Review of Addendum B to ANSI/RESNET 301-2014 Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: All
Paragraph / Figure / Table / Note: 5.2
Comment Intent: Objection
Comment Type: General

Comment:

With all of the work and effort to get the HERS Rating to penetrate the Market, so that realtors, buyers, builders, code officials, and even politicians to finally recognize and understand what a HERS Index is and what it represents, we are going to re-name it???  Why would we confuse our customers like that, were talking about a freight train that takes a LOT of effort to get moving in one direction and now you want to try and change that direction??  Not to mention ALL of the literature, websites and BILLBOARDS that say “HERS Index” will have to be changed as well at a huge cost to our customers and to ourselves as well?  It is going to leave a VERY bad taste in their mouth and will definitely lose market share and confidence in our customers.

I am wholly against the change.

Proposed Change:

I propose we keep the nameing we have worked long and hard to get people to buy into and instead propose that the ICC change their "ERI" to "HERS Index".  Who here has ever seen the ERI ANYWHERE!! I know I haven't.  Ask any builder you know if they have heard of it, or code official, or buyer, or realtor, or politician??  I can gurantee many more have heard of the HERS Rating than have heard of an ERI?

Comment #2

Page Number: 4
Paragraph / Figure / Table / Note: 203.2
Comment Intent: Objection
Comment Type: General

Comment:

There are many entities that provide professional development conferences (such as ICC and ASHRAE).  The current language is very restrictive and cost create higher costs for trainers to maintain accreditation.  The proposed change provides more flexibility and options.

 

Other changes in the proposal are editorial or grammatical in nature.

 

-I would also like to know when and where the committee will be meeting to discuss my proposal.  Under ANSI procedures, people who submit proposals are allowed to discuss them with the committee at an open meeting.

Proposed Change:

Annually, RESNET Certified Instructors Trainers shall complete a two-hour annual RESNET

roundtable on current information and also attend a RESNET professional development conference at least once every two years.

Comment #3

Page Number: 7
Paragraph / Figure / Table / Note: 206.2.15.4
Comment Intent: Objection
Comment Type: Technical

Comment:

This is a potential life and building safety situation.  Making a recommendation for repair is a totally insufficient and inadequate response to a gas leak.

Proposed Change:

206.2.15.4 Identify gas leaks using combustible gas sensing equipment. If a leak is found, recommend that a certified technician repair the leak. immediately notify the local gas supplier (natural gas distribution company or propane supplier) and notify the building owner, and follow all safety protocols.

Comment #4

Page Number: All
Comment Intent: Objection
Comment Type: General

Comment:

I am 100% against changing the name of the HERS Index that the rating, realtor, builder, contractor markets have been working with and know so well.  I believe this will add confusion in the industry and where this stands with the Home Energy Score.  ICC has only recently allowed the ERI in the 2015 code while the HERS Index has been around almost 20 years.  This does not make any sense!

Proposed Change:

Name it the HERS Energy Rating Index (HERS ERI) or get ICC to change the 2018 IECC to directly mention the HERS Index.  

Comment #5

Page Number: 54
Paragraph / Figure / Table / Note: Section 5.2.1
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

Can there be an explanation of the approved IDR review authority?  Who exactly is this review authority and how does one submit an IDR to this group?

Comment #6

Page Number: all
Comment Intent: Objection
Comment Type: General

Comment:

Any performance type-option in the code, by its very nature, should allow the builder or designer to use ANY means to achieve compliance. This change makes the IECC Section 406 proprietary to those associated with RESNET.  When ANSI/RESNET 301-2014 (301) is added to section 406 of the IECC, which is RESNET’s stated intent, Section 406 of the IECC becomes proprietary.  The function of Section 406 is to compare the proposed home to a code home. Adding 301 as a requirement will make this section proprietary.  Who uses 301 besides RESNET or those affiliated with RESNET?  This gives RESNET a commanding and/or unique position over competing groups in a way that is not really required to determine code compliance.  

