Comment #1Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 1-3Paragraph / Figure / Table / Note: Exceptions 4, 5,6Comment Intent: ObjectionComment Type: GeneralComment: We believe that allowing homes NOT to be tested is a great dilution to our industry value and will deviate RESNET from its mission of promoting energy efficiency in residential construction. The default values do not respresent homes testing value without rater instructions, inspections, and other guidance. This also can lead to more risk for builders and industry stakeholders. The process of inspecting, rating, verifying, and testing verification has led to better built homes with less leakage, very low amounts of thermal bypasses, and much healthier home construction. Continuing down this path could lead to homes that are not built well and ultimately hurt the consumers of new homes. Besides the moral aspect of this, which is a huge concern, it also is a negative for our industry and could cheapen the value of new homes that are constructed in a better manner and more energy efficient. Sincerely, Clayton Morris Proposed Change: Do NOT pass this amendment!
We believe that allowing homes NOT to be tested is a great dilution to our industry value and will deviate RESNET from its mission of promoting energy efficiency in residential construction. The default values do not respresent homes testing value without rater instructions, inspections, and other guidance. This also can lead to more risk for builders and industry stakeholders. The process of inspecting, rating, verifying, and testing verification has led to better built homes with less leakage, very low amounts of thermal bypasses, and much healthier home construction.
Continuing down this path could lead to homes that are not built well and ultimately hurt the consumers of new homes. Besides the moral aspect of this, which is a huge concern, it also is a negative for our industry and could cheapen the value of new homes that are constructed in a better manner and more energy efficient.
Sincerely,
Clayton Morris
Do NOT pass this amendment!
Comment #2Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 1Comment Intent: ObjectionComment Type: GeneralComment: This proposal to continue to allow a home not to receive on site testing and to use default values lower than code cheapens if not completely eliminates the value of the HERS rating. This will in turn lead to less demand for HERS ratings and for testing services. In the meantime, homes passed this way will be of lower quality and with less energy efficiency; a further detriment to the overall mission of RESNET. Quite frankly, I am completely flumoxed by RESNET's advocacy for this since it seems to fly in the face of our purpose and mission. After 9 months of this global pandemic we have learned a lot about how to inspect and rate homes safely and while this was a good move when we were all determining how to manage the Corona virus it is no longer necessary. With the arrival of new treatments (monoclonal antibodies) and vaccines, COVID is becoming less severe (current declines in fatality rates as treatments have improved suggest we are already close to this point). We dont shut down our businesses for diseases like the flu why are we doing this for COVID. Furthermore, is there a single documented case of transmission as a tresult of an in-home inspection? It is time to move back to business as normal. Best regards, Jonathan Risch CEO DPIS Builder Services
This proposal to continue to allow a home not to receive on site testing and to use default values lower than code cheapens if not completely eliminates the value of the HERS rating. This will in turn lead to less demand for HERS ratings and for testing services. In the meantime, homes passed this way will be of lower quality and with less energy efficiency; a further detriment to the overall mission of RESNET. Quite frankly, I am completely flumoxed by RESNET's advocacy for this since it seems to fly in the face of our purpose and mission.
After 9 months of this global pandemic we have learned a lot about how to inspect and rate homes safely and while this was a good move when we were all determining how to manage the Corona virus it is no longer necessary. With the arrival of new treatments (monoclonal antibodies) and vaccines, COVID is becoming less severe (current declines in fatality rates as treatments have improved suggest we are already close to this point). We dont shut down our businesses for diseases like the flu why are we doing this for COVID. Furthermore, is there a single documented case of transmission as a tresult of an in-home inspection?
It is time to move back to business as normal.
Best regards,
Jonathan Risch
CEO
DPIS Builder Services
Comment #3Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 1-4Comment Intent: ObjectionComment Type: GeneralComment: If installation is possible with proper safety protocols in place then testing should be possible with proper safety protocols in place. Additionally, how would this impact potential tax credits?
