Review of Substantive Changes to Draft PDS-02 of Proposed Chapter 2 Amendment Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: 3
Paragraph / Figure / Table / Note: 203.2
Comment Intent: Objection
Comment Type: Technical

Comment:

The addition of "and" at the end of section 203.2.1 means that certified Instructors must attend a RESNET Conference every three years. I disagree with this requirement for a few reasons.

I don't think that attending a conference inherently improves an instructor's ability to teach certification candidates.

Attending a conference can be a large financial expense that doesn't necessarily have a return on investment for the Training Provider. This could be a huge expense for an organization that employs multiple instructors.

Further, this amendment adds language to section 203.2.2. "Additional documented hours of attendance at RESNET Conferences qualify under this provision".

This effectively means that sections 203.2.1 and 203.2.2 are equal in their value as Professional Development. This indicates to me that Instructors should be able to choose 203.2.1 or 203.2.2 to meet their PD requirements. In fact allowing this choice was the intention of the Training and Education Committee when we authored Chapter 2 in the first place.

But if RESNET requires that Instructors attend a RESNET conference (according to section 203.2.1), and if that attendance qualifies for the requirements of section 203.2.2, then the 18 hours of PD required by section 203.2.2 are moot. They will always be superseded by the mandated attendance of a RESNET conference.

Adding "and" to section 203.2.1 will make 203.2.2 irrelevant. Leaving it there will lead people to think that 18 hours of PD is an option, when it effectively is not. Removing 203.2.2 would make it clear that RESNET is requiring Certified Instructors to attend a RESNET conference every three years. If that is the intent of this amendment, then RESNET should make that clear and strike 203.2.2. I don't think that is a good option.

If forcing attendance is not the intention of this amendment, then "and" should not be added to the end of section 203.2.1.

Proposed Change:

203.2.1 Document twelve (12) hours of attendance at the a RESNET conference or other conference approved by RESNET; and or

 

Response:

Reject

The committee felt that attending a RESNET approved conference (which are held in nearly every region of the US annually) at least once in 3 years is important for instructors in order to stay up to date with a dynamic and changing industry.  The 12hr requirement at a conference does NOT supersede the 18hr requirement overall.  Effectively, if a conference is big enough to count for all 18hrs, then both requirements could be met at once.  But many regional conferences are shorter.  Therefore, some supplemental professional development would be required to reach a total of 18hrs.  The intent is to allow for the difference to be made up either by approved PD courses from a RESNET Accredited Training Provider OR by attending additional RESNET approved conferences. 

Comment #2

Page Number: 4
Paragraph / Figure / Table / Note: 206.1.3
Comment Intent: Objection
Comment Type: Editorial

Comment:

Inserting 'Or" at the end of 206.1.3.1 makes three distinct PD options for Certified Home Energy Raters. If that is the intent then there should be three distinct sections that identify those options. My proposed change would make it obvious that there are three choices and that the Rater may choose 1 of the three.

Proposed Change:

206.1.3 Certified Home Energy Raters

206.1.3.1 Attend a RESNET approved conference once every three years OR

206.1.3.2 Complete 18 hours of RESNET approved professional development from a RESNET Accredited Training Provider every three years OR

206.1.3.3 Successfully complete one JobWerks assessment every three years.

 

Response:

Accept

Accept in principle. Standard will be reviewed for edits and numbering prior to publication. 

Comment #3

Page Number: 4
Paragraph / Figure / Table / Note: 206.1.3
Comment Intent: Objection
Comment Type: Technical

Comment:

RESNET no longer has a relationship with the developer of JobWerks and because of this, RESNET no longer has technical support of JobWerks.  This situation will result in no raters being able to use this option under current Standard language.

The technical complexity and cost of managing the JobWerks platforms outweigh the benefit of using this tool.    

 

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 OR 206.1.3.2 Successfully complete one JobWerks assessment every three years

Response:

Reject

The proposed change includes edits to a section of the amendment that was not part of this round of public comments, so must be rejected.  FYI, this sort of emergency change must be handled by interim addendum (which bypasses public comment period temporarily) with approval by the SMB.  FYI- RFI Evaluation amendment/interim addendum was passed with unanimous approval by SDC 200.  

Comment #4

Page Number: 4
Paragraph / Figure / Table / Note: 206.1.3
Comment Intent: Objection
Comment Type: Technical

Comment:

RESNET no longer has a relationship with the developer of JobWerks and because of this, RESNET no longer has technical support of JobWerks.  This situation will result in no raters being able to use this option under current Standard language.

The technical complexity and cost of managing the JobWerks platforms outweigh the benefit of using this tool.    

 

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 OR 206.1.3.2 Successfully complete one JobWerks assessment every three years

Response:

Reject

The proposed change includes edits to a section of the amendment that was not part of this round of public comments, so must be rejected.  FYI, this sort of emergency change must be handled by interim addendum (which bypasses public comment period temporarily) with approval by the SMB.  FYI- RFI Evaluation amendment/interim addendum was passed with unanimous approval by SDC 200.  

Comment #5

Page Number: 3
Paragraph / Figure / Table / Note: 203.1.2
Comment Intent: Objection
Comment Type: Technical

Comment:

Previously, the requirement to have candidates complete provisional ratings during class served as an unofficial prerequisite that all candidates attend Rater training with a RESNET accredited Training Provider. Now that the probationary ratings are being given to the QA providers, there is nothing in the standard to prevent someone from skipping training altogether, which I believe serves against RESNET's goal to make ratings more consistent and accurate. 

Furthermore, not having a required trainining component will allow for outside organizations to offer training without any regard to following the provisions outlined in 202.2 regarding accredtation. It will become a completely unregulated environment where RESNET will have little control of the quality of instruciton. 

We do not believe that the follwoing language goes far enough to prevent this scenario above as the QA provider would only be concerned with testing scores rather than ensuring candidates have adequate exposure to the industry and the fundamentals of the profession.

202.2.8 Only RESNET accredited Training Providers can offer Rater Training using certified RESNET certified Rater Instructors 

Proposed Change:

Proposed language

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

AND

205.2.3.1.4 Complete Rater training course provided through a RESNET accredited Rater Training Provider that meets minimum standards as outlined in section 202.2.

Response:

Accept

Accept in principle. Language will be added to the most logical section in the final edits of the standard. The intent of the comment has already been met in section 205.1.1, which did not go out with this round as it was not subject to public comment.  That section states “All Rater Candidates are required to complete Rater instruction delivered by a RESNET Accredited Rater Training Provider”

Comment #6

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

Comment:

There are two public comments that have been made which do not abide by the directions given, and I quote:

"Comments will be accepted only on the changes to the previously published draft PDS-02 of the proposed amendment and indicated by strike (delete)/underline (add) in draft PDS-03."

Which is clearly stated on the page where we can fill out the form to make public comments. As such, I request that SDC 200 ignore those two comments until the standard can be republished for a more appropriate public comment period. Refusal to do so indicates that SDC 200 or others do not care for the process which we have created explicitly for the purpose of keeping things on track.

If these comments are not ignored, then everyone has the right to comment on whatever they want in the public comments period- and this notification should be removed on ALL standards out for public comment from here on.

Proposed Change:

No change to the standard- but you must ignore the comments made that are not on anything struck through or underlined.

Response:

Reject

No change proposed.  The comment is duly noted.