Comment #1Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: AllComment Intent: ObjectionComment Type: GeneralComment: Before I start going through this document in full, I would like to point out that the way you've presented the Proposed Amendment THIS TIME is how it should have looked the FIRST TIME. I think it's incredibly disingenuous to present proposed changes to the RESNET Standards in two different ways, first without context of the full standards, and then showing the full context the second time but only allowing comments on the red, underlined, and/or struck through text. I understand it is not the committee's fault necessarily as they did not propose these standards, but before the first public comments on the original proposed changes went out some major editing should have been done. My major point with this comment: You should start the whole process over on these proposed changes, using the document you've uploaded THIS TIME to show the changes you made to the Standards. Not some half sentence, "...", incorrect numbering nonsense. An actual, complete set of clear, concise changes. Proposed Change: If you really want me to copy/paste the entire proposed standard into this box and strike-through it, I will. But, I think you understand my point, so I won't this time.
Before I start going through this document in full, I would like to point out that the way you've presented the Proposed Amendment THIS TIME is how it should have looked the FIRST TIME.
I think it's incredibly disingenuous to present proposed changes to the RESNET Standards in two different ways, first without context of the full standards, and then showing the full context the second time but only allowing comments on the red, underlined, and/or struck through text.
I understand it is not the committee's fault necessarily as they did not propose these standards, but before the first public comments on the original proposed changes went out some major editing should have been done.
My major point with this comment: You should start the whole process over on these proposed changes, using the document you've uploaded THIS TIME to show the changes you made to the Standards. Not some half sentence, "...", incorrect numbering nonsense. An actual, complete set of clear, concise changes.
If you really want me to copy/paste the entire proposed standard into this box and strike-through it, I will. But, I think you understand my point, so I won't this time.
Comment #2Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: There isn't a page numberParagraph / Figure / Table / Note: 205.2.3.4Comment Intent: ObjectionComment Type: GeneralComment: I have a big problem with the language of this text: "205.2.3 .4 A HERS Rater Candidate that does not complete, to the satisfaction of a Quality Assurance Provider, a minimum of three (3) of the five (5) required probationary ratings within twelve (12) months of passing the RESNET HERS Rater Tests, or otherwise does not achieve certification within the allowed twelve month timeframe, must at a minimum, do the following in order to maintain eligibility for certification:" Here's why: Some people are not HERS Raters primarily. Some are people who took the class to understand why buildings are the way they are. Some do it so they can do building inspections for cities- as it requires them to be listed in the public access RESNET Registry. So you're requiring that these people, who have no desire to actively perform HERS Ratings, who think performing HERS Ratings would drag their business model into the collective dirt, to at least do 3/5 of the probationary ratings (at a minimum). If they don't, they can't achieve a full certification, and then you make them do three additional probationary ratings and retake the HERS Rater test. I think that's a terrible idea. I understand the intent- you want people to explicitly be HERS Raters, who can perform a HERS Rating under the new, more stringent QA Standards. But you're ignoring the reality- that people don't really care about the certificate in order to do HERS Rating some times. They want it to do something else- because it costs too much to actively do HERS Raters. I think there should be a way to let them do that, but this will be too restrictive. I move to cut this section until we can figure out a less-heavy handed way to do what you meant to do. Proposed Change: 205.2.3 .4 A HERS Rater Candidate that does not complete, to the satisfaction of a Quality Assurance Provider, a minimum of three (3) of the five (5) required probationary ratings within twelve (12) months of passing the RESNET HERS Rater Tests, or otherwise does not achieve certification within the allowed twelve month timeframe, must at a minimum, do the following in order to maintain eligibility for certification: 205.2.3 .4.1 Pass the RESNET National Rater Test again; and 205.2.3 .4.2 Complete three (3) additional probationary ratings. One of the three (3) additional probationary ratings shall be a Confirmed Rating and be completed in the presence of a RESNET certified Candidate Field Assessor.
