Mandatory Attic Access Walkways

I submitted the following among proposals for 2018 revision of the International Energy Conservation Code:

Proposal submitted 1/4/2016:

R402.2.4 Access hatches and doors. Hinged doors and lift portals from conditioned spaces to unconditioned spaces (e.g. attics, unconditioned basements and crawl spaces) shall be insulated to the Energy Star standards of exterior opaque swinging doors, and shall be air sealed with well-fitting gaskets. The portal frame shall be sealed air tight in its rough opening. (The standard says: U-Factor ≤ 0.17)

The entry to an attic space at a portal shall have a surround of an ample raised floor that does not diminish insulation value. Flooring shall protect insulation against trampling while giving safe passage, to all attic electrical service points including fans, lights and junction boxes. Junction boxes not accessible from heated space shall be raised above insulation and flooring levels, or where this has failed, shall be flagged as a decked service point. Accessible service points shall include static vents that require periodic cleaning. Where a service point is buried in insulation, insulation over the service point shall be in batt form and tolerant of displacement for accessing the service point.

Existing code of 2015 says:

R402.2.4 Access hatches and doors. Access doors from conditioned spaces to unconditioned spaces such as attics and crawl spaces shall be weatherstripped and insulated to a level equivalent to the insulation on the surrounding surfaces. Access shall be provided to all equipment that prevents damaging or compressing the insulation. A wood- framed or equivalent baffle or retainer is required to be provided when loose-fill insulation is installed, the purpose of which is to prevent the loose-fill insulation from spilling into the living space when the attic access is opened, and to provide a permanent means of maintaining the installed R-value of the loose-fill insulation. 

All of this, and supporting statements offered to conference readers, is summarized in page Better Building Codes For Access Portals, at my web site r5portals.

I defended my proposal at 2016 Committee Action Hearings of the International Code Council in Louisville, KY, on April 18, 2016. There was expressed disdain in the matter of insulation value of a practical hatch, that I cited rival Energy Star standards, and no acknowledgement of my comprehensive math proof, that modest insulation is best; more on that elsewhere. Here, address the second-paragraph flooring requirement, forcefully opposed by one of the rotating intervenors of the National Association  of Home Builders. I took this opposition as formidable, in judges unanimously disapproving my proposal. Several participants privately encouraged me to persist in this and some of my other proposals, but no one came forward as an ally, to help if I would double my onerous personal investment, to offer and defend revised proposals, in Public Comment Hearings, Kansas City.  Those "final" hearings were concluded a week ago, and I was not there. To not feel defeated, I must believe that I am intent upon readiness to try again in the next of the three-year code cycles; then having time to enlist allies.

Here, add defense of the second paragraph of my proposal. I have a really-good example to share, of work done in Oregon City, Oregon June to July, 2016. A customer had discovered that large areas of the attics in his two-year-old home had no insulation. Hard to believe, but evidence showed in zonal early frost melt on the roof, unlike neighboring homes. 500 sq ft was bare, some seen in this view.  I suggest that a mandatory walkway here and an access cut further on, would have led to different and better construction choices. Impaired access is not good, for anyone.

In this photo see beginning of rapid and easy change. The scattered temporary plywood is important to my safety. I have cut down a horrible 16"  OSB skirt about the small access hole.

Move interfering HVAC ducts, and temporarily detach a bath fan duct. Separate HVAC flex ducts at a wye, and move them under the diagonal truss members.

Many trips are needed along a new smooth and level walkway, upon 32" bridges of truss elements. Cut batts to fit, in the garage, and carry pieces in a growing collection of empty insulation bags. A safe passageway should not be an afterthought. Many good things, not least worker safety, result from good access. Let access be lighted too. At least, let workers find power outlets to not rely on a flashlight.

In this access exercise, learn some lessons about HVAC duct installation, attic ventilation and a further thoughtless neglect of access. Preserving duct length is very important as ducts are disassembled and reset. Yet, I must sacrifice about 6" from each flex duct at this wye, because of remnant bad advice of PTCS trainers in the service area of Bonneville Power Administration. Goop, no longer required, should never be applied for liner attachment.

