Comment #1Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 1Paragraph / Figure / Table / Note: 102.1.4.10Comment Type: EditorialComment: The current version of the RESNET Standards posted on the RESNET website (dated 1-1-13) indicate that the Section being amended is actually 102.1.4.8. The Proposed Amendments to Chapter 1 from the QA Committee, currently which will not be completed for several months, are renumbering 102.1.4.8 to be 102.1.4.10. However, becuase it is likely that this amendment will be approved by the RESNET Board prior to the QA Committee's amendments, I recommend that this amendment be to 102.1.4.8 rather than 102.1.4.10. Proposed Change: Change Amendment from Section 102.1.4.10 to Section 102.1.4.8. Response: Rejected. While it may not have been clear in the original proposal, the amendment proposes to modify Addendum 3 of the currently existing standards, for which the Section numbers are correctly cited.
The current version of the RESNET Standards posted on the RESNET website (dated 1-1-13) indicate that the Section being amended is actually 102.1.4.8. The Proposed Amendments to Chapter 1 from the QA Committee, currently which will not be completed for several months, are renumbering 102.1.4.8 to be 102.1.4.10. However, becuase it is likely that this amendment will be approved by the RESNET Board prior to the QA Committee's amendments, I recommend that this amendment be to 102.1.4.8 rather than 102.1.4.10.
Change Amendment from Section 102.1.4.10 to Section 102.1.4.8.
Rejected. While it may not have been clear in the original proposal, the amendment proposes to modify Addendum 3 of the currently existing standards, for which the Section numbers are correctly cited.
Comment #2Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 1Comment Type: GeneralComment: I have a few questions. It states that the "Home Energy Rating Provider shall maintain this registry in accordance with policies and procedures established by RESNET". Does this mean that we will need to manually log all of the information described after this onto a spreadsheet. We already have this information on the website, and it is automatically pulled from the rating file. Also, we keep all of our rating files and supporting documentation on file here at our office. Next question, does this mean that every Rating Certificate created, whether printed out of Rem Rate or not, will require the rating file id# to be printed by the HERS Index. What about address labels that go in the panel from ENERGY STAR? With these going on a National Registry, and the address / rating file number. Is this going to allow homeowner, in perpetuity (meaning every time a home is sold the new owner), gets access to the rating file itself. We don't have anything to hid, but I am not a fan of giving informaiton that can be used or misconstrued in a manner to attack the builder. We do engineering, and stand behind our work, but we don't upload auto cad files to be reviewed. I just want to be real caucious and understand completely what we are agreeing to. Also, I would like to state that we have been adding files to the registry since last year, so we are complying. I just want to know who has access to the information, and what is it used for? I know that RESNET needs it as part of the QA process, and that I understand. My question would be, what else... Response: Rejected. There is no proposed change by the commenter. Paragraph 102.1.4.10 will be revised to improve clarity of RESNET and Provider responsibilities per comment #8.
I have a few questions.
It states that the "Home Energy Rating Provider shall maintain this registry in accordance with policies and procedures established by RESNET".
Does this mean that we will need to manually log all of the information described after this onto a spreadsheet. We already have this information on the website, and it is automatically pulled from the rating file. Also, we keep all of our rating files and supporting documentation on file here at our office.
Next question, does this mean that every Rating Certificate created, whether printed out of Rem Rate or not, will require the rating file id# to be printed by the HERS Index. What about address labels that go in the panel from ENERGY STAR?
With these going on a National Registry, and the address / rating file number. Is this going to allow homeowner, in perpetuity (meaning every time a home is sold the new owner), gets access to the rating file itself. We don't have anything to hid, but I am not a fan of giving informaiton that can be used or misconstrued in a manner to attack the builder. We do engineering, and stand behind our work, but we don't upload auto cad files to be reviewed. I just want to be real caucious and understand completely what we are agreeing to.
Also, I would like to state that we have been adding files to the registry since last year, so we are complying. I just want to know who has access to the information, and what is it used for? I know that RESNET needs it as part of the QA process, and that I understand. My question would be, what else...
Rejected. There is no proposed change by the commenter. Paragraph 102.1.4.10 will be revised to improve clarity of RESNET and Provider responsibilities per comment #8.
Comment #3Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: allComment Type: GeneralComment: In a couple of locations, the revisions say that the Home Energy Rating Provider shall "maintain the registry." First, it is not at all clear what is meant by "maintain the registry." Second, it should be RESNET that maintains the Registry. The Provider's responsibility should end when it uploads the required files. How can a Provider be expected to maintain a national Registry which is being contributed to by all the other Providers? It's more a question of semantics, but it needs to be clarified that RESNET will be maintaining the Registry. Response: Rejected. There is no proposed change by the commenter. Paragraph 102.1.4.10 will be revised to improve clarity of RESNET and Provider responsibilities per comment #8.
