.2 data adjusted to today as they were developed for similar use as DOE will be using this data.

Please contact me for follow-up as needed.

Sincerely

Merle McBride
Phone: 740-321-7083


Replied By:

30 - Nov - 2007 6:06 PM

Changes to Insulation Fact Sheet

Before You Insulate
Around the chimney: pack gaps around an insulated chimney with UNFACED rock wool or UNFACED fiberglass insulation
All chimneys and flues have a code specified air space required around them. The combustibility of the insulation is not necessarily the concern here as much as is heat build up. The insulation can trap heat in and cause the pipe to fail or conduct enough energy to ignite materials in contact with the insulation. In the example of the chimney; metal flashing and non combustible (ASTM E-136) fire caulk are what is recommended for draft stopping.

The rest of the ideas are simply to put the different types of insulation into balance (from my perspective of course!)

Thank you,

Robert De Vries
Technical Services
NU-WOOL CO INC.
1-800-748-0128

Attached Document...

Suggested Changes to the DOE Insulation Fact Sheet

Table 1. Types of Insulation-Basic Forms
Loose-Fill, Advantages: Good for standard stud and joist spaces as well as irregularly shaped areas and around obstructions.
This clarifies it is suitable for all construction not just unique situations.

Description of cellulose on page four after Table 1. Most cellulose is in the form of small flat pieces rather than fibers.  In general it is not a fair description of today’s cellulose product.

Table 2. R-Values
Most of the cellulose products on the market today have an R-value of 3.65-3.8 or an average of 3.72

Before You Insulate
Around the chimney: pack gaps around an insulated chimney with UNFACED rock wool or UNFACED fiberglass insulation.  All chimneys and flues have a code specified air space required around them.  The combustibility of the insulation  is not necessarily the concern here as much as is heat build up.  The insulation can trap heat in and cause the pipe to fail or conduct enough energy to ignite materials in contact with the insulation.  In the example of the chimney metal flashing and non combustible (ASTM E-136) fire caulk are what is recommended for draft stopping.

DO NOT USE ANY COMBUSTIBLE PRODUCTS SUCH AS CELLULOSE INSULATION OR PLASTIC FOAMS, HERE.  While cellulose doesn’t fit the definition of non combustible I feel referring to it as combustible in this instance is miss leading.  In act cellulose is used in dozens of firewalls increasing there fire resistance.

If the areas are more difficult to reach, you can greatly reduce the air leakage by blowing high-density cellulose insulation or injecting plastic foam insulation into these joints, thus reducing these energy-gobbling air paths.

Make Your Selection
It is important to know that different forms of insulation can be used together.  For example, you can add unfaced batt or roll insulation over loose-fill insulation…
I find the next few sentences confusing in that first we are told not to use a higher density insulation over low density then it goes on to say in some climates it is an effective practice to eliminate convective loops.  This may be a good place to give examples of higher density insulation since density has only been mentioned so far.

Can You Do It Yourself?
Placing insulation in the attic floor is usually easy, requiring only laying or blowing the material between the parallel joists of the frame.

The homeowner can often insulate basement or crawlspace walls, or floors over unheated areas, using rigid insulation, batt insulation or blown in cellulose.

If You Do It Yourself
The codes on vapor retarders has changed significantly.  You may want to defer to the IECC 2006 supplement for these changes.


Replied By: from

30 - Nov - 2007 6:24 PM

NAIMA Comments on DOE Insulation Level Recommendat

The comments in the attached document below is submitted on behalf of the North American Insulation Manufacturers Association (NAIMA) in response to the request for stakeholder review of the update to the Department of Energy (DOE) R-value recommendations.

On behalf of,
Charles C. Cottrell,
Vice President, Technical Services

Attached Document...

November 7, 2007

Therese Stovall
Senior Research Engineer
Oak Ridge National Laboratories
Bethel Valley Rd.
PO Box 2008
Oak Ridge, TN 37831

Subject: NAIMA Comments on DOE Insulation Level Recommendations

Dear Ms. Stovall:

These comments are submitted on behalf of the North American Insulation Manufacturers Association (NAIMA) in response to your request for stakeholder review of the update to the Department of Energy (DOE) R-value recommendations. NAIMA is the association for North American manufacturers of fiber glass, rock wool, and slag wool insulation products. Its role is to promote energy efficiency and environmental preservation through the use of fiber glass, rock wool, and slag wool insulation, and to encourage the safe production and use of these materials.

The three factors you requested input on are as follows:

1. Do the stakeholders agree that the installed insulation costs used are reasonable? If not,
please provide supportable alternate suggestions.

NAIMA’s anti-trust policy restricts the Association from discussing price information on products its members manufacture. Also, because the manufacturers only supply the materials, NAIMA members have limited knowledge of the total installed cost of insulation. NAIMA has requested its members to provide separate comments on whether they consider the prices you have proposed are reasonable and accurate, insofar as they are able. Price information will not be discussed amongst NAIMA members.