Goop applied blindly and in risk of clothing, missed this under-side zone of the main branch of the wye. There was duct leakage, out of sight. UL181 Nashua 557 tape easily achieves zero leakage here, and is the right choice for easiest damage-free separation of ducts for maintenance or replacement. Know that flexible ducts have claimed useful service life of not more than ten years . See example of Thermaflex ducts as fallen-apart rat paths after about 25 years .

I know that regardless of found condition, I must replace cardboard soffit vent baffles. They rarely survive more than thirty years and when used are with no manufacturer thought or guarantee of acceptable service life (sixty years!). Here I have more than conscience in play. Curl with detached flimsy staples is ugly. Looking down at vent bird block, see poor bird block design employed by most builders. Slot placement demands vent baffles 3 1/2" down from roof sheathing, a large sacrifice of potential insulation depth over exterior wall headers. This bird block is needed in every available roof joist bay, not in every fourth.

Lumber for proper soffit vent baffles is free, in good employment of job scrap. Use 25 cents of good deck screws, not nails. I assembled six baffles in thirty minutes. This is quicker than setting a $1 cardboard baffle, thus less expensive. Wood sleds are easily adapted for obstructions, then set much more securely.

Baffles just 32" tall are ample over R45 batts. I can push R30 top-layer batts tightly against a baffle, for fullest insulation value, and that is the controlling economy.

A hidden attic around this corner was uninsulated too. The triangular access is new. Opportunity was concealed behind redundant OSB sheathing.

While I am at this I will insulate over the garage too, to just R15. I can't bear to crawl there carrying insulation, through this jungle of beam and variable trusses.

Cut in a new access for the garage, "factory built" in my shop. Where truss bottom elements are 2x4, they must not carry loads unless strengthened as composite beams. Leave a couple of 9" rips of plywood that I needed for my safety, but not more flooring.

Here is the fully-dimensioned plan of my hatch, offered to anyone as noted here.

At June 18, 2021, I revisit this post upon reading the post of this date at Insulation Institute Blog: A Hot New Home and Missing Insulation. I see that this post should go further upon process of inspection, not just means of inspection. Process should be for information to the builder and ultimate home owner and not just a manager of building permits. Building permits delve in the short-term self-interest of a builder, to get a certificate of occupancy. They involve inspection requirements  often flouted. by disinterested and unmotivated municipal employees, who take an easy path where inspection is difficult or impossible.

Get better results where inspection is primarily in service of the self interest of the home occupants ever-after. Those citizens of the community  are the real employers of the inspectors. Let these employers then receive indelible proof of critical performance items in the form of pdf documents I call Diligence Reports. A diligence report is created by a professional technical writer rated for integrity and skill in taking photos and notes from the builder daily to generate each required Diligence Report. Report contents are driven by task checklists, and comply with simple national standards. The involvement of three parties in the satisfaction of checklists ensures honesty. 

A recent customer was fascinated with the notion of Diligence Reporting, and made this hat for me! 

I wondered when I would first find cause to share the humor.

Satisfaction With The BPA/ RTF Work Product

The following is a post of perhaps 2010, surfaced to the present in error in the course of applying labels. I don't know how to put it back. Instead, please read this in the present, updated. I have been interested in the excuse given by my rebates organization, Energy Trust of Oregon, that their policies for weatherization incentives are based on payback studies by Bonneville Power Administration and its contracted Regional Technical Forum. No criticism or improvement I offer can have any effect, against this slow Goliath. I studied the RTF documents in 2010 and reported that numbers presented have no evident bases. 

The RTF web presence for residential weatherization is now found at http://www.nwcouncil.org/energy/rtf/subcommittees/res/ 
Here I look for a cumbersome Excel spreadsheet, understood to be RTF's "Work Product."
This link works.

A 2011 document describes the RTF processes:
http://www.nwcouncil.org/energy/rtf/measures/support/guidelines/Guidelines%20for%20RTF%20Savings%20Estimation%20Methods%20(Release%206-1-11).pdf

RTF receives large funding, for no evident good result. A half million dollars being spent on existing measures review in 2012. Is anyone watching?