In a couple of locations, the revisions say that the Home Energy Rating Provider shall "maintain the registry." First, it is not at all clear what is meant by "maintain the registry." Second, it should be RESNET that maintains the Registry. The Provider's responsibility should end when it uploads the required files. How can a Provider be expected to maintain a national Registry which is being contributed to by all the other Providers? It's more a question of semantics, but it needs to be clarified that RESNET will be maintaining the Registry.
Comment #4Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 1Paragraph / Figure / Table / Note: 102.1.4.10.1 a) 8)Comment Type: GeneralComment: This is a comment from the NEHERS Alliance QAD Committee. The NEHERS represents 17 Providers in the Northeast. "8) Home Type (single-family, duplex, low-rise Multi-family, high-rise Multi-family)" This implies that "high-rise Multi-family" is an acceptable Rating type and should be uploaded to the National RESNET Registry. It is our understanding that high-rise multifamily buildings (on the unit level or whole building level) are not Ratings and should not be included in the Registry. We recomend removing "high-rise Multi-family" from this standard. Proposed Change: 102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include: a) The Rated Home characteristics, including but not limited to the following: 1) Physical location of the home, including street address, city, state and zip code 2) IECC climate zone of the home 3) Certified Rater ID 4) Accredited Rating Provider ID 5) Date of the Rating 6) Status of the Rated Home (new or existing) 7) Rating Type for the home (confirmed or sampled) 8) Home Type (single-family, duplex, low-rise Multi-family, high-rise Multi-family) Response: Accepted. Improves clarity of the provision. High-Rise Multi-family shall be stricken from the Home Type list given is Section 102.1.4.10.1a)8.
This is a comment from the NEHERS Alliance QAD Committee. The NEHERS represents 17 Providers in the Northeast.
"8) Home Type (single-family, duplex, low-rise Multi-family, high-rise Multi-family)"
This implies that "high-rise Multi-family" is an acceptable Rating type and should be uploaded to the National RESNET Registry. It is our understanding that high-rise multifamily buildings (on the unit level or whole building level) are not Ratings and should not be included in the Registry.
We recomend removing "high-rise Multi-family" from this standard.
102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include: a) The Rated Home characteristics, including but not limited to the following: 1) Physical location of the home, including street address, city, state and zip code 2) IECC climate zone of the home 3) Certified Rater ID 4) Accredited Rating Provider ID 5) Date of the Rating 6) Status of the Rated Home (new or existing) 7) Rating Type for the home (confirmed or sampled) 8) Home Type (single-family, duplex, low-rise Multi-family, high-rise Multi-family)
Accepted. Improves clarity of the provision. High-Rise Multi-family shall be stricken from the Home Type list given is Section 102.1.4.10.1a)8.
Comment #5Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 2Paragraph / Figure / Table / Note: 102.3.4.10.2 b)Comment Type: EditorialComment: 102.3.4.10.2 b) "All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for Home Energy Ratings that are submitted to the RESNET Registry." Please clarify that this is not stating the QA requirements "are met or exceeded" prior to upload. It is not clear that QA can be met or exceeded AFTER the rating is entered into the registry. Often the 10% file QA and 1% field QA takes place after a Rating has already been registered. Proposed Change: All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for are applicable to all Home Energy Ratings that are submitted to the RESNET Registry. OR All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for are applicable to aAll Home Energy Ratings that are submitted to the RESNET Registry are subject to the Quality Assurance controls that are required by National RESNET Standards. Response: Accepted as Modified. The provision in question will be modified as follows: “b) All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for Home Energy Ratings that are submitted to listed in the RESNET Registry.”
102.3.4.10.2 b) "All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for Home Energy Ratings that are submitted to the RESNET Registry."
Please clarify that this is not stating the QA requirements "are met or exceeded" prior to upload. It is not clear that QA can be met or exceeded AFTER the rating is entered into the registry. Often the 10% file QA and 1% field QA takes place after a Rating has already been registered.
All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for are applicable to all Home Energy Ratings that are submitted to the RESNET Registry.
OR
All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for are applicable to aAll Home Energy Ratings that are submitted to the RESNET Registry are subject to the Quality Assurance controls that are required by National RESNET Standards.
