Comment #1Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 2Paragraph / Figure / Table / Note: 904.4.1.1Comment Type: GeneralComment:Most of this makes sense to me, it is mostly housekeeping. There is one significant change to our operations though: 904.4.1.1 The Provider’s QA Designee shall be responsible for an annual rating data file review of the greater of one (1) home or ten percent (10%) of each Rater's annual total of homes for which Projected or Confirmed confirmed or sampled rRatings were provided. When determining the number of rating data files to review for a Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 homes x 10% = 10.1 means that 11 rating data files shall be reviewed. This says that projected ratings OR Confirmed Ratings completed in a given year must be QA’d. This seems ambiguous regarding projects that overlap years. Are we potentially counting homes for QA twice when they have projected ratings one year and confirmed ratings the next. In the past the QA was based on Confirmed ratings only. This wasn’t perfect either, but easier to implement. Justification for Change:We would be dramatically increasing the number of ratings requiring review and many QAZ Providers will need a new process of reporting Projected Ratings. This additional cost to Raters and Providers could be a shock to the system and a complication of our already complicated systems. Also As I understand it, most QA Providers have been set up to QA only Confirmed Ratings and this change will require new systems to collect and review Projected ratings as well. IF adopted I think this would require considerable time to implement.Proposed Change:For the sake of QA Review Count of Total Ratings, a house which has both a projected and Confirmed Rating will not count as 2 Home Ratings - only one. I think we need some more clarification about how to handle reporting of Projected Ratings.
Most of this makes sense to me, it is mostly housekeeping. There is one significant change to our operations though:
904.4.1.1 The Provider’s QA Designee shall be responsible for an annual rating data file review of the greater of one (1) home or ten percent (10%) of each Rater's annual total of homes for which Projected or Confirmed confirmed or sampled rRatings were provided. When determining the number of rating data files to review for a Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 homes x 10% = 10.1 means that 11 rating data files shall be reviewed. This says that projected ratings OR Confirmed Ratings completed in a given year must be QA’d. This seems ambiguous regarding projects that overlap years. Are we potentially counting homes for QA twice when they have projected ratings one year and confirmed ratings the next. In the past the QA was based on Confirmed ratings only. This wasn’t perfect either, but easier to implement.
We would be dramatically increasing the number of ratings requiring review and many QAZ Providers will need a new process of reporting Projected Ratings. This additional cost to Raters and Providers could be a shock to the system and a complication of our already complicated systems. Also As I understand it, most QA Providers have been set up to QA only Confirmed Ratings and this change will require new systems to collect and review Projected ratings as well. IF adopted I think this would require considerable time to implement.
For the sake of QA Review Count of Total Ratings, a house which has both a projected and Confirmed Rating will not count as 2 Home Ratings - only one.
I think we need some more clarification about how to handle reporting of Projected Ratings.
Comment #2Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 3Paragraph / Figure / Table / Note: JustificationsComment Type: TechnicalComment:It seems this proposed revision stems from some builders never hiring a rater to verify projected ratings once they have the projected rating certificate in hand and I am not sure the proposed revisions resolve the problem at hand. Does 303.7.2 imply projected ratings are to become confirmed ratings? If so what is the control mechanism to require a builder to have a confirmed rating once a Projected Rating certificate is issued? Outside of a program requirement for labeling(e.g. Energy Star) or a code jurisdiction requirement, I don’t see how a builder would be motivated to request verification services just because it is written in the RESNET Standard. 303.7.2 only states that “a Projected Rating for the home shall become a Confirmed Rating for the home”?...In other words, a builder can request a "Projected Rating" Service and obtain a projected Home Energy Rating Certificate without any measure of site verification. So if their sole purpose in getting a HERS Rating is for marketing, once that certificate is in hand to label and market the homes efficiency, what's the motivation to pay for verification (outside of the obvious benefits of a 2nd set of eyes on the home)? I believe in those cases where a builder only hires rating services for the projected rating certificate or label, the proposed revised statement below at least makes it clear to whoever looks at the label/certificate that no verification went into that label in hopes that the consumer, code official, or whomever is looking at the label would know to seek verification. Proposed revisions to the labeling language: “This home has been labeled in accordance with the RESNET Standard definition of a projected rating and is based on plans and specifications that have not been verified. These specifications are assumed to have not been verified in accordance with any