If installation is possible with proper safety protocols in place then testing should be possible with proper safety protocols in place. Additionally, how would this impact potential tax credits?
Comment #4Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 1-3Paragraph / Figure / Table / Note: AllComment Intent: ObjectionComment Type: GeneralComment: Allowing for homes to not be tested or verified on site greatly reduces the validity of the RESNET HERS Rating. The RESNET name and brand has been built based upon a standard that requires onsite verification throughout the building process. To allow the use of defaults in lieu of testing undermines the work that the RESNET staff, board members and certified individuals have spent the last 15 years developing. All municipalities and code enforcement inspections are back to business as usual and RESNET should be the same way rating the house that is being built rather than a theoretical house using default values. The entire amendment should be removed from the standards. Proposed Change: Draft PDS-02 MINHERS Addendum 48f COVID-19 Pandemic Exception for Onsite Airtightness Tests Date Approved: Effective Date: Transition Period: Termination Date: Proponent: Steve Baden Organization: RESNET Purpose: Addendum 48f authorizes an extension of the exception for testing first authorized by interim Addendum 48i and is intended to apply only during the COVID-19 Pandemic. It adds an exception to the requirements of Standard ANSI/RESNET/ICC 301 in Section 303 of the MINHERS standards and applies only to the determination of RESNET Home Energy Rating System, (HERS), ratings. The exception allows use of default values in lieu of conducting air tightness tests for dwelling unit enclosures and duct systems as well as for measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380. Note that programs other than the RESNET HERS that adopt Standard ANSI/RESNET/ICC 301 for energy ratings of homes may not recognize this test exception. Amendment: Add new Exception 6 to section 303.1 as follows: 303 Technical Requirements 303.1 Applicable Standards All RESNET Home Energy Ratings conducted in accordance with this Standard shall comply with the provisions of ANSI/RESNET/ICC 301. Note: The RESNET Home Energy Ratings adopt Standards ANSI/RESNET/ICC 301 and ANSI/RESNET/ICC 380 including all of their addenda and normative appendices. See 304 Normative References. Standards 301 and 380 Addenda are effective on the date they are approved by ANSI. The Standards Management Board may establish a Transition Period during which addenda may be used. If a Transition Period is authorized these addenda must be used after a Mandatory Compliance Date designated by the Standards Management Board. If no Transition Period is authorized they must be used beginning on the Mandatory Compliance Date established by the Standards Management Board. : : : (Exceptions 1, 2 and 3 are repealed when Addendum 42 becomes mandatory January 1, 2021 and the Exceptions below will be renumbered) : : Exception 4: RESNET Home Energy Ratings conducted in Puerto Rico and the US Virgin Islands shall comply with the provisions of ANSI/RESNET/ICC 301, except that Ratings of homes with a permit date prior to January 1, 2022 are permitted to use a default infiltration rate of 10 ACH50 in lieu of conducting an airtightness test in accordance with Standard ANSI/RESNET/ICC 380. In addition, for a home in the Tropical Climate Zone for which its Living Space is not serviced by a space heating mechanical system and not more than one-half of its Living Space is serviced by a space cooling mechanical system, the Conditioned Space Volume shall be defined as the volume of its Living Space and the Conditioned Floor Area shall be defined as the floor area of its Living Space. Exception 5: RESNET Home Energy Ratings shall comply with the requirements of ANSI/RESNET/ICC 301and its Addenda except that Ratings on homes with a building permit date, or alternate pursuant to Addendum 43, prior to January 1, 2021 are permitted to use the following exception: When the following condition is met and documented, duct leakage testing is not required. At a pre-drywall stage of construction, 100% of the distribution system and air handler shall be visible and visually verified to be contained inside the Conditioned Space Volume. At a final stage of construction, ductwork that is visible and the air handler shall again be verified to be contained in the Conditioned Space Volume. To calculate the energy impacts on the Rated Home, a DSE of 0.88 shall be applied to both the heating and cooling system efficiencies. Exception 6: RESNET Home Energy Ratings shall comply with the provisions of ANSI/RESNET/ICC 301, except during for dwelling units with a rating date on or up to 120 days after the effective date of this amendment established by the RESNET