Accepted as Modified. The provision in question will be modified as follows:
“b) All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for Home Energy Ratings that are submitted to listed in the RESNET Registry.”
Comment #6Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 1Paragraph / Figure / Table / Note: 102.3.4.10.2 a) 9)Comment Type: TechnicalComment: Conditioned Area of the home is listed in section 102.3.4.10.2 a) 9) as a minimum requirement for information uploaded to the Registry. We assume this is "Conditioned Floor Area" which is what is input in the software we use. If so, please state this explicitly to avoid confusion. Proposed Change: 102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include: a) The Rated Home characteristics, including but not limited to the following: 1) Physical location of the home, including street address, city, state and zip code 2) IECC climate zone of the home 3) Certified Rater ID 4) Accredited Rating Provider ID 5) Date of the Rating 6) Status of the Rated Home (new or existing) 7) Rating Type for the home (confirmed or sampled) 8) Home Type (single-family, duplex, low-rise Multi-family, high-rise Multi-family) 9) Conditioned Floor area of the home Response: Accepted. Improves clarity of the provision. Section 102.3.4.10.2 a) 9) will be revised to specify the “Conditioned Floor Area” of the home.
Conditioned Area of the home is listed in section 102.3.4.10.2 a) 9) as a minimum requirement for information uploaded to the Registry. We assume this is "Conditioned Floor Area" which is what is input in the software we use. If so, please state this explicitly to avoid confusion.
102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include: a) The Rated Home characteristics, including but not limited to the following: 1) Physical location of the home, including street address, city, state and zip code 2) IECC climate zone of the home 3) Certified Rater ID 4) Accredited Rating Provider ID 5) Date of the Rating 6) Status of the Rated Home (new or existing) 7) Rating Type for the home (confirmed or sampled) 8) Home Type (single-family, duplex, low-rise Multi-family, high-rise Multi-family) 9) Conditioned Floor area of the home
Accepted. Improves clarity of the provision. Section 102.3.4.10.2 a) 9) will be revised to specify the “Conditioned Floor Area” of the home.
Comment #7Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 1Paragraph / Figure / Table / Note: 102.3.4.10.2 a) 9)Comment Type: TechnicalComment: Conditioned Area of the home is listed in section 102.3.4.10.2 a) 9) as a minimum requirement for information uploaded to the Registry. We assume this is "Conditioned Floor Area" which is what is input in the software we use. If so, please state this explicitly to avoid confusion. Proposed Change: 102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include: a) The Rated Home characteristics, including but not limited to the following: 1) Physical location of the home, including street address, city, state and zip code 2) IECC climate zone of the home 3) Certified Rater ID 4) Accredited Rating Provider ID 5) Date of the Rating 6) Status of the Rated Home (new or existing) 7) Rating Type for the home (confirmed or sampled) 8) Home Type (single-family, duplex, low-rise Multi-family, high-rise Multi-family) 9) Conditioned Floor area of the home Response: Accepted. Improves clarity of the provision. Section 102.3.4.10.2 a) 9) will be revised to specify the “Conditioned Floor Area” of the home.
Comment #8Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 2Paragraph / Figure / Table / Note: 102.1.4.10.2 c)Comment Type: GeneralComment: 4) 102.1.4.10.1 "c) An executable copy of the building input file used by the accredited software rating tool to generate the Home Energy Rating." Is this in addition to the upload already in place? Will the entire Rating file be sent to the Registry? Is it already? Please clarify what information is being pulled into the Registry at the moment. This list in the standard states "At a minimum, the National RESNET Registry shall include". This is a question of confidentiality. It may be solved by adding language to this standard to clarify the confidentiality of the submitted information. Proposed Change: Please add language clarifying the confidentiality of the submitted Rating information. Who sees this information? Response: Rejected. No proposed change was presented by the commentator. However, the question of confidentiality of information presented to the Registry is substantive and is being addressed. The table of authorizations for who is allowed to view or obtain data from the National RESNET Registry is the subject of another set of RESNET Policy provisions being prepared by the RESNET Quality Assurance Committee that will be voted separately by the RESNET Board. There will be a future opportunity to review and comment on this issue.
4) 102.1.4.10.1 "c) An executable copy of the building input file used by the accredited software rating tool to generate the Home Energy Rating."
Is this in addition to the upload already in place? Will the entire Rating file be sent to the Registry? Is it already?
Please clarify what information is being pulled into the Registry at the moment. This list in the standard states "At a minimum, the National RESNET Registry shall include".
This is a question of confidentiality. It may be solved by adding language to this standard to clarify the confidentiality of the submitted information.