RESNET Standard for verification unless indicated in an updated label with a “Confirmed Rating” or Sampled Rating” Type. Proposed Revisions to the HERS Software Reporting Requirements: I also propose that the rating software companies should be required to include the rating type and prescribed rating type statements (such as the current sampling language and the proposed project rating language) on any report that contains a HERS Index. To my knowledge the sampling statement is only reported on the Energy Star label and is definitely not reported on the HERC, Home Energy Rating Label, or the HERC Home Performance reports commonly used in non-ENERGY STAR, HERS Rated Homes. Justification for Change:Technically a projected rating is not a part of the “Sampling Protocol” and does not fit well into that standard, since no site visit would be required of a builder to have a projected rating certificate in hand. The projected rating type, as RESNET implies in this ammendment, is less stringent than the sampling standard and should not be lumped into the sampling standard if since no measure technically has to be verified in the field for any home. The statement above better distinguishes the projected rating from other types of field verified ratings such as a sampled or confirmed rating type...each of these types deserve their own "disclaimer" pertinent to the involvement of verification. Proposed Change:Proposed revisions to the labeling language: “This home has been labeled in accordance with the RESNET Standard definition of a projected rating and is based on plans and specifications that have not been verified. These specifications are assumed to have not been verified in accordance with any RESNET Standard for verification unless indicated in an updated label with a “Confirmed Rating” or Sampled Rating” Type. Proposed Revisions to the HERS Software Reporting Requirements I also propose that the rating software companies should be required to include the rating type and prescribed rating type statements (such as the current sampling language and the proposed project rating language) on any report that contains a HERS Index. To my knowledge the sampling statement is only reported on the Energy Star label and is definitely not reported on the HERC, Home Energy Rating Label, or the HERC Home Performance reports commonly used in non-ENERGY STAR, HERS Rated Homes.
It seems this proposed revision stems from some builders never hiring a rater to verify projected ratings once they have the projected rating certificate in hand and I am not sure the proposed revisions resolve the problem at hand.
Does 303.7.2 imply projected ratings are to become confirmed ratings? If so what is the control mechanism to require a builder to have a confirmed rating once a Projected Rating certificate is issued? Outside of a program requirement for labeling(e.g. Energy Star) or a code jurisdiction requirement, I don’t see how a builder would be motivated to request verification services just because it is written in the RESNET Standard. 303.7.2 only states that “a Projected Rating for the home shall become a Confirmed Rating for the home”?...In other words, a builder can request a "Projected Rating" Service and obtain a projected Home Energy Rating Certificate without any measure of site verification. So if their sole purpose in getting a HERS Rating is for marketing, once that certificate is in hand to label and market the homes efficiency, what's the motivation to pay for verification (outside of the obvious benefits of a 2nd set of eyes on the home)?
I believe in those cases where a builder only hires rating services for the projected rating certificate or label, the proposed revised statement below at least makes it clear to whoever looks at the label/certificate that no verification went into that label in hopes that the consumer, code official, or whomever is looking at the label would know to seek verification.
Proposed revisions to the labeling language: “This home has been labeled in accordance with the RESNET Standard definition of a projected rating and is based on plans and specifications that have not been verified. These specifications are assumed to have not been verified in accordance with any RESNET Standard for verification unless indicated in an updated label with a “Confirmed Rating” or Sampled Rating” Type.
Proposed Revisions to the HERS Software Reporting Requirements: I also propose that the rating software companies should be required to include the rating type and prescribed rating type statements (such as the current sampling language and the proposed project rating language) on any report that contains a HERS Index. To my knowledge the sampling statement is only reported on the Energy Star label and is definitely not reported on the HERC, Home Energy Rating Label, or the HERC Home Performance reports commonly used in non-ENERGY STAR, HERS Rated Homes.
Technically a projected rating is not a part of the “Sampling Protocol” and does not fit well into that standard, since no site visit would be required of a builder to have a projected rating certificate in hand.
The projected rating type, as RESNET implies in this ammendment, is less stringent than the sampling standard and should not be lumped into the sampling standard if since no measure technically has to be verified in the field for any home. The statement above better distinguishes the projected rating from other types of field verified ratings such as a sampled or confirmed rating type...each of these types deserve their own "disclaimer" pertinent to the involvement of verification.