Standards Management Board. Due to the COVID pandemic. This exception shall remain in effect until thirty (30) days after the Presidential Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak is lifted. , dDwelling units with a “Date Rated” as reported to the Registry rated during that time are permitted to use default values in lieu of conducting air tightness testing of dwelling unit enclosures and duct systems as well as measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380. Ratings utilizing default test values must be compliant with RESNET’s Temporary Protocols for Alternative Testing During the COVID-19 Pandemic: ? Default values by Climate Zone below in table 3.1, OR ? Default values determined by the Rating Provider for a builder by metro-code area based on past 120 days performance (i.e. measured data from the 120 days immediately preceding the effective date of this exception), OR ? Other default values adopted by program sponsors -such as a building department, a utility program, or a program such as ENERGY STAR - as approved by RESNET. Default Values Table 3.1 CZ CFM25 per SF ACH50 1A 0.032 5.11 2A 0.033 4.91 2B 0.037 4.26 3A 0.036 5.08 3B 0.037 3.90 3C 0.033 3.99 4A 0.034 4.54 4B 0.051 5.00 4C 0.028 3.43 5A 0.033 4.01 5B 0.036 3.21 6A 0.033 3.35 6B 0.026 3.46 7B 0.023 2.99 ? Ventilation Airflow Rate Defaults o Installer-measured and documented ventilation airflow rate -OR- o HVI Rated equipment airflow rates
Allowing for homes to not be tested or verified on site greatly reduces the validity of the RESNET HERS Rating. The RESNET name and brand has been built based upon a standard that requires onsite verification throughout the building process. To allow the use of defaults in lieu of testing undermines the work that the RESNET staff, board members and certified individuals have spent the last 15 years developing.
All municipalities and code enforcement inspections are back to business as usual and RESNET should be the same way rating the house that is being built rather than a theoretical house using default values.
The entire amendment should be removed from the standards.
Draft PDS-02
MINHERS Addendum 48f
COVID-19 Pandemic Exception for Onsite Airtightness Tests
Date Approved: Effective Date: Transition Period: Termination Date: Proponent: Steve Baden Organization: RESNET
Purpose:
Addendum 48f authorizes an extension of the exception for testing first authorized by interim Addendum 48i and is intended to apply only during the COVID-19 Pandemic. It adds an exception to the requirements of Standard ANSI/RESNET/ICC 301 in Section 303 of the MINHERS standards and applies only to the determination of RESNET Home Energy Rating System, (HERS), ratings. The exception allows use of default values in lieu of conducting air tightness tests for dwelling unit enclosures and duct systems as well as for measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380. Note that programs other than the RESNET HERS that adopt Standard ANSI/RESNET/ICC 301 for energy ratings of homes may not recognize this test exception.
Amendment:
Add new Exception 6 to section 303.1 as follows:
303 Technical Requirements 303.1 Applicable Standards All RESNET Home Energy Ratings conducted in accordance with this Standard shall comply with the provisions of ANSI/RESNET/ICC 301. Note: The RESNET Home Energy Ratings adopt Standards ANSI/RESNET/ICC 301 and ANSI/RESNET/ICC 380 including all of their addenda and normative appendices. See 304 Normative References. Standards 301 and 380 Addenda are effective on the date they are approved by ANSI. The Standards Management Board may establish a Transition Period during which addenda may be used. If a Transition Period is authorized these addenda must be used after a Mandatory Compliance Date designated by the Standards Management Board. If no Transition Period is authorized they must be used beginning on the Mandatory Compliance Date established by the Standards Management Board. : : : (Exceptions 1, 2 and 3 are repealed when Addendum 42 becomes mandatory January 1, 2021 and the Exceptions below will be renumbered) : : Exception 4: RESNET Home Energy Ratings conducted in Puerto Rico and the US Virgin Islands shall comply with the provisions of ANSI/RESNET/ICC 301, except that Ratings of homes with a permit date prior to January 1, 2022 are permitted to use a default infiltration rate of 10 ACH50 in lieu of conducting an airtightness test in accordance with Standard ANSI/RESNET/ICC 380. In addition, for a home in the Tropical Climate Zone for which its Living Space is not serviced by a space heating mechanical system and not more than one-half of its Living Space is serviced by a space cooling mechanical system, the Conditioned Space Volume shall be defined as the volume of its Living Space and the Conditioned Floor Area shall be defined as the floor area of its Living Space.
