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Members question duct-testing and alteration triggers that could force large retrofits
Summary
Board members expressed concern that proposed rules requiring duct testing when ductwork is relocated or increased by 25% could force expensive tear-outs and raise embodied-energy and cost concerns for older buildings and historic properties.
Staff reviewed new alteration provisions that would require duct system acceptance testing and possible sizing of new HVAC equipment when alterations relocate or increase ductwork by 25% or more of total system length. Several members warned that the requirement could force extensive work on older systems and be impractical for historic and existing buildings.
"Duct testing is required when relocating or increasing more than 25% of the lengths of the ducts in a space," the presenter explained. Board members said that requirement could compel owners to remove otherwise serviceable ductwork or tear out ceilings to meet insulation or testing obligations, raising cost and embodied-energy concerns.
Members asked staff to analyze interaction with the existing building code, historic exemptions and how the 25% threshold would be applied in practice. The board did not adopt a formal amendment at the meeting but signaled a desire to amend or remove the most burdensome testing triggers for alterations that would be impractical to comply with in older buildings.
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