The "work product" of Bonneville Power Administration/ Regional Technical 
Forum, is in lists of "Deemed Measures." Such lists aim to give decisive figures from technical methodologies, of involved savings in Demand Side Management, DSM, for the power generator. Lists in areas of residential energy savings, are not for guidance of contractors or home owners.

The list at September, 2012 is:
http://www.nwcouncil.org/energy/rtf/measures/res/ResSFWx_v2_4.xlsm 
This is a link for download of an Excel file. It is more conveniently viewed via my Google Drive:
https://docs.google.com/open?id=0Byj-qncyomXmMVFxVzVXX25SN00 

My comparative study in 2010 is based on ResWXSF_FY10v2_1, which is no longer posted at nwcouncil.org. It may be seen instead where I have posted it at my Google Drive:
https://docs.google.com/open?id=0Byj-qncyomXmM0QtS1NiZWNGRUE. 

These Excel spreadsheets are large and I am entitled to consider significance of these to me, as a weatherization contractor, and as a home owner. I look only at residential weatherization matters, to see that worthy work, happens. In this BPA can't help, they only control rates paid to them by Utility customers. RTF has no direct role in helping. The existing courses of action are through government and other entities that handle funds to be given out or to be on-loan. 

The lack of BPA heart in weatherization is evident in its posting of consumer and contractor links of end-result Specifications documents. The core authorship is at Portland, Oregon neighbor, Energy Trust of Oregon, ETO. Posted ETO specifications are two years out of date. Although BPA tries to push ETO specifications throughout the Columbia River watershed service area, and ETO blames specification deficiencies on RTF limitations, BPA is not paying much attention. No one is in charge; certainly not BPA.


I have asked BPA and RTF to justify their so-expensive work product vs. my measures review with understandable bases, done at no cost. They will not reply, being somehow beyond criticism. At September 2012, I look for changes on insulation measures that matter to me. Comparing documents v2.1, v2.3 and v2.4, I find no progress. A few numbers shift by strange small amounts.
https://docs.google.com/open?id=0Byj-qncyomXmVWgyZjZRcDYycFk 


A respondent to this survey, stated:
"It would be helpful to have actual savings data to back up estimated energy savings."


I know that savings Insulation Math has predicted for my customers, have been of no interest to my rebates organization. The improved utility bills of my customers are not being tracked.

What is Home Performance with Energy Star?

I take the lonely position that the Unites States is horribly misguided, where it takes and pushes the notion that residential weatherization benefits from a US Department of Energy/ Environmental Protection Agency program called Home Performance with ENERGY STAR®.

This position is expressed in numerous posts. Search Home Performance in the line above. I do not just imagine that home performance is simply a scam to most contractors. A little snake oil song and dance. Privileged access to rebates for customers then abused in a conflict of interest. I knew I had done wrong when I sold my blower door to a BPI-certified know-nothing. I had done wrong in abetting misuse of that tool, thereafter. She immediately perceived me with pity. How will I get work? She offered to share crumbs to me as a subcontractor, in her privileged role as a General, no doubt taking ten percent for no effort and no competence or responsibility, a theft from my customer. A year later her only recollection of value in the blower door was in finding a nail pull-out hole at bottom of a large-diameter return air duct; no value in other words.

I might have a blower door again some day. But, never while lies persist, that they are needful. Trained eyes find every problem, where I have done the hard work of developing attic access. In every case where I have followed a HPwES tester, I find large savings opportunities not detectable by test, never sought by test, and not achievable without days of hard work, less rewarded because of counterfeit competition. The worst problem with privilege of rebates or other incentives in HPwES, is that it teaches non-participants to not bother with diligence.

I have thought HPwES to be a product of odd thinking at Bonneville Power Administration and Eugene (Oregon) Water & Electric Board, feeling guilty of association as an Oregonian. From EWEB: Final Report, Demand-Side Resource and Programs Assessment for Eugene Water & Electric Board November 13, 2006, at page 35:

Home Performance with ENERGY STAR® programs, a structure that focuses on optimizing household energy performance using blower doors and other test equipment.
It is rarely more than a blower door show.