Proposed Change:

Do not reference a proprietary standard in the IECC.

Comment #7

Page Number: all
Comment Intent: Objection
Comment Type: General

Comment:

This is inconsistent with the ICC’s key role in managing their code and standard development processes.  As such, the ICC does not (and should not) make official endorsements of substantive code changes.  The ICC, by putting its name on a standard without participating in that standard’s development, and sanctioning changing the name of that standard to match an existing IECC section, gives up its neutral status for that code change.  Moreover, the ICC did not participate in managing the development of 301, as it did in ICC 700.  Is the ICC contending that this RESNET process is to be a substitute for the ICC’s process by which it would approve a new standard or method being brought into the I-codes?  Has ICC already decided 301 is the proper methodology for Section 406 of the code? This is very inconsistent with Section 3.2 of "ANSI Essential Requirements: Due process requirements for American National Standards" which says even "The appearance that a standard endorses any particular products, services or companies must be avoided.  "

Proposed Change:

Remove ICC's name from the 301 standard.  Remove the ICC narme from the title and name as used in 301.  Do not list ICC as a sponsor.  Do not use the ICC logo.

Comment #8

Page Number: all
Comment Intent: Objection
Comment Type: General

Comment:

If ANSI/RESNET 301-2014 (301) is added to section 406 of the IECC (RESNET representatives have said 301 will be part of the Group B I-code changes due in January 2016) then section 406 of the IECC will become firmly proprietary and preferential. 

 

Proposed Change:

RESNET should not propose the addition of a proprietary 301 to the IECC.  The name of 301 should not be changed.

Comment #9

Page Number: 10, 11, 12
Paragraph / Figure / Table / Note: Section 4.1.1
Comment Intent: Objection
Comment Type: General

Comment:

To further show the point of the improper proprietary nature of the proposal, consider the expansion of the scope of tradeoffs.  Section 406 of the IECC and 301 greatly expand the scope of what can be traded off in the IECC.  RESNET is retaining the expansion of scope for tradeoffs to itself, as only those affiliated with RESNET use 301.  RESNET intends to use its ability to make tradeoffs not only for equipment and air tightness, but also most of the list of equipment in Section 4.2.2.5 such as refrigerator, dishwasher, range/oven, etc. … Others programs or options will not be able to make these tradeoffs, offering RESNET a substantial market advantage. 

Proposed Change:

Do not specify RESNET's unique calculation as a requirement of Section 406 of the IECC.  Allow any energy cost based tradeoff to be used.. 

Comment #10

Page Number: 2, 6
Paragraph / Figure / Table / Note: Definitions
Comment Intent: Objection
Comment Type: Technical

Comment:

RESNET wants the HERS name and the term Home Energy Raters reserved for use of those associated with RESNET.  To illustrate that this is true, we need look no further than the fact that RESNET retains a trademark on the word HERS.  Simply crossing out the name does not change the fact that RESNET has the trademark.  Is RESNET implying others can be named “Home Energy Raters”, even if they are not part of RESNET’s network?  If not, again, this is effectively proprietary. 

Proposed Change:

Release the trademark on the term HERS.  Make it clear "Home Energy Rater" is a generic term that applies to others outside those associated with RESNET.

Comment #11

Page Number: application of 301 outside of 301
Comment Intent: Objection
Comment Type: Technical

Comment:

The definitions in 301 are inconsistent with the definitions approved by RESNET in Amendment 2014-01.  Is RESNET not even going to use 301? (http://www.resnet.us/standards/Addendum_to_Chapter_3.pdf).

These definitions state:

302 DEFINITIONS

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.

Approved Rating Provider – Shall mean a RESNET-accredited Quality Assurance Provider who is listed in good standing in the National RESNET Registry.

Approved Software Rating Tool – Shall mean a RESNET-accredited HERS® Rating Tool that has been tested and approved in accordance with RESNET Publication 002-13 and that is listed in the RESNET National Registry of Accredited Rating Software Programs (http://www.resnet.us/professional/programs/energy_rating_software).