I have a big problem with the language of this text:
"205.2.3 .4 A HERS Rater Candidate that does not complete, to the satisfaction of a Quality Assurance Provider, a minimum of three (3) of the five (5) required probationary ratings within twelve (12) months of passing the RESNET HERS Rater Tests, or otherwise does not achieve certification within the allowed twelve month timeframe, must at a minimum, do the following in order to maintain eligibility for certification:"
Here's why:
Some people are not HERS Raters primarily. Some are people who took the class to understand why buildings are the way they are. Some do it so they can do building inspections for cities- as it requires them to be listed in the public access RESNET Registry.
So you're requiring that these people, who have no desire to actively perform HERS Ratings, who think performing HERS Ratings would drag their business model into the collective dirt, to at least do 3/5 of the probationary ratings (at a minimum).
If they don't, they can't achieve a full certification, and then you make them do three additional probationary ratings and retake the HERS Rater test.
I think that's a terrible idea. I understand the intent- you want people to explicitly be HERS Raters, who can perform a HERS Rating under the new, more stringent QA Standards.
But you're ignoring the reality- that people don't really care about the certificate in order to do HERS Rating some times. They want it to do something else- because it costs too much to actively do HERS Raters. I think there should be a way to let them do that, but this will be too restrictive.
I move to cut this section until we can figure out a less-heavy handed way to do what you meant to do.
205.2.3 .4 A HERS Rater Candidate that does not complete, to the satisfaction of a Quality Assurance Provider, a minimum of three (3) of the five (5) required probationary ratings within twelve (12) months of passing the RESNET HERS Rater Tests, or otherwise does not achieve certification within the allowed twelve month timeframe, must at a minimum, do the following in order to maintain eligibility for certification:
205.2.3 .4.1 Pass the RESNET National Rater Test again; and
205.2.3 .4.2 Complete three (3) additional probationary ratings. One of the three (3) additional probationary ratings shall be a Confirmed Rating and be completed in the presence of a RESNET certified Candidate Field Assessor.
Comment #3Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 7Paragraph / Figure / Table / Note: 206.1.3Comment Intent: ObjectionComment Type: TechnicalComment: It used to be a recertification option to simply re-take the HERS Rater test. Was that intentionally removed? I think that option should remain. Definitions describe the Job Werks HERS Rater assessment, but that option was deleted? Which assessment are you intending here?
It used to be a recertification option to simply re-take the HERS Rater test. Was that intentionally removed? I think that option should remain.
Definitions describe the Job Werks HERS Rater assessment, but that option was deleted? Which assessment are you intending here?
Comment #4Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 7Paragraph / Figure / Table / Note: 206.1Comment Intent: ObjectionComment Type: TechnicalComment: Every HERS Raters and RFI were required to demonstrate rating knowledge in their mentored ratings. Adding Jobwerks to the mix does not add any more real value to the process for RESNET Raters and this seems onerous and unnecessary to have this requirement. If a Rater is not performing their job according to the standards shouldn’t that be discovered during quality assurance process. Under that argument, having this evaluation every three years is too late. I propose removing this requirement of having it be every three years and add some real value to what could be a valuable tool to the industry and it’s stakeholders. The only time a rater should be required to have this type of assessment is if there is real value to the rater, builder, or stakeholders. I propose that RESNET and Jobwerks work together with other stakeholders that utilize the RESNET Standards to come up with a more robust assessment. Then in that case RESNET could make a claim that industry stakeholders need/require this evaluation. For example, ENERGY STAR has field verification requirements that not all HERS Raters have been evaluated on in the field. The written exam for Energy Star is not a great evaluation of how a rater can apply their knowledge of the program in a home. Since there is not an ENERGY STAR requirement for field training, having a jobwerks application for ENERGY STAR (and other EEPs) could be something that programs require of their partners. This is a real gap that is not addressed in the current proposal and could be a real value add to the Jobwerks program. If the ENERGY STAR program were to say they wanted to have a “Jobwerks for ENERGY STAR” assessment as a requirement for all raters participating in their program I think there is an argument that this would be valuable to the industry. Then ENERGY STAR (or insert LEED, ICC, etc.) may choose to do so and thus add value to the process. I think the ICC, ENERGY STAR, or others would be willing to work with RESNET to further develop this tool to gain confidence in the certification process of their verifiers. The