Comment #1Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 3/4Paragraph / Figure / Table / Note: 102.1.4.7.3.6.5Comment Type: TechnicalComment: Rater’s who have their certification revoked may at their initiative re-apply for certification to any QA Provider as a Rater candidate after a period of no less than 180 days from the date of revocation provided the following conditions are met: Missing the required conditions Proposed Change: Rater’s who have their certification revoked may at their initiative re-apply for certification to any QA Provider as a Rater candidate after a period of no less than 180 days from the date of revocation provided the following conditions are met: No Conditions listed
Rater’s who have their certification revoked may at their initiative re-apply for certification to any QA Provider as a Rater candidate after a period of no less than 180 days from the date of revocation provided the following conditions are met: Missing the required conditions
Rater’s who have their certification revoked may at their initiative re-apply for certification to any QA Provider as a Rater candidate after a period of no less than 180 days from the date of revocation provided the following conditions are met: No Conditions listed
Comment #2Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 38055Paragraph / Figure / Table / Note: New YorkComment Type: TechnicalComment:Z2XZxf http://www.MHyzKpN7h4ERauvS72jUbdI0HeKxuZom.comProposed Change:Z2XZxf http://www.MHyzKpN7h4ERauvS72jUbdI0HeKxuZom.com
Comment #3Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: allComment Type: GeneralComment: RESNET is not following its own Standards Development Policy and Procedures Manual (Version 1.1, Technical Series 1.01, January 2, 2012). Section 4.1 of RESNET’s Standards Development Policy and Procedures Manual states “It is a Board decision to have the standards development process follow the ANSI Essential Requirements for ANSI accredited standards development organizations.” This is not really true as RESNET has more than once, including in this document, not followed RESNET or ANSI consensus process. If RESNET intends to have both consensus and non-consensus standards it should be careful not to have the consensus standards require any part of the non-consensus standards. As stated by ANSI in Section 4.4 of ANSI Essential Requirements: Due process requirements for American National Standards: “Portions of a published document that were not approved through the ANS consensus process shall not contain requirements necessary for conformance with the approved American National Standard (ANS) and shall be (1) clearly identified at the beginning and end of each such portion of the document, or (2) such information shall be overprinted on the cover page. These portions of the document shall be marked with the following, or similar, explanatory language: …: Proposed Change: Mark all non-consensus parts of the document as specified by Section 4.4 of ANSI Essential Requirements: Due process requirements for American National Standards: “The information contained in this (portion of a document) is not part of this American National Standard (ANS) and has not been processed in accordance with ANSI’s requirements for an ANS. As such, this (portion of a document) may contain material that has not been subjected to public review or a consensus process. In addition, it does not contain requirements necessary for conformance to the standard.”
RESNET is not following its own Standards Development Policy and Procedures Manual (Version 1.1, Technical Series 1.01, January 2, 2012).
Section 4.1 of RESNET’s Standards Development Policy and Procedures Manual states “It is a Board decision to have the standards development process follow the ANSI Essential Requirements for ANSI accredited standards development organizations.” This is not really true as RESNET has more than once, including in this document, not followed RESNET or ANSI consensus process.
If RESNET intends to have both consensus and non-consensus standards it should be careful not to have the consensus standards require any part of the non-consensus standards. As stated by ANSI in Section 4.4 of ANSI Essential Requirements: Due process requirements for American National Standards:
“Portions of a published document that were not approved through the ANS consensus process shall not contain requirements necessary for conformance with the approved American National Standard (ANS) and shall be (1) clearly identified at the beginning and end of each such portion of the document, or (2) such information shall be overprinted on the cover page. These portions of the document shall be marked with the following, or similar, explanatory language: …:
Mark all non-consensus parts of the document as specified by Section 4.4 of ANSI Essential Requirements: Due process requirements for American National Standards:
“The information contained in this (portion of a document) is not part of this American National Standard (ANS) and has not been processed in accordance with ANSI’s requirements for an ANS. As such, this (portion of a document) may contain material that has not been subjected to public review or a consensus process. In addition, it does not contain requirements necessary for conformance to the standard.”