Current and accurate cost data for insulation is not available from any source that NAIMA is aware of. Therefore, NAIMA recommends the DOE conduct a comprehensive survey of home builders and insulation contractors to determine the installed cost of commonly used insulation materials. cost information would be valuable to all parties involved in determining what levels of insulation are appropriate and justified in homes. NAIMA also recommends that the Department establish a methodology for gathering insulation cost data and conduct such a survey at regular intervals. DOE should consult the Department of Justice guidelines on collecting price information. Considering the time intervals when energy codes are updated and the rapidly increasing cost of energy, we recommend the Department conduct such a survey every 2 or 3 years.

ORNL should be aware that the DOE has agreed to fund a consultant (through PNNL) to go gather insulation product/system prices for use in updating the ASHRAE 90.1 energy standard for commercial buildings. And the ASHRAE 90.2 Committee has a formal ASHRAE project currently out for bids to determine residential insulation product/system prices. NAIMA recommends that ORNL consider using this data if the timetable is appropriate.

If the Department does not conduct a comprehensive survey, NAIMA would support the “1996 Fact Sheet Updated to 2007” values contained in your letter and agrees with the justification for those values. Also, from my personal experience in construction, I have found RS Means data tends to be considerably higher than what is found in the market and recommend judicious use of it as a source for cost data. It is important that the costs be realistic and fair so that DOE’s recommendations have strong credibility.

NAIMA strongly supports the Department’s plans to use the “least cost option” for determining optimal life-cycle savings. There are numerous insulation options available to achieve all the given R-value levels. These options can vary tremendously in cost and if a consumer decides to choose a more costly option, for whatever reason, that is their prerogative.

Regarding the issue of fuel prices, NAIMA recommends using higher fuel escalation rates than what the Energy Information Agency (EIA) uses. Historically the EIA projections have underestimated the actual escalation rates for fuel costs and this has had the negative affect of undervaluing all energy efficiency measures – including insulation. Given that predicting future energy costs is a difficult task, NAIMA believes that it is better to overestimate the future cost of fuel, rather than underestimate it, because more energy will be conserved than if the fuel cost is underestimated.

Please note that one of the most common R-values for wall cavity insulation, R-13, was not included in the list of cavity insulation options in Table 1 and R-11 is not commonly used in any attics.

2. Are all the insulation options shown in the cost table available on a national basis?

NAIMA members manufacture all of the fiber glass batt and loose-fill options shown in the tables and market them throughout the United States. The other materials listed are readily available to the best of our knowledge.

3. Provide feedback regarding possible result presentation options, e.g.: list all results that
produce similar life-cycle savings, list the R-value that maximizes energy savings, list the R-value that maximizes economic savings, other ideas?

NAIMA strongly recommends that the results be presented in substantially the same format as the existing recommendations. The recommended total R-values that maximize energy savings for attic, wall and floor assemblies in different climate zones contained in a table, which corresponds to a color-coded map. The only change NAIMA recommends is to revise the map to be consistent with the climate zone map developed by the Department and currently contained in the ICC and ASHRAE energy standards.

The current DOE R-value recommendations are used extensively in manufacturers’ literature and store displays because they are easy for consumers to understand. This color-coded map showing total R-value for different building assemblies is concise and easy to interpret. If the Department chooses to present more detailed results or insulation combinations it should be done in a separate fact sheet that can be used by consumers desiring more detailed information.

Thank you for the opportunity to comment on this information and we look forward to working with ORNL and the Department of Energy on the R-value recommendations.

Sincerely,

 

Charles C. Cottrell
Vice President, Technical Services


Replied By: from

30 - Nov - 2007 5:43

PM DOE Insulation Fact Sheet

I would like to briefly respond to your request for stakeholder comments on the fact sheet methodology. The cost assumptions as described in your e-mail appear reasonable; however I have not been able to collect specific insulation cost data to cross-check the numbers. Our material-only selling prices do not translate to installed costs paid by the builder or ultimate home owner. One additional potential source of cost data is the work that NREL has done on optimizing energy efficiency, which is discussed in the documents at these links. You might be able to get more from them on the underlying cost data base.
http://www.nrel.gov/docs/fy05osti/37733.pdfPDF

http://www.nrel.gov/docs/fy06osti/39821.pdfPDF

http://aceee.org/conf/06et/tp1-3_anderson.pdfPDF

I can confirm that all the cavity insulation R-values you have listed are available from our company and others on a national basis. All the batt products are manufactured at each of our regional plants and are listed on the standard Product Availability list for customers to order. In each locality, there are certain more popular items that are normally inventoried by contractors or retailers, but all the other R-values are available for ordering if they need them. Also, the loose-fill products for attics can be installed to a range of thicknesses/R-values to meet local requirements.

Reed Larson,
Technical Services Manager / Insulation Systems,
JMTC/P.O. Box625005/Littleton,CO80162


Replied By: from

30 - Nov - 2007 7:04 PM

DOE Insulation Fact Sheet

I have read this attached DOE Insulation Fact Sheet in its entirety and have nothing to add, remove or change.

Regards,

Joe Church.



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