Exception 5: RESNET Home Energy Ratings shall comply with the requirements of ANSI/RESNET/ICC 301and its Addenda except that Ratings on homes with a building permit date, or alternate pursuant to Addendum 43, prior to January 1, 2021 are permitted to use the following exception:
When the following condition is met and documented, duct leakage testing is not required. At a pre-drywall stage of construction, 100% of the distribution system and air handler shall be visible and visually verified to be contained inside the Conditioned Space Volume. At a final stage of construction, ductwork that is visible and the air handler shall again be verified to be contained in the Conditioned Space Volume.
To calculate the energy impacts on the Rated Home, a DSE of 0.88 shall be applied to both the heating and cooling system efficiencies.
Exception 6: RESNET Home Energy Ratings shall comply with the provisions of ANSI/RESNET/ICC 301, except during for dwelling units with a rating date on or up to 120 days after the effective date of this amendment established by the RESNET Standards Management Board. Due to the COVID pandemic. This exception shall remain in effect until thirty (30) days after the Presidential Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak is lifted. , dDwelling units with a “Date Rated” as reported to the Registry rated during that time are permitted to use default values in lieu of conducting air tightness testing of dwelling unit enclosures and duct systems as well as measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380. Ratings utilizing default test values must be compliant with RESNET’s Temporary Protocols for Alternative Testing During the COVID-19 Pandemic:
? Default values by Climate Zone below in table 3.1, OR ? Default values determined by the Rating Provider for a builder by metro-code area based on past 120 days performance (i.e. measured data from the 120 days immediately preceding the effective date of this exception), OR ? Other default values adopted by program sponsors -such as a building department, a utility program, or a program such as ENERGY STAR - as approved by RESNET. Default Values Table 3.1 CZ CFM25 per SF ACH50 1A 0.032 5.11 2A 0.033 4.91 2B 0.037 4.26 3A 0.036 5.08 3B 0.037 3.90 3C 0.033 3.99 4A 0.034 4.54 4B 0.051 5.00 4C 0.028 3.43 5A 0.033 4.01 5B 0.036 3.21 6A 0.033 3.35 6B 0.026 3.46 7B 0.023 2.99
? Ventilation Airflow Rate Defaults o Installer-measured and documented ventilation airflow rate -OR- o HVI Rated equipment airflow rates
Comment #5Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 2Paragraph / Figure / Table / Note: Exception 6Comment Intent: ObjectionComment Type: GeneralComment: I believe that allowing builders to use default values without actually testing homes will dilute the industry. If we let this to happen, all the work we have done to this point will be lost. For years, we have been selling the HERS rating process and the quality assurance that goes into as a way to set yourself apart from the competition. If we let default values take the place of raters and their expertese, the industry will be taken back several years. During the pandemic, we have been able to work with our builders to allow for safe testing of homes following CDC protocols for safety. If I have learned one thing from builders in my experience is that if you give them an inch, they will take it all and not look back. If we issue HERS ratings without testing, it will be hard to recover from the perception that verification and testing have never been necessary. The last thing we want is for the industry that we have dedicated years to promoting have an asterisk stuck behind it because raters and builders can't coordinate to provide a safe working environment for diagnostic testing. Homeowners also see the value, efficiency and safety benefits of a HERS rated home. The verification and testing that raters do in the field is a huge reason for that. If we step back from that, the demand for HERS rated homes will also suffer along with the efficiency and quality of the homes being constructed. Thank you for your time. Noe Montalvo
I believe that allowing builders to use default values without actually testing homes will dilute the industry. If we let this to happen, all the work we have done to this point will be lost. For years, we have been selling the HERS rating process and the quality assurance that goes into as a way to set yourself apart from the competition. If we let default values take the place of raters and their expertese, the industry will be taken back several years.