ICF claims it is running the show, for EPA:
http://www.icfi.com/insights/projects/community-development/home-performance-with-energy-star 
ICF provides support to the EPA’s Climate Protection Partnerships Division in the development and implementation of Home Performance with ENERGY STAR® (HPwES) and other home improvement initiatives designed to encourage homeowners to make cost-effective energy efficiency improvements.

The HPwES program focuses on the development and delivery of the whole-house approach to improving residential energy efficiency, comfort, and safety. As the primary recruitment team for HPwES, ICF works with utilities, state energy offices, and other organizations on program development and coordinates the delivery of national objectives in regional markets.

Currently, ICF manages twenty regional markets to identify program sponsors for HPwES. We actively work with these organizations to provide support during the planning and implementation process. This support includes assistance with conducting a detailed market assessment, selecting appropriate program design, establishing contractor training and certification requirements, recruiting contractors, and implementing comprehensive home performance programs, including incentive payment verification and processing.

Who is ICF?
http://www.icfi.com/about/our-history 
ICF International was founded in 1969 as the Inner City Fund, a venture capital firm whose mission was to finance inner-city businesses.  

Our first president was C. D. Lester, a former Tuskegee Airman, who was joined in the firm by three U.S. Department of Defense analysts. Our consulting business proved more successful than our investments, and in 1972, the firm was reorganized as a consulting firm and renamed ICF Incorporated.

Focusing on energy issues for U.S. federal agencies and for industry throughout the 1970s, the firm expanded into environmental business rapidly in the 1980s and began to build its engineering capabilities. In 1988 ICF acquired Kaiser Engineers, which had originated as the engineering unit of Henry J. Kaiser's industrial empire and grew to rank among the largest engineering and construction companies in the world. In the following year (1989), the combined company went public and eventually traded stock on the New York Stock Exchange. The combined company operated as "ICF Kaiser,"with the consulting unit remaining largely intact.

In 1999, ICF Consulting ended its decade-long affiliation with Kaiser Engineers through a leveraged buyout, financed in part by the CM Equity Partners, LP, an equity investment firm based in New York City.

In 2006, ICF Consulting was renamed ICF International to reflect our growing geographic presence and increased scope of our service offerings from advisory services through implementation and improvement. The firm also pursued an Initial Public Offering (IPO) and now is a publicly traded firm listed on the NASDAQ under the symbol ICFI.

ICF International is a global, diversified firm that combines the entrepreneurship and dynamism of a new company with a solid reputation in the consulting industry derived from more than 40 years of performance.

Playing The Game: For Shame

All who participate in "performance-based" weatherization, the game in question, tell a lie. The lie is that the prep work for upgrade of residential insulation must be guided "scientifically," with a blower door. 

The participant player sets this nylon garment into your front door, with a clever aluminum framework that seals it all around. A strong fan blows to the outdoors, pulling air in everywhere else. A "minus 50 pascal" pressure differential is established by winding up the fan, and the calibrated flow rate of the fan is recorded. It's as if a twenty MPH wind is driving against your home from all directions, simultaneously, they say.


Under these conditions, some interesting things happen. Mildly interesting in that few discoveries are actionable. Irksome conditions in that windows and outside doors are shut. Stupid fireplace damper closed, don't forget it. All interior doors are open and subject to some room-to-room differentials. Cool breezes around old doors. Unrealistic inflow at unloaded window gaskets. A failed backdraft stop on a fan might be detected. Stop it, says the home occupant. And the crew goes to work for a couple of hours of "fixing" your home. I'm concerned about what happens in the attic. Can't fix a fan, so forget that.


Untrained people go around with cans of insulating foam, looking for things to squirt. The least-professional will toss the couple of expended cans, still with some flammable propellant, wherever. A pro who has invested a few dollars will dispense via a "gun," not deigning ever to do the messy and stinky change of a cartridge on a job. Perhaps he has invested in  two guns. What he can't see, he doesn't need to know. Two cans expended. Good job done?




No way!


I believe this is a known, taught, scam, that teaches home owners to not trust weatherization contractors, and to question all recommendations from program sponsors.