Please add language clarifying the confidentiality of the submitted Rating information. Who sees this information?
Rejected. No proposed change was presented by the commentator. However, the question of confidentiality of information presented to the Registry is substantive and is being addressed. The table of authorizations for who is allowed to view or obtain data from the National RESNET Registry is the subject of another set of RESNET Policy provisions being prepared by the RESNET Quality Assurance Committee that will be voted separately by the RESNET Board. There will be a future opportunity to review and comment on this issue.
Comment #9Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 1Paragraph / Figure / Table / Note: 102.1.4.10Comment Type: GeneralComment: Proposed language states, "The Home Energy Rating Provider shall maintain this Registry in accordance with policies and procedures established by RESNET." I think RESNET should "maintain" this registry and that the HERS Provider shall input data compliant with RESNET Policies and Procedures into the database. Proposed Change: Therefore, I propose the language to read, "...using the National RESNET Registry. RESNET shall maintain this registry. The Home Energy Rating Provider shall input data into this Registry in accordance with policies and procedures established by RESNET." Response: Accepted as modified. Paragraph 102.1.4.10 also seemed to confuse several commentators regarding the responsibility of RESNET to maintain the National RESNET “Registry” and the Provider’s responsibility to maintain a current and up-to-date “registry” of it certified raters and home ratings conducted under its authority within the National RESNET Registry. The paragraph has been rewritten as follows to clarify the responsibilities and the commentator’s comment was integrated into the rewrite. Delete to following in its entirety: 102.1.4.10 Registries National RESNET Registry. The Home Energy Rating Provider shall maintain a current and accurate registry of all of its Raters and all Home Energy Ratings conducted under the auspices of such Home Energy Rating Provider using the RESNET National Buildings RESNET Registry. The Home Energy Rating Provider will shall maintain this Registry in accordance with policies and procedures established by RESNET related to the RESNET Buildings Registry. Insert: “102.1.4.10 National RESNET Registry. The National RESNET Registry shall be maintained by RESNET and made available for use by accredited Home Energy Rating Providers, their certified Raters and other parties in accordance with RESNET Board policy. Each accredited Home Energy Rating Provider shall be included in the National RESNET Registry. Each accredited Home Energy Rating Provider shall be responsible for maintaining a current and accurate listing of their Certified Raters using the National RESNET Registry. Each accredited Home Energy Rating Provider shall be responsible for registering each Home Energy Rating conducted under the auspices of said Home Energy Rating Provider in the National RESNET Registry in accordance with Sections 102.1.4.10.1 and 102.4.10.2.”
Proposed language states, "The Home Energy Rating Provider shall maintain this Registry in accordance with policies and procedures established by RESNET."
I think RESNET should "maintain" this registry and that the HERS Provider shall input data compliant with RESNET Policies and Procedures into the database.
Therefore, I propose the language to read, "...using the National RESNET Registry. RESNET shall maintain this registry. The Home Energy Rating Provider shall input data into this Registry in accordance with policies and procedures established by RESNET."
Accepted as modified. Paragraph 102.1.4.10 also seemed to confuse several commentators regarding the responsibility of RESNET to maintain the National RESNET “Registry” and the Provider’s responsibility to maintain a current and up-to-date “registry” of it certified raters and home ratings conducted under its authority within the National RESNET Registry. The paragraph has been rewritten as follows to clarify the responsibilities and the commentator’s comment was integrated into the rewrite.
Delete to following in its entirety: 102.1.4.10 Registries National RESNET Registry. The Home Energy Rating Provider shall maintain a current and accurate registry of all of its Raters and all Home Energy Ratings conducted under the auspices of such Home Energy Rating Provider using the RESNET National Buildings RESNET Registry. The Home Energy Rating Provider will shall maintain this Registry in accordance with policies and procedures established by RESNET related to the RESNET Buildings Registry.
Insert: “102.1.4.10 National RESNET Registry. The National RESNET Registry shall be maintained by RESNET and made available for use by accredited Home Energy Rating Providers, their certified Raters and other parties in accordance with RESNET Board policy. Each accredited Home Energy Rating Provider shall be included in the National RESNET Registry. Each accredited Home Energy Rating Provider shall be responsible for maintaining a current and accurate listing of their Certified Raters using the National RESNET Registry. Each accredited Home Energy Rating Provider shall be responsible for registering each Home Energy Rating conducted under the auspices of said Home Energy Rating Provider in the National RESNET Registry in accordance with Sections 102.1.4.10.1 and 102.4.10.2.”