point being is to let the market set the demand and simply have RESNET and jobwerks facilitate the process. Jobwerks has the potential to be a game changing tool for establishing industry confidence in the evaluation process of raters. Setting requirements that don’t have immediate value opens RESNET to criticism. Having actual demand from industry stakeholders who require the assessment based on current needs (unlike CAZ requirements for potential future needs) could help usher RESNET into a more smooth adoption of this system. If we view this like the ENERGY STAR Training a few years ago, where RESNET recognizes that training as qualifying for Professional Development and apply that same principle to the Jobwerks for <insert EEP or Code> then I think we’d have more widespread support for this initiative. Proposed Change: 206.1.2 Rating Field Inspectors 206.1.2.1 Pass the RESNET JobWerks RFI Assessment overseen by a RESNET certified Candidate Field Assessor once in a three year period. 206.1.3 2 Certified Home Energy Raters and Rating Field Inspectors 206.1.3 2.1 Pass one of the following professional development criteria : Attend a RESNET approved conference once every three years Or 18 hours of RESNET approved professional development from a RESNET Accredited Training Provider Or 206.1.3.2 Successfully complete one JobWerks assessment pertaining to an EEP or Code every three years
Every HERS Raters and RFI were required to demonstrate rating knowledge in their mentored ratings. Adding Jobwerks to the mix does not add any more real value to the process for RESNET Raters and this seems onerous and unnecessary to have this requirement. If a Rater is not performing their job according to the standards shouldn’t that be discovered during quality assurance process. Under that argument, having this evaluation every three years is too late.
I propose removing this requirement of having it be every three years and add some real value to what could be a valuable tool to the industry and it’s stakeholders. The only time a rater should be required to have this type of assessment is if there is real value to the rater, builder, or stakeholders. I propose that RESNET and Jobwerks work together with other stakeholders that utilize the RESNET Standards to come up with a more robust assessment. Then in that case RESNET could make a claim that industry stakeholders need/require this evaluation. For example, ENERGY STAR has field verification requirements that not all HERS Raters have been evaluated on in the field. The written exam for Energy Star is not a great evaluation of how a rater can apply their knowledge of the program in a home. Since there is not an ENERGY STAR requirement for field training, having a jobwerks application for ENERGY STAR (and other EEPs) could be something that programs require of their partners. This is a real gap that is not addressed in the current proposal and could be a real value add to the Jobwerks program. If the ENERGY STAR program were to say they wanted to have a “Jobwerks for ENERGY STAR” assessment as a requirement for all raters participating in their program I think there is an argument that this would be valuable to the industry. Then ENERGY STAR (or insert LEED, ICC, etc.) may choose to do so and thus add value to the process. I think the ICC, ENERGY STAR, or others would be willing to work with RESNET to further develop this tool to gain confidence in the certification process of their verifiers.
The point being is to let the market set the demand and simply have RESNET and jobwerks facilitate the process. Jobwerks has the potential to be a game changing tool for establishing industry confidence in the evaluation process of raters. Setting requirements that don’t have immediate value opens RESNET to criticism. Having actual demand from industry stakeholders who require the assessment based on current needs (unlike CAZ requirements for potential future needs) could help usher RESNET into a more smooth adoption of this system. If we view this like the ENERGY STAR Training a few years ago, where RESNET recognizes that training as qualifying for Professional Development and apply that same principle to the Jobwerks for <insert EEP or Code> then I think we’d have more widespread support for this initiative.
206.1.2 Rating Field Inspectors
206.1.2.1 Pass the RESNET JobWerks RFI Assessment overseen by a RESNET certified Candidate Field Assessor once in a three year period.
206.1.3 2 Certified Home Energy Raters and Rating Field Inspectors
206.1.3 2.1 Pass one of the following professional development criteria :
Attend a RESNET approved conference once every three years
Or
18 hours of RESNET approved professional development from a RESNET Accredited Training Provider
206.1.3.2 Successfully complete one JobWerks assessment pertaining to an EEP or Code every three years
Comment #5Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 2Paragraph / Figure / Table / Note: 202.2Comment Intent: Not an ObjectionComment Type: EditorialComment: This section references 912 when I believe it should reference 911. 912 is the appeal process of 911. This is according to the Mortgage Industry National Home Energy Rating Systems Standards dated January 1, 2013 & RESNET Standards - Advisory Version. . Proposed Change: Edit this section to reference the intended section in the standard.