Proposed revisions to the labeling language: “This home has been labeled in accordance with the RESNET Standard definition of a projected rating and is based on plans and specifications that have not been verified. These specifications are assumed to have not been verified in accordance with any RESNET Standard for verification unless indicated in an updated label with a “Confirmed Rating” or Sampled Rating” Type. Proposed Revisions to the HERS Software Reporting Requirements I also propose that the rating software companies should be required to include the rating type and prescribed rating type statements (such as the current sampling language and the proposed project rating language) on any report that contains a HERS Index. To my knowledge the sampling statement is only reported on the Energy Star label and is definitely not reported on the HERC, Home Energy Rating Label, or the HERC Home Performance reports commonly used in non-ENERGY STAR, HERS Rated Homes.
Comment #3Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 3Comment Type: TechnicalComment:Worst-Case Analysis –A home energy rating for which the minimum rated features of the home are configured to provide the poorest energy performance of the home (i.e. the largest HERS Index) when four ordinal home orientations and the least energy efficient minimum rated features for the specified home plan are considered by the Rating. Worst-Case Analysis may not only provide for the poorest energy performance of the home but may also have threshold diagnostic threshold values input into the software. It may not be the least energy efficient minimum rated features. I suggest alternate wording: Worst-Cast Analysis-A home energy rating from a specified home plan where the poorest energy performance of the home (i.e. the largest HERS Index) is used when four ordinal home orientations are evaluated. A Worst Case analysis may use threshold diagnostic values to determine the least energy efficient minimum rated features for the specified home plan.Justification for Change:The definition for Worst-Case Analysis does not take into account threshold diagnostic values that are assumed at the plan stage.Proposed Change:I suggest alternate wording: Worst-Cast Analysis-A home energy rating from a specified home plan where the poorest energy performance of the home (i.e. the largest HERS Index) is used when four ordinal home orientations are evaluated. A Worst Case analysis may use threshold diagnostic values to determine the least energy efficient minimum rated features for the specified home plan. Also I did not see where Projected Ratings are addressed in the Standards concerning RESNET Registry input. I Propose NO Projected Ratings are input into the Registry. Only Projected Ratings site confirmed should be input into the REGISTRY. The site confirmed threshold values can be arrived at by using threshold diagnostic testing or actual diagnostic values.
Worst-Case Analysis –A home energy rating for which the minimum rated features of the home are configured to provide the poorest energy performance of the home (i.e. the largest HERS Index) when four ordinal home orientations and the least energy efficient minimum rated features for the specified home plan are considered by the Rating.
Worst-Case Analysis may not only provide for the poorest energy performance of the home but may also have threshold diagnostic threshold values input into the software. It may not be the least energy efficient minimum rated features.
I suggest alternate wording: Worst-Cast Analysis-A home energy rating from a specified home plan where the poorest energy performance of the home (i.e. the largest HERS Index) is used when four ordinal home orientations are evaluated. A Worst Case analysis may use threshold diagnostic values to determine the least energy efficient minimum rated features for the specified home plan.
The definition for Worst-Case Analysis does not take into account threshold diagnostic values that are assumed at the plan stage.
Also I did not see where Projected Ratings are addressed in the Standards concerning RESNET Registry input. I Propose NO Projected Ratings are input into the Registry. Only Projected Ratings site confirmed should be input into the REGISTRY. The site confirmed threshold values can be arrived at by using threshold diagnostic testing or actual diagnostic values.
Comment #4Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 2 Paragraph / Figure / Table / Note: 904.4.1.3.4Comment Type: TechnicalComment:904.4.1.3.4 For In the case of each Confirmed Ratings , confirm that the values entered into the rRating sSoftware for all Minimum Rated Features are either RESNET-defined defaults or are supported by field data. The values entered into the rating software for a Confirmed Rating are permitted to represent a worst-case analysis. for homes Suggested New wording to above: The values entered into the rating software for a Confirmed Rating are permitted to represent a Worst-Case Analysis for the home. Capitalize Worst-Case as it is now a defined analysis. Suggested new wording to above: ...are either RESNET-defined defaults or are supported by on site field confirmed testing using threshold diagnostic values or actual diagnostic values.Justification for Change:2 comments... One for capitalizing Worst-Case Analysis since it is a defined term. Two for new wording to take into account a Confirmed Rating is now a Projected Rating that has been confirmed using actual on site diagnostic testing. This diagnostic testing can either be to confirm threshold values have been met or that site testing has been performed and one has actual diagnostic values that can be reinput into the software to get the lowest HERS Index for this Projected Rating. Again I note -do we need to state that ONLY CONFIRMED RATINGS are input into the REGISTRY?Proposed Change:The values entered into the rating software for a Confirmed Rating are permitted to represent a Worst-Case Analysis for the home. Capitalize Worst-Case as it is now a defined analysis. Suggested new wording to above: ...are either RESNET-defined defaults or are supported by on site field confirmed testing using threshold diagnostic values or actual diagnostic values.
