Comment #1Amendment: Proposed Amendment to Section 1004.2 of the MINHERS StandardsPage Number: 1Comment Intent: Not an ObjectionComment Type: GeneralComment: I concur. Pulaski Technical College is and approved Rater Training Provider and an example of an excluded organization as currently written. Proposed Change: Strike as proposed.
I concur. Pulaski Technical College is and approved Rater Training Provider and an example of an excluded organization as currently written.
Strike as proposed.
Comment #2Amendment: Proposed Amendment to Section 1004.2 of the MINHERS StandardsPage Number: 1Comment Intent: Not an ObjectionComment Type: GeneralComment: Agree with propsed amendment. Proposed Change: None.
Agree with propsed amendment.
None.
Comment #3Amendment: Proposed Amendment to Section 1004.2 of the MINHERS StandardsPage Number: 1Comment Intent: Not an ObjectionComment Type: TechnicalComment: As a Rating QA Provider and a CEQ Provider I agree with the intent of this amendment. However, there are several questions that this raises regarding the role of the Rating QA Provider's QA Designee and additional workload as well as the potential increase of required rate of quality assurance placed on the Rater. The standard places a heavy burden of QA over the EnergySmart Contractor and EnergySmart Team as well as the involved HERS Rater or BPA on the Rating QA Provider QAD. The standard also places a minimum QA review targeted specifically at a percentage rate considering only the HERS Rater's EnergySmart Projects. Also, the standards place a burden of record-keeping on the Rating Provider for documentation of the EnergySmart Project that is above and beyond that which is necessary to provide QA review of the HERS Rater's work. This documentation includes program sponsor information, copy of the signed proposal, and contact information for the EnergySmart contractors. If the CEQ Provider is also required to be a Rating QA Provider, then the membership of the EnergySmart Team members helps to offset the cost of the additional QA and record-keeping. I have no objection to removing that requirement, however, I believe that the QA of the EnergySmart Team must fall on the CEQ Provider meaning that there needs to be a CEQ QA Designee role created and the QA work specific to oversight of the quality of the EnergySmart Team must fall within that role. From a Rating QA Provider perspective, the EnergySmart project should be considered as any other EEP and when QA is performed on a Rater's involvement in such a project it would include the requirement of a comprehensive Rating Data File as required in the standards. If a minimum percentage of EnergySmart projects is to have QA performed, the CEQ QAD should be responsible to perform that QA. Proposed Change: New: Create a requirement for CEQ Providers to maintain a QA Designee. 1006.5 Rating Provider Quality Assurance Review of Rater Final Verification of EnergySmart Projects Rework this section to be specific to the CEQ Provider QAD responsibilities for quality oversight of the EnergySmart Team. The Rating Provider's QAD and Rater's QA requirements would remain as they are directed in Chapter 9.
As a Rating QA Provider and a CEQ Provider I agree with the intent of this amendment. However, there are several questions that this raises regarding the role of the Rating QA Provider's QA Designee and additional workload as well as the potential increase of required rate of quality assurance placed on the Rater.
The standard places a heavy burden of QA over the EnergySmart Contractor and EnergySmart Team as well as the involved HERS Rater or BPA on the Rating QA Provider QAD. The standard also places a minimum QA review targeted specifically at a percentage rate considering only the HERS Rater's EnergySmart Projects. Also, the standards place a burden of record-keeping on the Rating Provider for documentation of the EnergySmart Project that is above and beyond that which is necessary to provide QA review of the HERS Rater's work. This documentation includes program sponsor information, copy of the signed proposal, and contact information for the EnergySmart contractors.
If the CEQ Provider is also required to be a Rating QA Provider, then the membership of the EnergySmart Team members helps to offset the cost of the additional QA and record-keeping. I have no objection to removing that requirement, however, I believe that the QA of the EnergySmart Team must fall on the CEQ Provider meaning that there needs to be a CEQ QA Designee role created and the QA work specific to oversight of the quality of the EnergySmart Team must fall within that role.
From a Rating QA Provider perspective, the EnergySmart project should be considered as any other EEP and when QA is performed on a Rater's involvement in such a project it would include the requirement of a comprehensive Rating Data File as required in the standards. If a minimum percentage of EnergySmart projects is to have QA performed, the CEQ QAD should be responsible to perform that QA.
New: Create a requirement for CEQ Providers to maintain a QA Designee.
1006.5 Rating Provider Quality Assurance Review of Rater Final Verification of EnergySmart Projects
Rework this section to be specific to the CEQ Provider QAD responsibilities for quality oversight of the EnergySmart Team. The Rating Provider's QAD and Rater's QA requirements would remain as they are directed in Chapter 9.
Comment #4Amendment: Proposed Amendment to Section 1004.2 of the MINHERS StandardsPage Number: 1Comment Intent: ObjectionComment Type: TechnicalComment: I cannot imagine that an insurance provider, either general or professional liability, will insure a RESNET QA provider for the inherent liability involved in accepting another CEQ providers training, certification, teams and/or projects without question. The 1004.2 Amendment stipulates that a CEQ Provider does not have to be a RESNET QA Provider, and yet the QA Provider assumes ALL the liability for a rater's CEQ credentials and projects undertaken by another CEQ Provider. This is the very essence of "Blind Liability" and no insurer that I know of will accept the liability for a certification process or projects undertaken by another entity that the QA provider has no first-hand knowledge about or may not even have any details about the project whatsoever. If you can find an insurer who is willing to underwrite an insurance policy that includes all the liability for another provider's actions, and their raters, and their certified contractors, and their material suppliers and all the other peripheral players who can be involved in an energy retrofit project, then please tell me because I would like to know who they are. Proposed Change: My recommendation is to reject this Amendment in its entirety. This surely will be a 'no-go' with insurance providers across the country. Without the proper insurance, no provider can remain in business.
I cannot imagine that an insurance provider, either general or professional liability, will insure a RESNET QA provider for the inherent liability involved in accepting another CEQ providers training, certification, teams and/or projects without question. The 1004.2 Amendment stipulates that a CEQ Provider does not have to be a RESNET QA Provider, and yet the QA Provider assumes ALL the liability for a rater's CEQ credentials and projects undertaken by another CEQ Provider. This is the very essence of "Blind Liability" and no insurer that I know of will accept the liability for a certification process or projects undertaken by another entity that the QA provider has no first-hand knowledge about or may not even have any details about the project whatsoever.
If you can find an insurer who is willing to underwrite an insurance policy that includes all the liability for another provider's actions, and their raters, and their certified contractors, and their material suppliers and all the other peripheral players who can be involved in an energy retrofit project, then please tell me because I would like to know who they are.
My recommendation is to reject this Amendment in its entirety. This surely will be a 'no-go' with insurance providers across the country. Without the proper insurance, no provider can remain in business.
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