This section references 912 when I believe it should reference 911. 912 is the appeal process of 911. This is according to the Mortgage Industry National Home Energy Rating Systems Standards dated January 1, 2013 & RESNET Standards - Advisory Version. .
Edit this section to reference the intended section in the standard.
Comment #6Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 2Paragraph / Figure / Table / Note: 202.2.1Comment Intent: Not an ObjectionComment Type: EditorialComment: This section references 911.3 when I believe it should reference 910.3. This is according to the Mortgage Industry National Home Energy Rating Systems Standards dated January 1, 2013 & RESNET Standards - Advisory Version. Proposed Change: Make edites to reference the intended section
This section references 911.3 when I believe it should reference 910.3. This is according to the Mortgage Industry National Home Energy Rating Systems Standards dated January 1, 2013 & RESNET Standards - Advisory Version.
Make edites to reference the intended section
Comment #7Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 2Paragraph / Figure / Table / Note: 202.2.4Comment Intent: ObjectionComment Type: GeneralComment: Why is it necessary for providers to maintain examinations and individual examination results when this is stored and saved in the RESNET testing database? Proposed Change: 202.2.4 Maintain records for three years of all training materials and trainee data, training schedules, curricula, and attendance records., examinations and individual examination results. This information shall be made available to RESNET upon request by RESNET.
Why is it necessary for providers to maintain examinations and individual examination results when this is stored and saved in the RESNET testing database?
202.2.4 Maintain records for three years of all training materials and trainee data, training schedules, curricula, and attendance records., examinations and individual examination results. This information shall be made available to RESNET upon request by RESNET.
Comment #8Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 5Paragraph / Figure / Table / Note: 205.2Comment Intent: Not an ObjectionComment Type: EditorialComment: The sections under 205.2 need to be properly indented. Proposed Change: Edit with proper idention.
The sections under 205.2 need to be properly indented.
Edit with proper idention.
Comment #9Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 6Paragraph / Figure / Table / Note: 205.2.3.1Comment Intent: ObjectionComment Type: TechnicalComment: his entire section requires a RESNET accredited Rating Quality Assurance Provider to confirm tasks. Shouldn’t that also include confirming that a HERS Rater candidate has taken training? Proposed Change: 205.2.3.1 Complete the following National RESNET HERS series of tests with the minimum (passing) scores to be determined by RESNET: 205.2.3.1.1 National HERS Rater Test 205.2.3.1.2 RESNET Combustion Appliance Simulation Test 205.2.3.1.3 RESNET Rater Simulation Practical Test 205.2.3.2 - Complete HERS Rater training with an accredited HERS Rater Training Provider including two (2) Practice Ratings in the presence of a RESNET certified Trainer.
his entire section requires a RESNET accredited Rating Quality Assurance Provider to confirm tasks. Shouldn’t that also include confirming that a HERS Rater candidate has taken training?
205.2.3.1 Complete the following National RESNET HERS series of tests with the minimum (passing) scores to be determined by RESNET:
205.2.3.1.1 National HERS Rater Test 205.2.3.1.2 RESNET Combustion Appliance Simulation Test 205.2.3.1.3 RESNET Rater Simulation Practical Test
205.2.3.2 - Complete HERS Rater training with an accredited HERS Rater Training Provider including two (2) Practice Ratings in the presence of a RESNET certified Trainer.
Comment #10Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 6Paragraph / Figure / Table / Note: 205.2.3 .4Comment Intent: ObjectionComment Type: GeneralComment: It would be more clear if the actual requirements were specifically listed out and not just general listed as RESNET HERS Rater Tests. Proposed Change: 205.2.3 .4 A HERS Rater Candidate that does not complete, to the satisfaction of a Quality Assurance Provider, a minimum of three (3) of the five (5) required probationary ratings within twelve (12) months of passing the National Rater Test and the RESNET CAZ Requirements RESNET HERS Rater Tests, or
It would be more clear if the actual requirements were specifically listed out and not just general listed as RESNET HERS Rater Tests.