Comment #10Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 1Paragraph / Figure / Table / Note: 102.1.4.10.1Comment Type: GeneralComment: "Minimum Requirements. At a minimum, the National RESNET Registry shall include:" Given that the RESNET approved modeling software already includes this information, I propose that the modeling software export the same minimum information proposed into the Registry without the HERS Provider having to transfer every item individually into the Registry. Proposed Change: "Minimum Requirements. At a minimum, the RESNET approved energy modeling software used by the HERS Provider shall be capable of exporting the following information into the Registry:" Response: Rejected. Whether an accredited software tool automatically complies with the provision of the standard is not germane to the standards language that specifies the minimum requirements of the standard.
"Minimum Requirements. At a minimum, the National RESNET Registry shall include:"
Given that the RESNET approved modeling software already includes this information, I propose that the modeling software export the same minimum information proposed into the Registry without the HERS Provider having to transfer every item individually into the Registry.
"Minimum Requirements. At a minimum, the RESNET approved energy modeling software used by the HERS Provider shall be capable of exporting the following information into the Registry:"
Rejected. Whether an accredited software tool automatically complies with the provision of the standard is not germane to the standards language that specifies the minimum requirements of the standard.
Comment #11Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 2Paragraph / Figure / Table / Note: 102.1.4.12Comment Type: GeneralComment: Proposed comment, "All Home Energy Rating Providers shall collect and upload the Energy Simulation File for each home rated by each Certified Rater..." Proposed Change: What is the difference between the "Energy Simulation File" and the "Approved Software Tool" stated in the standards? Is these are the same, I propose to true up the language. If these are difference items, then I propose to add a description of this "Energy Simulation File" to the standard's "glossary of terms". Response: Accepted as Modified. To maintain consistency with the terminology used in Section 102.1.4.10.1c) and avoid the need to define a new term, the beginning of Section 102.1.4.12 will be revised as follows: “All Home Energy Rating Providers shall collect and upload an executable copy of the building input file used by the accredited software rating tool to generate the Home Energy Rating for each home rated by each Certified Rater….”
Proposed comment, "All Home Energy Rating Providers shall collect and upload the Energy Simulation File for each home rated by each Certified Rater..."
What is the difference between the "Energy Simulation File" and the "Approved Software Tool" stated in the standards? Is these are the same, I propose to true up the language. If these are difference items, then I propose to add a description of this "Energy Simulation File" to the standard's "glossary of terms".
Accepted as Modified. To maintain consistency with the terminology used in Section 102.1.4.10.1c) and avoid the need to define a new term, the beginning of Section 102.1.4.12 will be revised as follows: “All Home Energy Rating Providers shall collect and upload an executable copy of the building input file used by the accredited software rating tool to generate the Home Energy Rating for each home rated by each Certified Rater….”
Comment #12Amendment: Proposed RESNET National Buildings Registry AmendmentPage Number: 1Paragraph / Figure / Table / Note: 102.1.4.10.1Comment Type: GeneralComment: Most of the changes seem pretty straight forward and make sense. Would possibly be interested in one minor addition. Proposed Change: In the section mentioned above: Would like to add somewhere some sort of "Date Processed by Provider" or something along those lines. This would be to track and compare to provider records when things were processed for QA purposes. The "Date of Rating" does not fully suffice for this purpose. It could have been completed one quarter, but not certified or processed by the provider until the next quarter comes around. Also, it could have happened a long time ago, but if it had to be uploaded in order for something to be printed, it cannot be listed by upload date either. The wording on the additional field may not be correct, but it could be helpful in terms of quarterly tracking and more accurate QA records. Response: Rejected. The date that a rating is processed by the Provider is a function performed by the National RESNET Registry and cannot be left to the Provider’s discretion.
Most of the changes seem pretty straight forward and make sense. Would possibly be interested in one minor addition.
In the section mentioned above:
Would like to add somewhere some sort of "Date Processed by Provider" or something along those lines.
This would be to track and compare to provider records when things were processed for QA purposes. The "Date of Rating" does not fully suffice for this purpose. It could have been completed one quarter, but not certified or processed by the provider until the next quarter comes around. Also, it could have happened a long time ago, but if it had to be uploaded in order for something to be printed, it cannot be listed by upload date either.
The wording on the additional field may not be correct, but it could be helpful in terms of quarterly tracking and more accurate QA records.
Rejected. The date that a rating is processed by the Provider is a function performed by the National RESNET Registry and cannot be left to the Provider’s discretion.
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