Proposed Amendment of Chapter 3 to Adopt ANSI/RESNET 301-2014

Comment #1

Amendment: Proposed Amendment of Chapter 3 to Adopt ANSI/RESNET 301-2014
Page Number: 1
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

Definitions shoudl not be added to Section 302.  All definitions in the Standards are organized alphabetically in Appendix B.

Proposed Change:

302 DEFINITIONS

Section 302 of the current Standard appropriately states "See Appendix B".  The definitions listed in the Amendment should be moved to the end of the Amendmente and labeled "Appendix B".  The paragraph at the beginning, i.e. "The following terms have specific meanings as used in this Standard. In the event that definitions given here differ from definitions given elsewhere, including those given in ANSI/RESNET 301-2014, the definitions given here shall govern," should perhaps be moved to the justification becuase it does not belong under 302 or in Appendix B.

Response:

Accept as modified.

Reason: It is critically important that the definitions provided in Section 302 remain in Section 302. ANSI/RESNET 301-2014 does not give RESNET explicit approval authority for accreditations and certifications of Rating Providers, certified raters, certified rating field inspectors. The definitions are specific to chapter 3 and will be located in both chapter 3 and Appendix B.


Comment #2

Amendment: Proposed Amendment of Chapter 3 to Adopt ANSI/RESNET 301-2014
Page Number: 2
Comment Intent: Not an Objection
Comment Type: General

Comment:

Request for clarification and modification of Paragraph 303.3.

Proposed Change:

It is not clear exactly what paragraph 303.3 does and does not allow.  Specifically, it is not clear if "projected ratings" can be printed without being sent to the Registry.  We can now, and need to in order to provide documentation for homebuilders which accompany their plans submittals for approval and subsequent issuance of building permits.  Assuming that printing of projected ratings will still be allowed, this should be explicitly stated in the 303.3. 

Response:

Reject

Reason: There is no reason or necessity to explicitly state everything a Standard allows; otherwise the list would be lengthy and subject to frequent change as new products and designs enter the market. The fact that Projected Ratings, which are authorized by the Standard, are not included in the provisions that require registration makes it sufficiently clear that Projected Ratings may be printed without being sent to the Registry..


Comment #3

Amendment: Proposed Amendment of Chapter 3 to Adopt ANSI/RESNET 301-2014
Page Number: 2
Comment Intent: Objection
Comment Type: Technical

Comment:

Questioning effective date.

Proposed Change:

I thought that all Standard Amendments could not be effective any sooner than 30 days after adoption.  The QA Changes adopted by the Board in December of 2013 could not go into effect on January 1st, as the QA Committee had hoped, for this reason.  How is that this Standard Amendment can be made effective immediately?

Response:

Reject

Reason: There is no explicit provision that prohibits a duly noticed standards action from becoming effective at any duly noticed time. If the amendment does not duly notice an effective date, RESNET policy is to make the effective date 30 days following approval; however, if an effective date is duly noticed in the amendment, there is no prohibition against any specific time period.


Comment #4

Amendment: Proposed Amendment of Chapter 3 to Adopt ANSI/RESNET 301-2014
Page Number: All
Comment Intent: Objection
Comment Type: General

Comment:

1) RESNET has an ANSI consensus process, “Standards Development Policy and Procedures Manual”.  RESNET should use that process.  Unless this is followed, RESNET should not claim the resulting document to be either consensus or non-proprietary.

2) As noted online, this comment solicitation “Applies to: 2006 Mortgage Industry National Home Energy Rating Systems Standards”
RESNET continues to use an ambiguous and incorrect document naming.  “2006”is the incorrect date.  This is 2014.  There are about 10 different documents I can find with that name.  The main document on the RESNET site does not have that date.
Resolution:  Give the document a proper name, version and date, then restart the public comment.

3) Specifying RESNET databases and processes is proprietary.  Specifying proprietary processes or products violates a major tenant of that ANSI consensus process.  As both ANSI and RESNET state “The appearance that a standard endorses any particular products, services or companies must be avoided.”  If this standard is intended to be proprietary, rather than consensus, then the proprietary nature is not an issue.  However, if this standard is intended to be a consensus standard for use by all, it cannot be proprietary.  RESNET has trademarked the term “HERS”, another attempt to be proprietary.
Resolution: Remove proprietary language.  Or agree that this standard is proprietary.

4) The reference to the Energy Policy Act of 1992 is unclear.  At a minimum this is 20 years late from the date of the required regulation.  That regulation is to be established by several entities including DOE, HUD, VA, and other home energy rating programs (others besides RESNET).  The RESNET standard does not meet that requirement.  Statements in RESNET documents do not make if compliant with the law, nor does it make the RESNET standard a requirement of the law.

Response:

Reject

Reason:    RESNET does not contend that its standards provide compliance with EPAct 92, rather it simply states in the Purpose for Chapter 3 of its MINHERS Standard that it is the intent of RESNET to be consistent with the provisions of EPAct 92 with respect to voluntary home energy ratings.


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