During the pandemic, we have been able to work with our builders to allow for safe testing of homes following CDC protocols for safety. If I have learned one thing from builders in my experience is that if you give them an inch, they will take it all and not look back. If we issue HERS ratings without testing, it will be hard to recover from the perception that verification and testing have never been necessary. The last thing we want is for the industry that we have dedicated years to promoting have an asterisk stuck behind it because raters and builders can't coordinate to provide a safe working environment for diagnostic testing.
Homeowners also see the value, efficiency and safety benefits of a HERS rated home. The verification and testing that raters do in the field is a huge reason for that. If we step back from that, the demand for HERS rated homes will also suffer along with the efficiency and quality of the homes being constructed. Thank you for your time.
Noe Montalvo
Comment #6Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 2Paragraph / Figure / Table / Note: Exception 6Comment Intent: ObjectionComment Type: GeneralComment: I believe that allowing builders to use default values without actually testing homes will dilute the industry. If we let this to happen, all the work we have done to this point will be lost. For years, we have been selling the HERS rating process and the quality assurance that goes into as a way to set yourself apart from the competition. If we let default values take the place of raters and their expertese, the industry will be taken back several years. During the pandemic, we have been able to work with our builders to allow for safe testing of homes following CDC protocols for safety. If I have learned one thing from builders in my experience is that if you give them an inch, they will take it all and not look back. If we issue HERS ratings without testing, it will be hard to recover from the perception that verification and testing have never been necessary. The last thing we want is for the industry that we have dedicated years to promoting have an asterisk stuck behind it because raters and builders can't coordinate to provide a safe working environment for diagnostic testing. Homeowners also see the value, efficiency and safety benefits of a HERS rated home. The verification and testing that raters do in the field is a huge reason for that. If we step back from that, the demand for HERS rated homes will also suffer along with the efficiency and quality of the homes being constructed. Thank you for your time. Noe Montalvo
Comment #7Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: AllComment Intent: ObjectionComment Type: GeneralComment: You are a science based organization. Use the science, not hype. I've been testing and training through the entire pandemic. I wear a mask, keep socially distant, wash my hands often and use hand sanitizer once I'm back in my truck. Allowing builders to not test can undermine the intent and integrity of our industry. Stick to the science and get back to work.
You are a science based organization. Use the science, not hype. I've been testing and training through the entire pandemic. I wear a mask, keep socially distant, wash my hands often and use hand sanitizer once I'm back in my truck. Allowing builders to not test can undermine the intent and integrity of our industry. Stick to the science and get back to work.
Comment #8Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 1-4Comment Intent: ObjectionComment Type: GeneralComment: I am concerned with the regulation and accuracy of ratings if this ammendment passes. I would caution passing an ammendment to allow for lesser service will not only be detrimental to those in the industry but the consumer of the product. There is something to be said about the validity and professionalism that we should all hold ourselves to and require those with the RESNET certifications to hold themselves to. Energy Rating is still a foreign subject to many in the construction industry and moreso, homeowners. We are the experts and it is only through holding ourselves to higher standards can we ever expect to shape the industry towards a better and brighter future for generations to come. This ammendment seems to be a step in the wrong direction that would defund our credibility and services. I agree with others that we have adapted to our landscape of COVID well and found innovative ways to complete our jobs during the pandemic. I implore you to reconsider this ammendment and take into account what the future looks like without COVID because as other pandemics have come and gone what remains true is our need for a sustainable future with ethics and credibility. Please don't make a rushed decision about all of our futures in regard to a virus that we have all lived with for over 7 months.