205.2.3 .4 A HERS Rater Candidate that does not complete, to the satisfaction of a Quality Assurance Provider, a minimum of three (3) of the five (5) required probationary ratings within twelve (12) months of passing the National Rater Test and the RESNET CAZ Requirements RESNET HERS Rater Tests, or
Comment #11Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 7Paragraph / Figure / Table / Note: 206.1.3Comment Intent: ObjectionComment Type: GeneralComment: Why the requirement for attending a conference to get recertified? Why isn’t passing a jobwerks assessment enough? If QA finds no problems and the rater demonstrates they are capable of rating a house via jobwerks why the other requirement? Conferences are expensive and would be a financial burden on low volume raters. Proposed Change: 206.1.3 Certified Home Energy Raters 206.1.3.1 Attend a RESNET approved conference once every three years OR 18 hours of RESNET approved professional development from a RESNET Accredited Training Provider
Why the requirement for attending a conference to get recertified? Why isn’t passing a jobwerks assessment enough? If QA finds no problems and the rater demonstrates they are capable of rating a house via jobwerks why the other requirement? Conferences are expensive and would be a financial burden on low volume raters.
206.1.3 Certified Home Energy Raters 206.1.3.1 Attend a RESNET approved conference once every three years OR 18 hours of RESNET approved professional development from a RESNET Accredited Training Provider
Comment #12Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 3Paragraph / Figure / Table / Note: 203.2Comment Intent: Not an ObjectionComment Type: TechnicalComment: As written this section is not clear if CEUs earned above and beyond the 12 awarded for attending one RESNET Conference could be counted toward the 18 additional required CEUs. For example if an instructor attended the RESNET conference every year would they be able to count the 12 CEUs from each addituonal conference in the same three year period towards the other 18 CEUs required? Proposed Change: CLEAResult proposes allowing the additional CEUs from attending more than one RESNET conference in a 3 year period to be applied to the additional 18 required CEUs. Suggested language would be a 3rd bullet in this section stating: "Instructors who attend more than one RESNET Conference in the same three year certification period shall be allowed to count the additiuonal CEUs earned at the 2nd or 3rd conference attended to count toward the additional 18 CEUs reuired."
As written this section is not clear if CEUs earned above and beyond the 12 awarded for attending one RESNET Conference could be counted toward the 18 additional required CEUs. For example if an instructor attended the RESNET conference every year would they be able to count the 12 CEUs from each addituonal conference in the same three year period towards the other 18 CEUs required?
CLEAResult proposes allowing the additional CEUs from attending more than one RESNET conference in a 3 year period to be applied to the additional 18 required CEUs. Suggested language would be a 3rd bullet in this section stating:
"Instructors who attend more than one RESNET Conference in the same three year certification period shall be allowed to count the additiuonal CEUs earned at the 2nd or 3rd conference attended to count toward the additional 18 CEUs reuired."
Comment #13Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 6Paragraph / Figure / Table / Note: 205.2.3.4Comment Intent: Not an ObjectionComment Type: TechnicalComment: As written there is no time limit set on how long a rater would have to submit their 3 additional ratings once they re-tested. There should be a time limit a rater has after they fail the first time to certify within a year to submit additional ratings after re-testing. CLEAResult suggests 6 months would be a reasonable time limit. Proposed Change: 205.2.3.4.2 Complete three additional probationary ratings within six months of re-taking and passing the national test. One of the three additional probationary ratings shall be a confirmed rating and be complteted in the prescence of a RESNET certified Candidate Field Assessor.
As written there is no time limit set on how long a rater would have to submit their 3 additional ratings once they re-tested. There should be a time limit a rater has after they fail the first time to certify within a year to submit additional ratings after re-testing. CLEAResult suggests 6 months would be a reasonable time limit.
205.2.3.4.2 Complete three additional probationary ratings within six months of re-taking and passing the national test. One of the three additional probationary ratings shall be a confirmed rating and be complteted in the prescence of a RESNET certified Candidate Field Assessor.