Here is my first public complaint against the fraud, where the contractor is named. My knowledge is from the rare privilege of being allowed to see another contractor's work. Such work is a secret between the contractor and a rebates organization such as Energy Trust/ Conservation Services Group, in Oregon. My complaint was sniffed-at, by these groups. The contractor was soon elevated to Energy Trust's highest "Three Star" honors. 


All who help deliver Home Performance With Energy Star, "qualified" through crummy  training blessed and taxed by Building Performance Institute, BPI, or through Bonneville Power Administration's Performance Tested Comfort Systems (PTCS), are coddled and rewarded. The advantage given to a playing "three star" contractor can be payout to the contractor of Public Purpose funds, in excess of $10,000 per year. A contractor not playing the game, for whatever its stupid goal, never gets a penny of public money. None ever should. We work for the public, who get to do right and hire smart, if they are not misled. Contractors should be recommended only for their honesty and diligence, demonstrated in years of complaint-free service.


Hiring smart can yield a better result, like this.


To be continued.

Real Air Sealing In An Oregon Attic

I offer a contrast between charged silliness of Home Performance with Energy Star (HPwES) air sealing, and real sealing, of an Oregon attic. Work complained against, is by the most-respected HPwES contractor in metro Portland, Oregon. The HPwES work was  completed Fall 2008, and left the home occupants feeling no improvement of comfort, helpless and had. I claim a friendship with the owner of the HPwES business, and invited him to confront my complaints, as they hatched. Instead, shielded by the power of a large national commitment to HPwES, he simply challenged me: "How long have you been in this business?" Pathetic me? Six years of energetic learning. He? 25 years. Of such work? I think not. Businesses become corrupted by stupid practices, and the decline likely is only in recent years. There is a basis for defense and pride, but it is not likely that work tied to HPwES, has improved since 2008.


Here is an album showing what I found, and how I fixed it.


There is a lot in the link, for an average reader. Let me summarize. The HPwES contractor accepted a job of improving the "performance" of an attic with dangerous and limited access, and badly-placed found insulation, intended R19. Work done was messy slathering of goop on the home's air handler return ducts and header boxes (air source heat pump electric heat already installed), a wrap of unfaced R11 batts on those ducts, and an aimless hour or two of whimsically dispensing a couple of cans of orange spray foam. That orange foam was abhorrent to the home owner, oozing in kitchen cabinets, and in other areas of the living space. I take it, this is the taught practice of HPwES. Nothing more brainy happens in the "holistic" approach to weatherization. The foam touched gaps of about 5% of the home's drywall wall headers on the attic floor, and was all for a very offending "show" elsewhere in unattached piles and gobs. I infer that a door on the air handler closet whistled under blower door influence, and was quieted with spray foam and new gaskets. The "after" blower door test result can only have been with not-allowed closure of that closet door, for result of more than 1100 CFM50, vs required 300 CFM50, minimum for rebate. Quite an achievement! The HPwES contractor might claim even now, that there was no error or wrong-doing. The rebate sponsor, Energy Trust of Oregon, will not respond to other complaint in the job, against ineffective crawl space insulation. I think then that the only way to challenge arrogant HPwES, Energy Trust, and Bonneville Power Administration, is in this kind of public airing.


I have been waiting for HPwES contractors to defend themselves where I have accused them in several places on a public forum: Here, and  here. Responses are aw c'mon, or don't spoil the "game" of auditing. This isn't about taking a home owner's money to do an audit. It's about saving energy, and fixing things. We don't need auditors. We need people who fix things, and document their work for homeowner records. Anyone who does things or writes things that do not have honest value, is part of a problem.

Weatherization and a State Bank, in a Mayoral Race

I see a weatherization core in the politics of a mayoral campaign in Portland, Oregon. Our sitting mayor, Sam Adams, escaped recall thanks to voter lethargy, after lying to avoid losing his election in 2008. Our city has suffered malaise through his term. Sam Adams has wisely decided to not seek reelection, creating an early vacuum for a good array of candidates to move in.