904.4.1.3.4 For In the case of each Confirmed Ratings , confirm that the values entered into the rRating sSoftware for all Minimum Rated Features are either RESNET-defined defaults or are supported by field data. The values entered into the rating software for a Confirmed Rating are permitted to represent a worst-case analysis. for homes
Suggested New wording to above:
The values entered into the rating software for a Confirmed Rating are permitted to represent a Worst-Case Analysis for the home.
Capitalize Worst-Case as it is now a defined analysis.
Suggested new wording to above:
...are either RESNET-defined defaults or are supported by on site field confirmed testing using threshold diagnostic values or actual diagnostic values.
2 comments...
One for capitalizing Worst-Case Analysis since it is a defined term.
Two for new wording to take into account a Confirmed Rating is now a Projected Rating that has been confirmed using actual on site diagnostic testing. This diagnostic testing can either be to confirm threshold values have been met or that site testing has been performed and one has actual diagnostic values that can be reinput into the software to get the lowest HERS Index for this Projected Rating.
Again I note -do we need to state that ONLY CONFIRMED RATINGS are input into the REGISTRY?
Comment #5Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 2 Paragraph / Figure / Table / Note: 102.1.4.1Comment Type: TechnicalComment:102.1.4.1 Projected Rating. If the home energy rating Provider’s program provides for Projected Ratings, the rating must be clearly labeled as a Projected Rating. Projected Ratings may be used to demonstrate energy code compliance or programmatic qualification but shall not be classified as Confirmed Ratings until the home is subjected to field inspection and testing, if applicable, in accordance with Section 303.7 of RESNET Standards My concern is Projected Ratings be allowed as programmatic qualification with out some written stipulation such as "FROM PLANS-No DIAGNOSTIC TESTING HAS BEEN PERFORMED" be required to be printed on software outputs. I suggest adding wording to 102.1.4.1 Projected Rating. ....clearly labeled on all software output forms for Projected Ratings "Projected Rating from plans-No diagnostic testing has been performed".Justification for Change:The concern is most large production builders use raters/providers who utilize projected ratings for code compliance or program compliance. The output from the software should clearly state it is a Projected Rating which has not been confirmed by on-site diagnostic testing. The Projected Rating could have threshold diagnostic values which will have to be field verified before it can be utilized as an actual confirmed rating. I suggest a confirmed rating is the only rating that is input into the RESNET REGISTRY. A Rater or Provider could use the "batch" feature of the software to change from a Projected Rating to a Confirmed Rating before being input into the RESNET REGISTRY.
102.1.4.1 Projected Rating. If the home energy rating Provider’s program provides for Projected Ratings, the rating must be clearly labeled as a Projected Rating. Projected Ratings may be used to demonstrate energy code compliance or programmatic qualification but shall not be classified as Confirmed Ratings until the home is subjected to field inspection and testing, if applicable, in accordance with Section 303.7 of RESNET Standards
My concern is Projected Ratings be allowed as programmatic qualification with out some written stipulation such as "FROM PLANS-No DIAGNOSTIC TESTING HAS BEEN PERFORMED" be required to be printed on software outputs.
I suggest adding wording to 102.1.4.1 Projected Rating. ....clearly labeled on all software output forms for Projected Ratings "Projected Rating from plans-No diagnostic testing has been performed".
The concern is most large production builders use raters/providers who utilize projected ratings for code compliance or program compliance. The output from the software should clearly state it is a Projected Rating which has not been confirmed by on-site diagnostic testing. The Projected Rating could have threshold diagnostic values which will have to be field verified before it can be utilized as an actual confirmed rating. I suggest a confirmed rating is the only rating that is input into the RESNET REGISTRY. A Rater or Provider could use the "batch" feature of the software to change from a Projected Rating to a Confirmed Rating before being input into the RESNET REGISTRY.