Approved Tester – Shall mean a RESNET Rater or Rating Field Inspector (RFI) who has been certified by a RESNET-accredited Quality Assurance Provider and who is listed in good standing in the National RESNET Registry.

Certified Rater – Shall mean a RESNET Rater who has become qualified to conduct home energy ratings through certification by a RESNET-accredited Quality Assurance Provider and who is listed in good standing in the National RESNET Registry.

 

In conclusion, RESNET should not override its own standard 301 to make it more proprietary.  This becomes another way to corner the market.  RESNET should use the definitions in 301, or don’t claim to use 301.

Proposed Change:

Retract RESNET Amendment 2014-01

Comment #12

Page Number: 10, 11
Paragraph / Figure / Table / Note: 4.1.1, 4.1.2
Comment Intent: Objection
Comment Type: Technical

Comment:

RESNET and those associated with RESNET are the only ones that use the unique calculation called the “normalized modified end use load”, making it propretary.  Rather than embracing the general principal of meeting the energy efficiency in the IECC by having equivalent efficiency, which can be done in a variety of ways, RESNET is adding in a unique calculation to itself.  The IECC values energy efficiency in terms of energy cost, which mirrors the perspective of most energy users.  In other words, The IECC method calculates the energy cost as seen by the person paying the bills in the residence.  In the “normalized modified end use load”, 301 adds multipliers to compute value and then calls it energy cost.  The 301 method values a heating dollar, a cooling dollar, and a water-heating dollar differently; and as such is not computing the energy dollars that the residential occupant would pay.  Both EPA’s Energy Star and DOE’s Builders Challenge evaluated the HERS scores as indicators of compliance with their programs.  Both decided that there was too much variation in HERS scores, so they restricted the use to the “HERS index target”, which is recomputed for each home regardless of location.  Section 406 of the IECC should reference ANY procedure that allows tradeoffs such that bottom line energy cost is as good or is better than the IECC.  IECC procedures should be consistent with the IECC performance calculation, not just part of the performance calculation. 

Proposed Change:

Delete the 4.1.1 and 4.1.2 and replace it with an energy cost calculation as specified in the IECC.

Comment #13

Page Number: 14, 34, others
Paragraph / Figure / Table / Note: Table 4.2.2(1), Section 4.3.3.2.5, others
Comment Intent: Objection
Comment Type: Technical

Comment:

301 references ASHRAE 62.2-2013, for example in Table 4.2.2(1)’s ventilation calculation and Section 4.3.3.2.5 on required ventilation rates.  The IECC does not use ASHRAE 62.2-2013, or the values from it.  The IECC uses rates in ASHRAE 62.2-2010.  Any procedure RESNET wants referenced in the IECC should use the same ventilation rates as the IECC.

Proposed Change:

Replace the values from ASHRAE 62.2-2013 with the values from the 2010 version.

Comment #14

Page Number: many
Comment Intent: Objection
Comment Type: General

Comment:

Some specific actionable items:

The ICC should maintain its arm’s length independence from the process of developing substantive code changes. At a minimum, the ICC’s name should be removed from the standard.

Drop the trademark to the HERS term and make it clear “Home Energy Rater” is intended to be generic description for someone who inspects and compares homes to determine their level of energy efficiency.

Renaming a standard to match a code section is, in a word, proprietary.  This is being done to promote 301 as the only standard to use in IECC Section 406.  The existing name for 301 should be retained.

If this is to be proposed for the IECC, the unique energy calculation done by RESNET should be replaced by an energy cost calculation consistent with the IECC’s performance calculation.

The 301 methodology should be modified to allow other national and regional programs such as --Building Performance Institute’s methods, Washington State’s energy calculation, City of Austin’s procedures, DOE’s Home Energy Score and many other programs to be used to show energy equivalence under the IECC.

Proposed Change:

Remove ICC's name.  Retract the HER's trademark. Retain the existing 301 name. Use an energy cost calculation consistent with the IECC proformance calculation.