I attended two rallies in the Portland mayoral campaign, last evening, January 26th. The first was in promotion of candidate Eileen Brady. The best part of that event was a talk by Paul Hawken, surprising in the clarity of a call for an Oregon State Bank, as a channel for keeping finance through our savings, local. Off Wall Street. Not gone to who-knows-where and maybe doing ourselves harm. The State Bank is a central focus of the new Oregon Working Families Party, and did not fare well in the Oregon Legislature 2011 session. I bet it is not a matter of passion, to Eileen Brady. Paul Hawken will remain an honored adviser, and will not expect much environmental or finance innovation through Portland's Mayor, whoever is elected. 


I left the staid Brady event after an hour, for more-urgent attendance at a Jefferson Smith Party, a really joyous event. The Smith campaign makes no promise on the State Bank issue, yet it was Jefferson Smith who stood up for a State Bank, at a major Working Families Party event in Portland, February 1st, 2011. That attendance has earned my loyalty, to my State Representative. I was generously given opportunity to speak up in a Smith Town Hall Meeting in my neighborhood, on March 30th, 2011, before the dawn of the current mayoral opportunity. I will work very actively for the election of Jefferson Smith, to nurture whatever seed I have planted in a weatherization cause. 


At the Eileen Brady event, I also wanted to study a relationship between Ms. Brady, and endorsers present, Jules Bailey, and Derek Smith, the City of Portland employee who elevated himself to run a new private business spending public funds for weatherization, Clean Energy Works Portland (now Clean Energy Works Oregon). More on this below. 


I have my own view on utility of an Oregon State Bank, and see it has not before been posted here. It is as stated here in a May, 2011 email response to yet-another customer who declined my weatherization bid, for lack of up-front savings:


I imagine a radical escape from commercial banking, serving weatherization. A new Oregon State Bank could shuffle money for the work. The work with rapid payback gets done, and draw on the savings commences, in sustained higher utility bills or other repayment contract, with closeout at house sale. The contractor could draw from a liabilities account as needed, maybe leaving a lot in a retirement account. I  see the important things we must do to survive, getting harder with each new catastrophe. This could apply not only where large energy savings are possible, but  where hazards risk house destruction, as with faulty wiring or a failed roof.

By chance yesterday, I stopped in at the Portland Metropolitan Workforce Training Center,  a facility of Portland Community College. I remarked to an attendant, that  I work as a business owner in weatherization, with skills hard-won. Would someone talk with me? I had a wonderful half-hour meeting with the center's Director. We confirmed that no training is happening at the Center.

I reported that none is happening through money funnel Energy Trust of Oregon, per their online calendar. 

I find no credible training in weatherization, anywhere except ECONTC. A well-meaning person in Portland, seeking to participate in "green" activities for needful employment, is abused in this. The cost now is $2995 for forty hours of dreadful misguidance, paid always by our federal or state tax dollars in some foolish grant. Some of the "BPI Certified" wannajobs do find work, in the abuse of home owners.

BPI certification and resolve to do weatherization "performance-based" are prerequisite of contractors who align with Clean Energy Works Oregon, CEWO, the only hope in Oregon for home owners who NEED the up-front financing of work that was promised in Oregon's HB2626 of 2009, feather in the cap of Rep. Jules Bailey, and should-be pride to the State of Oregon, that surpasses our first-in-USA Bottle Bill. CEWO takes taxpayer money justified by HB2626, and hands it out in big piles, usually to those with no need, and always with spillage to the privileged play-along contractors. I do better work always, than any of those on the take. My customers are never punished where I am not in the program, but very often my bids fail because work is not affordable. People just stay cold in Winter, with loss of productivity and consequence to health.

I think such status-quo inaction with weatherization is common. Federal stimulus money never made it out, thanks to BPI greed in trying to rig programs.

Oregon might yet lead the nation in weatherization, not subvert it through energetically supporting Home Performance With Energy Star. Really finding the public financing, and sending it where it really is needed, is key. For this, we need our State Bank. Every state might need a similar bank. We need to see weatherization and home preservation in general, as suitable investments in a State Bank portfolio. Portland might move the ball some, in wise selection of its next mayor.