Comment #6Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 2Paragraph / Figure / Table / Note: the new 904.4.1.3.5Comment Type: EditorialComment:The new term "Rating Software file" is being introduced. In its current work to updated Chapter 9, the QA Committee has used a different term, "Energy Simulation File", based on a discussion last year that included Kelly Parker and Philip Fairey.Justification for Change:Recommend that the Technical Committee adopt this definition so it is in place already when the QA Committee's changes are sent to public comment, and so the QA Committee does not have to change the definition again, possibly causing confusion. Best to naill down one definition as soon as possible.Proposed Change:Change the term "Rating Software file" to "Energy Simulation File" in new paragraph 904.4.1.3.5. Add the following definition to Appendix B: Energy Simulation File – The complete set of input data used by an accredited rating software tool to determine the Home Energy Rating for the specified home as listed in Section 102.1.4.110 of these Standards.
The new term "Rating Software file" is being introduced. In its current work to updated Chapter 9, the QA Committee has used a different term, "Energy Simulation File", based on a discussion last year that included Kelly Parker and Philip Fairey.
Recommend that the Technical Committee adopt this definition so it is in place already when the QA Committee's changes are sent to public comment, and so the QA Committee does not have to change the definition again, possibly causing confusion. Best to naill down one definition as soon as possible.
Change the term "Rating Software file" to "Energy Simulation File" in new paragraph 904.4.1.3.5.
Add the following definition to Appendix B:
Energy Simulation File – The complete set of input data used by an accredited rating software tool to determine the Home Energy Rating for the specified home as listed in Section 102.1.4.110 of these Standards.
Comment #7Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 1Paragraph / Figure / Table / Note: 102.1.4.1Comment Type: GeneralComment:The latest version of the RESNET Standards, published on the RESENT website, is dated March 2, 2012. The title for 102.1.4.1 in the latest version is "Ratings from plan", not "Projected Ratings".Justification for Change:Need to be modifying the latest version of the Standards.Proposed Change:Confirm that proposed changes are to the most current version of the Standards.
The latest version of the RESNET Standards, published on the RESENT website, is dated March 2, 2012. The title for 102.1.4.1 in the latest version is "Ratings from plan", not "Projected Ratings".
Need to be modifying the latest version of the Standards.
Confirm that proposed changes are to the most current version of the Standards.
Comment #8Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 1-3Paragraph / Figure / Table / Note: GeneralComment Type: GeneralComment:I appreciate the goal of wanting to be more clear about the actual status of a rating that originated "from plans" which is then backed by testing and inspection data collected in the field. The same distinction is important for "projected ratings" on existing homes that are ultimately improved and then tested and inspected to confirm that the improvements were made. As I understand this amendment, in both instances the final rating will be called "confirmed" so long as the data collected in the field from testing and inspections is as good or better than the worst-case assumptions used in the computer modeling, i.e. no need to enter actual testing, inspection or home orientation data into the software. Makes sense and I agree. However, I believe that using the same rating name for homes with actual testing/inspection data and actual orientation as homes that have a final rating based on worst-case assumptions is problematic for two reasons. First, we are not providing any higher distinction, or distinction at all, for ratings that represent the actual/final/existing house. Some homeowners or builders may want that distinction, or you might even call it clarification, about their home. Second, when considering RESNET's new Registry, lumping actual with worst-case homes all together is going to come back to haunt RESNET when, not if, someone wants to look at the data and know which homes are which. There most definitely IS a difference between HERS Indexes and performance metrics for a home that is based on actual actual testng, inspection, and orientation data and one that is based on worst-case assumptions. It would be shortsighted of RESNET to ignore this difference for the two reasons just given, and probably even more reasons. Justification for Change:See comments.Proposed Change:It is not my preference to add terms, names or labels, but in this case I think that it is critically important. My recommendation is that we call ratings based on actual/final testing and inspections results collected from the field and the home's actual orientation "Actual Rating". There might be a better term, but this one seems as straight forward as it gets. Recommend that Chapter 1 be modified as necessary to accomodate the distinction between Projected, Confirmed and Actual ratings. Recommend that "303.7 Projected and Confirmed Ratings" be modified to "303.7 Projected, Confirmed and Actual Ratings" and then the necessary modifications/additions be made to this section to include Actual Rating. Recommend that a definition be added to Appendix B for Actual Rating. The QA Committee is in the middle of making substantial changes to Chapter 9. Much of the text proposed in this amendment for Chapter 9 has already been changed. However, whatever the final outcome from this amendment, the QA Committee will integrate so that the our proposed changes are consistent. Hopefully the final outcome includes these recommendations.