I am concerned with the regulation and accuracy of ratings if this ammendment passes. I would caution passing an ammendment to allow for lesser service will not only be detrimental to those in the industry but the consumer of the product. There is something to be said about the validity and professionalism that we should all hold ourselves to and require those with the RESNET certifications to hold themselves to.
Energy Rating is still a foreign subject to many in the construction industry and moreso, homeowners. We are the experts and it is only through holding ourselves to higher standards can we ever expect to shape the industry towards a better and brighter future for generations to come. This ammendment seems to be a step in the wrong direction that would defund our credibility and services. I agree with others that we have adapted to our landscape of COVID well and found innovative ways to complete our jobs during the pandemic. I implore you to reconsider this ammendment and take into account what the future looks like without COVID because as other pandemics have come and gone what remains true is our need for a sustainable future with ethics and credibility. Please don't make a rushed decision about all of our futures in regard to a virus that we have all lived with for over 7 months.
Comment #9Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 2-3Paragraph / Figure / Table / Note: Exception 4,5,6Comment Intent: ObjectionComment Type: GeneralComment: In most of the country construction is considered an essential industry. Construction has not slowed, and Raters have been allowed on site in the same way that other trades have been allowed on site. The exceptions were a reaction to the very first experience with Covid and do not appear to be needed as we have learned to wear masks and interact on site to perform our jobs is a safe manner. If we say that an Energy Rating Index is not valid if upgrades have been made to a house how could it be valid if the actual blower door number is not used? The validity and credibility of our industry is on the line. In addition, the ability of unscrupulous business practices to arise is certain as the market is already trying to drive the price of a rating down. If defaults become the norm for any length of time pressure to lower prices is certain to come. Lastly, the energy code does not recognize the default value, yet the energy code industry is young ad unsophisticated and may not look at the air leakage reports, for example, as carefully as they should. In some climate zones the default value is below the code minimum. As we are beginning to build credibility with code jurisdictions the use of default testing values could severely damage the effort. Proposed Change: Remove the exceptions and do not allow them
In most of the country construction is considered an essential industry. Construction has not slowed, and Raters have been allowed on site in the same way that other trades have been allowed on site. The exceptions were a reaction to the very first experience with Covid and do not appear to be needed as we have learned to wear masks and interact on site to perform our jobs is a safe manner.
If we say that an Energy Rating Index is not valid if upgrades have been made to a house how could it be valid if the actual blower door number is not used? The validity and credibility of our industry is on the line. In addition, the ability of unscrupulous business practices to arise is certain as the market is already trying to drive the price of a rating down. If defaults become the norm for any length of time pressure to lower prices is certain to come.
Lastly, the energy code does not recognize the default value, yet the energy code industry is young ad unsophisticated and may not look at the air leakage reports, for example, as carefully as they should. In some climate zones the default value is below the code minimum. As we are beginning to build credibility with code jurisdictions the use of default testing values could severely damage the effort.
Remove the exceptions and do not allow them
Comment #10Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: AllComment Intent: ObjectionComment Type: GeneralComment: As a HERS rater, this extension feels unneccesary as builders have continued their building practices including air tightness testing which has led to improved home savings that our clients desire. Allowing raters to continue to put in default values sets a bad precedent for future HERS ratings and lessens the need for builders to want this service. As an essential industry, we have been able to continue proper testing and change our social distancing practices to allow for this testing to continue in a safe manner. It is my opinion that RESNET should be wanting to promote this science and not fall off of it for convenience as it will be used just to not have to put the work in. We should instead focus our efforts on how to test safely during a pandemic instead of going down a path that could make the HERS rating less important for builders.