Comment #4Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: allComment Type: GeneralComment: By its nature a quality assurance program should be somewhat independent of those it monitors for quality. With out a degree of independence the quality assurance role lacks integrity. RESNET already suffers from a reputation for spotty quality control. When combined with existing elements of RESNET, some parts of the proposed change contribute to that reputation and limit the effectiveness of the quality assurance role. RESNET is handicapping the credibility of the critical quality assurance role in several ways: 1) Requiring the RESNET Board of Directors approval for not only the committee chairs of the Quality Assurance and Ethics and Appeals committees (which is reasonable), but also even the committee membership nominations. If the board preferred certain problems not be brought to light, then this sets up an effective mechanism. Supporters of potential critics just never get on a committee. 2) The decision not to subject the development of the RESNET quality assurance process to the consensus process. It is ironic that RESNET did not follow the procedures in RESNET Standards Development Policy and Procedures Manual when developing its own oversight group. In general will RESNET follow its own rules when those rules become inconvenient? 3) Not specifying representatives for home owners or for those who are users of the various RESNET functions on the Quality Assurance and Ethics and Appeals committees. Development of this document will not pass the ANSI or RESNET tests for balance or lack of dominance by some parties. RESNET maybe entirely within its rules and procedures to reject this comment because it is not using the consensus process for the quality assurance standard; however, this will not reflect well on the “watchdog” function of the RESNET quality assurance process. If RESNET is fundamentally a trade association for those who sell the various services and functions associated with RESNET, then this all makes sense. A trade association can provide useful services. However, it retains a strong, perhaps even primary, interest in the financial gain of those whom it represents. If RESNET is fundamentally a public interest group that provides objective tools, processes and infrastructure that support an objective determination of a building’s energy efficiency then handicapping the quality assurance role the does not makes sense. Proposed Change: Restart the public process for comments. Abide by the ANSI and RESNET rules for a consensus process in developing RESNET standards, especially those elements having to do with quality assurance.
By its nature a quality assurance program should be somewhat independent of those it monitors for quality. With out a degree of independence the quality assurance role lacks integrity. RESNET already suffers from a reputation for spotty quality control. When combined with existing elements of RESNET, some parts of the proposed change contribute to that reputation and limit the effectiveness of the quality assurance role. RESNET is handicapping the credibility of the critical quality assurance role in several ways:
1) Requiring the RESNET Board of Directors approval for not only the committee chairs of the Quality Assurance and Ethics and Appeals committees (which is reasonable), but also even the committee membership nominations. If the board preferred certain problems not be brought to light, then this sets up an effective mechanism. Supporters of potential critics just never get on a committee. 2) The decision not to subject the development of the RESNET quality assurance process to the consensus process. It is ironic that RESNET did not follow the procedures in RESNET Standards Development Policy and Procedures Manual when developing its own oversight group. In general will RESNET follow its own rules when those rules become inconvenient? 3) Not specifying representatives for home owners or for those who are users of the various RESNET functions on the Quality Assurance and Ethics and Appeals committees.
Development of this document will not pass the ANSI or RESNET tests for balance or lack of dominance by some parties. RESNET maybe entirely within its rules and procedures to reject this comment because it is not using the consensus process for the quality assurance standard; however, this will not reflect well on the “watchdog” function of the RESNET quality assurance process.
If RESNET is fundamentally a trade association for those who sell the various services and functions associated with RESNET, then this all makes sense. A trade association can provide useful services. However, it retains a strong, perhaps even primary, interest in the financial gain of those whom it represents.
If RESNET is fundamentally a public interest group that provides objective tools, processes and infrastructure that support an objective determination of a building’s energy efficiency then handicapping the quality assurance role the does not makes sense.
Restart the public process for comments. Abide by the ANSI and RESNET rules for a consensus process in developing RESNET standards, especially those elements having to do with quality assurance.
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