I appreciate the goal of wanting to be more clear about the actual status of a rating that originated "from plans" which is then backed by testing and inspection data collected in the field. The same distinction is important for "projected ratings" on existing homes that are ultimately improved and then tested and inspected to confirm that the improvements were made. As I understand this amendment, in both instances the final rating will be called "confirmed" so long as the data collected in the field from testing and inspections is as good or better than the worst-case assumptions used in the computer modeling, i.e. no need to enter actual testing, inspection or home orientation data into the software. Makes sense and I agree.
However, I believe that using the same rating name for homes with actual testing/inspection data and actual orientation as homes that have a final rating based on worst-case assumptions is problematic for two reasons. First, we are not providing any higher distinction, or distinction at all, for ratings that represent the actual/final/existing house. Some homeowners or builders may want that distinction, or you might even call it clarification, about their home. Second, when considering RESNET's new Registry, lumping actual with worst-case homes all together is going to come back to haunt RESNET when, not if, someone wants to look at the data and know which homes are which. There most definitely IS a difference between HERS Indexes and performance metrics for a home that is based on actual actual testng, inspection, and orientation data and one that is based on worst-case assumptions. It would be shortsighted of RESNET to ignore this difference for the two reasons just given, and probably even more reasons.
See comments.
It is not my preference to add terms, names or labels, but in this case I think that it is critically important. My recommendation is that we call ratings based on actual/final testing and inspections results collected from the field and the home's actual orientation "Actual Rating". There might be a better term, but this one seems as straight forward as it gets.
Recommend that Chapter 1 be modified as necessary to accomodate the distinction between Projected, Confirmed and Actual ratings.
Recommend that "303.7 Projected and Confirmed Ratings" be modified to "303.7 Projected, Confirmed and Actual Ratings" and then the necessary modifications/additions be made to this section to include Actual Rating.
Recommend that a definition be added to Appendix B for Actual Rating.
The QA Committee is in the middle of making substantial changes to Chapter 9. Much of the text proposed in this amendment for Chapter 9 has already been changed. However, whatever the final outcome from this amendment, the QA Committee will integrate so that the our proposed changes are consistent. Hopefully the final outcome includes these recommendations.
Comment #9Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 1Paragraph / Figure / Table / Note: 303.7.2Comment Type: TechnicalComment:Add reference to Chapter 8 testing procedures Sections 802 and 803 to align with the definitions sectionJustification for Change:Need to use the correct standards and proceduresProposed Change:Copy the wording from the definitions section for Confirmed Rating.
Add reference to Chapter 8 testing procedures Sections 802 and 803 to align with the definitions section
Need to use the correct standards and procedures
Copy the wording from the definitions section for Confirmed Rating.
Comment #10Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 1 - 2Paragraph / Figure / Table / Note: 303.7.2Comment Type: TechnicalComment:The section in parenthesis after the reference to chapter 3, states that default values for envelope leakage rates and distribution system efficiencies are allowed in a Confirmed Rating. I do not agree with this as a default value is not a confirmed value. Default values in a confirmed rating should be eliminated here and in the definitions section.Justification for Change:Default values are not confirmed values and do not belong in a confirmed rating.Proposed Change:Default values in a confirmed rating should be eliminated here and in the definitions section.
The section in parenthesis after the reference to chapter 3, states that default values for envelope leakage rates and distribution system efficiencies are allowed in a Confirmed Rating. I do not agree with this as a default value is not a confirmed value. Default values in a confirmed rating should be eliminated here and in the definitions section.
Default values are not confirmed values and do not belong in a confirmed rating.
Default values in a confirmed rating should be eliminated here and in the definitions section.
Comment #11Amendment: Proposed Amendment on Confirmed and Projected RatingsPage Number: 1-2Paragraph / Figure / Table / Note: 303.7.2Comment Type: TechnicalComment:If default values for envelope air leakage rates and distribution system efficiencies are allowed to be used to generate a Confirmed Rating for a home, then a HESP or BPA will be able to produce Confirmed Ratings on homes.Justification for Change:Does RESNET want certified homes that are produced by Raters or HESP/BPAs?Proposed Change:Eliminate the allowance for default values for envelope air leakage rates and distribution system efficiencies to be used to generate a Confirmed Rating for a home.
If default values for envelope air leakage rates and distribution system efficiencies are allowed to be used to generate a Confirmed Rating for a home, then a HESP or BPA will be able to produce Confirmed Ratings on homes.
Does RESNET want certified homes that are produced by Raters or HESP/BPAs?
Eliminate the allowance for default values for envelope air leakage rates and distribution system efficiencies to be used to generate a Confirmed Rating for a home.
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