As a HERS rater, this extension feels unneccesary as builders have continued their building practices including air tightness testing which has led to improved home savings that our clients desire. Allowing raters to continue to put in default values sets a bad precedent for future HERS ratings and lessens the need for builders to want this service. As an essential industry, we have been able to continue proper testing and change our social distancing practices to allow for this testing to continue in a safe manner. It is my opinion that RESNET should be wanting to promote this science and not fall off of it for convenience as it will be used just to not have to put the work in. We should instead focus our efforts on how to test safely during a pandemic instead of going down a path that could make the HERS rating less important for builders.
Comment #11Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 1-3Paragraph / Figure / Table / Note: AllComment Intent: ObjectionComment Type: GeneralComment: Allowing homes to not be tested or verified on site would significantly put a tarnish on the accountability and legitimacy of RESNET HERS Rating. There is a reason for the certifications obtained and testing practices used. We are all testing these homes based on building science, because RESNET is a science-based entity. Verification and field testing are key to the science. Allowing builders to not test their homes can undermine the intent and validity of our industry. This allows builders to set their personal building practices to the default values as an overall goal, rather than striving to be better than the industry default standards. Using default values not only hurts the saving potential for builders but also the home buyers. The entire amendment should be removed from the standards. Proposed Change: Draft PDS-02 MINHERS Addendum 48f COVID-19 Pandemic Exception for Onsite Airtightness Tests Date Approved: Effective Date: Transition Period: Termination Date: Proponent: Steve Baden Organization: RESNET Purpose: Addendum 48f authorizes an extension of the exception for testing first authorized by interim Addendum 48i and is intended to apply only during the COVID-19 Pandemic. It adds an exception to the requirements of Standard ANSI/RESNET/ICC 301 in Section 303 of the MINHERS standards and applies only to the determination of RESNET Home Energy Rating System, (HERS), ratings. The exception allows use of default values in lieu of conducting air tightness tests for dwelling unit enclosures and duct systems as well as for measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380. Note that programs other than the RESNET HERS that adopt Standard ANSI/RESNET/ICC 301 for energy ratings of homes may not recognize this test exception. Amendment: Add new Exception 6 to section 303.1 as follows: 303 Technical Requirements 303.1 Applicable Standards All RESNET Home Energy Ratings conducted in accordance with this Standard shall comply with the provisions of ANSI/RESNET/ICC 301. Note: The RESNET Home Energy Ratings adopt Standards ANSI/RESNET/ICC 301 and ANSI/RESNET/ICC 380 including all of their addenda and normative appendices. See 304 Normative References. Standards 301 and 380 Addenda are effective on the date they are approved by ANSI. The Standards Management Board may establish a Transition Period during which addenda may be used. If a Transition Period is authorized these addenda must be used after a Mandatory Compliance Date designated by the Standards Management Board. If no Transition Period is authorized they must be used beginning on the Mandatory Compliance Date established by the Standards Management Board. : : : (Exceptions 1, 2 and 3 are repealed when Addendum 42 becomes mandatory January 1, 2021 and the Exceptions below will be renumbered) : : Exception 4: RESNET Home Energy Ratings conducted in Puerto Rico and the US Virgin Islands shall comply with the provisions of ANSI/RESNET/ICC 301, except that Ratings of homes with a permit date prior to January 1, 2022 are permitted to use a default infiltration rate of 10 ACH50 in lieu of conducting an airtightness test in accordance with Standard ANSI/RESNET/ICC 380. In addition, for a home in the Tropical Climate Zone for which its Living Space is not serviced by a space heating mechanical system and not more than one-half of its Living Space is serviced by a space cooling mechanical system, the Conditioned Space Volume shall be defined as the volume of its Living Space and the Conditioned Floor Area shall