Public Comment in regards to Pool Pumps and Motors

 

July 30, 2013

 

Submitted by Jennifer Hatfield on behalf of the Florida Swimming Pool Association

 

Section:  R101.4.3 of the FBC – Energy Conservation

 

Background: The 2010 FBC – Energy Conservation included Table 101.4.1 Nonexempt Existing Buildings, which provided requirements for renovations, specifically equipment found in Section 403, which included pool pumps and motors.  The renovations portion of this table provided that only when the cost exceeded 30% of the assessed value of the structure would Section 403 requirements apply.  Further, the Commission provided a guidance document titled “Energy Code Guidelines for Existing Building Replacement Systems,” which clearly provided that pool filtration pumps only were required to meet Section 403.9.4 of the code if they were part of a renovation job where total cost exceeded 30% of the assessed value of the pool structure. Table 101.4.1 was not brought forward in the 2013 Code.  As the 2013 Code currently stands, it is unclear on what is required when it comes to replacement pool filtration pumps and motors; therefore, the following public comment would appear to fall under the glitch category “unintended results from the integration of previously adopted Florida-specific amendments with the model code.”

 

Proposed Modification:

R101.4.3 Additions, alterations, renovations or repairs. Additions, alterations, renovations or repairs to an existing building, building system or portion thereof shall conform to the provisions of this code as they relate to new construction without requiring the unaltered portion(s) of the existing building or building system to comply with this code. Additions, alterations, renovations or repairs shall not create an unsafe or hazardous condition or overload existing building systems. An addition shall be deemed to comply with this code if the addition alone complies or if the existing building and addition comply with this code as a single building.

Exception: The following need not comply provided the energy use of the building is not increased:

1. Storm windows installed over existing fenestration.

2. Glass only replacements in an existing sash and frame.

3. Surface applied window film on existing fenestration assemblies.

4. Existing ceiling, wall or floor cavities exposed during construction provided that these cavities are filled with insulation.

5. Construction where the existing roof, wall or floor cavity is not exposed.

6. Reroofing for roofs where neither the sheathing nor the insulation is exposed. Roofs without insulation in the cavity and where the sheathing or insulation is exposed during reroofing shall be insulated either above or below the sheathing.

7. Replacement of existing doors that separate conditioned space from the exterior shall not require the installation of a vestibule or revolving door, provided, however, that an existing vestibule that separates a conditioned space from the exterior shall not be removed,

8. Alterations that replace less than 50 percent of the luminaires in a space, provided that such alterations do not increase the installed interior lighting power.

9. Alterations that replace only the bulb and ballast within the existing luminaires in a space provided that the alteration does not increase the installed interior lighting power.

10. Swimming pool filtration pumps and motors.

 

 

Rationale:  This modification would make it clear that when replacing filtration pumps and motors, Section R403.9 (specifically the requirements found in APSP-15 in regards to pool filtration pumps and motors) does not apply.  APSP-15 provisions addressing pool filtration pumps and motors would only apply for new construction.  The current 2010 code provides this same exception only when the total cost of the renovations does not exceed 30% of the assessed value of the pool.  This proposal simply makes a blanket exemption for replacement filtration pumps and motors because in most cases a pool renovation will not exceed 30% of the assessed value of the pool and it gives the consumer a choice.  Further, this proposal provides a clearer approach on what pool pump and motor energy efficiency requirements are provided for replacements versus new construction, providing clarity for utility companies offering pump rebates and for energy raters needing to have a clear understanding of the minimum pool requirements for rating programs.