Comment #14Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 7Paragraph / Figure / Table / Note: 206.1.3Comment Intent: Not an ObjectionComment Type: TechnicalComment: As written this section does not make it clear if a HERS rater is required to fulfill both requirements of this section or just one. Does a HERS rater need to collect 18 CEUs AND pass the JobWerks simulation every three years or does the rater need to collect 18 CEUs OR pass the JobWerks simulation every three years? CLEAResult would favor a HERS rater having to do one OR the other but not both. Being required to do both would add substantial cost to the re-certification process. Proposed Change: Suggested language would be to put the word "or" at the end of section 206.1.3.1.
As written this section does not make it clear if a HERS rater is required to fulfill both requirements of this section or just one. Does a HERS rater need to collect 18 CEUs AND pass the JobWerks simulation every three years or does the rater need to collect 18 CEUs OR pass the JobWerks simulation every three years?
CLEAResult would favor a HERS rater having to do one OR the other but not both. Being required to do both would add substantial cost to the re-certification process.
Suggested language would be to put the word "or" at the end of section 206.1.3.1.
Comment #15Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 3Paragraph / Figure / Table / Note: 203.2Comment Intent: Not an ObjectionComment Type: GeneralComment: It is our understanding that both elements of professional development included in this section are intended to be required. It is also our position that attendance at RESNET conferences be suitable to meet either requirement. Proposed Change: RESNET Certified Instructors shall complete a two-hour RESNET Roundtable on current information each year and also once every three years: Document twelve (12) hours of attendance at the RESNET conference or other conference approved by RESNET; and Complete eighteen (18) hours of RESNET approved Professional Development courses delivered by RESNET accredited Training Providers or other events or venues approved by RESNET. Additional documented hours of attendance at RESNET conferences qualify under this provision.
It is our understanding that both elements of professional development included in this section are intended to be required. It is also our position that attendance at RESNET conferences be suitable to meet either requirement.
RESNET Certified Instructors shall complete a two-hour RESNET Roundtable on current information each year and also once every three years:
Comment #16Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 6Paragraph / Figure / Table / Note: 205.2.3Comment Intent: Not an ObjectionComment Type: GeneralComment: Our proposed addition to this section is an attempt to clarify the meaning of the modified language in 205.2.3.4 and also to recognize that, for some Rater Candidates who have demonstrated progress, additional time to complete the process is needed and warranted. That time, should be defined and limited. In our opinion, an additional 6 months is appropriate. Proposed Change: 205.2.3.5 For a HERS Rater Candidate that has completed, to the satisfaction of a Quality Assurance Provider, a minimum of three (3), but less than (5) of the five (5) required probationary ratings within twelve (12) months of passing the RESNET HERS Rater Tests, an additional six (6) months will provided to successfully complete the remaining probationary ratings with no additional requirements.
Our proposed addition to this section is an attempt to clarify the meaning of the modified language in 205.2.3.4 and also to recognize that, for some Rater Candidates who have demonstrated progress, additional time to complete the process is needed and warranted. That time, should be defined and limited. In our opinion, an additional 6 months is appropriate.
205.2.3.5 For a HERS Rater Candidate that has completed, to the satisfaction of a Quality Assurance Provider, a minimum of three (3), but less than (5) of the five (5) required probationary ratings within twelve (12) months of passing the RESNET HERS Rater Tests, an additional six (6) months will provided to successfully complete the remaining probationary ratings with no additional requirements.
Comment #17Amendment: Proposed Amendment of Chapter 2 on Instruction, Assessment and CertificationPage Number: 7Paragraph / Figure / Table / Note: 206.1.3.1Comment Intent: Not an ObjectionComment Type: GeneralComment: Our proposed edit is an attempt to appropriately clarify the intent of the recertification requirements for Certified HERS Raters. Proposed Change: 206.1.3.1 Attend a RESNET approved conference once every threeyears OR18 hours of RESNET approved professional development from a RESNET Accredited Training provide; or
Our proposed edit is an attempt to appropriately clarify the intent of the recertification requirements for Certified HERS Raters.
206.1.3.1 Attend a RESNET approved conference once every threeyears OR18 hours of RESNET approved professional development from a RESNET Accredited Training provide; or
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