1 - The proposed prescriptive requirements are an excessive
increase in r-value especially when compared against established advanced
energy design guidelines (AEDG). The highest r-value requirement in the AEDGs
is 15.2 and then only in CZ7&8. This current process for measuring the cost
effectiveness of a measure needs to be revisited, since it does not take into
account the interactions between different energy measures. Stuffing excessive
amounts of material into a structure is not necessarily any more sustainable
than not having enough. Also values are a result of extrapolation. The values
from the AEDG are a much more reasonable than those proposed.
2 - Due to age of the criteria equations, early 1990's, when the highest value
of insulation was 15.2, the generated value of 19.5 is not cost effective when
compared against the potentially low energy efficiency benefit.