be defined as the floor area of its Living Space. Exception 5: RESNET Home Energy Ratings shall comply with the requirements of ANSI/RESNET/ICC 301and its Addenda except that Ratings on homes with a building permit date, or alternate pursuant to Addendum 43, prior to January 1, 2021 are permitted to use the following exception: When the following condition is met and documented, duct leakage testing is not required. At a pre-drywall stage of construction, 100% of the distribution system and air handler shall be visible and visually verified to be contained inside the Conditioned Space Volume. At a final stage of construction, ductwork that is visible and the air handler shall again be verified to be contained in the Conditioned Space Volume. To calculate the energy impacts on the Rated Home, a DSE of 0.88 shall be applied to both the heating and cooling system efficiencies. Exception 6: RESNET Home Energy Ratings shall comply with the provisions of ANSI/RESNET/ICC 301, except during for dwelling units with a rating date on or up to 120 days after the effective date of this amendment established by the RESNET Standards Management Board. Due to the COVID pandemic. This exception shall remain in effect until thirty (30) days after the Presidential Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak is lifted. , dDwelling units with a “Date Rated” as reported to the Registry rated during that time are permitted to use default values in lieu of conducting air tightness testing of dwelling unit enclosures and duct systems as well as measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380. Ratings utilizing default test values must be compliant with RESNET’s Temporary Protocols for Alternative Testing During the COVID-19 Pandemic: ? Default values by Climate Zone below in table 3.1, OR ? Default values determined by the Rating Provider for a builder by metro-code area based on past 120 days performance (i.e. measured data from the 120 days immediately preceding the effective date of this exception), OR ? Other default values adopted by program sponsors -such as a building department, a utility program, or a program such as ENERGY STAR - as approved by RESNET. Default Values Table 3.1 CZ CFM25 per SF ACH50 1A 0.032 5.11 2A 0.033 4.91 2B 0.037 4.26 3A 0.036 5.08 3B 0.037 3.90 3C 0.033 3.99 4A 0.034 4.54 4B 0.051 5.00 4C 0.028 3.43 5A 0.033 4.01 5B 0.036 3.21 6A 0.033 3.35 6B 0.026 3.46 7B 0.023 2.99 ? Ventilation Airflow Rate Defaults o Installer-measured and documented ventilation airflow rate -OR- o HVI Rated equipment airflow rates
Allowing homes to not be tested or verified on site would significantly put a tarnish on the accountability and legitimacy of RESNET HERS Rating. There is a reason for the certifications obtained and testing practices used. We are all testing these homes based on building science, because RESNET is a science-based entity. Verification and field testing are key to the science.
Allowing builders to not test their homes can undermine the intent and validity of our industry. This allows builders to set their personal building practices to the default values as an overall goal, rather than striving to be better than the industry default standards. Using default values not only hurts the saving potential for builders but also the home buyers.
Draft PDS-02 MINHERS Addendum 48f COVID-19 Pandemic Exception for Onsite Airtightness Tests Date Approved: Effective Date: Transition Period: Termination Date: Proponent: Steve Baden Organization: RESNET Purpose: Addendum 48f authorizes an extension of the exception for testing first authorized by interim Addendum 48i and is intended to apply only during the COVID-19 Pandemic. It adds an exception to the requirements of Standard ANSI/RESNET/ICC 301 in Section 303 of the MINHERS standards and applies only to the determination of RESNET Home Energy Rating System, (HERS), ratings. The exception allows use of default values in lieu of conducting air tightness tests for dwelling unit enclosures and duct systems as well as for measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380. Note that programs other than the RESNET HERS that adopt Standard ANSI/RESNET/ICC 301 for energy ratings of homes may not recognize this test exception.
Amendment: Add new Exception 6 to section 303.1 as follows:
303 Technical Requirements 303.1 Applicable Standards All RESNET Home Energy Ratings conducted in accordance with this Standard shall comply with the provisions of ANSI/RESNET/ICC 301. Note: The RESNET Home Energy Ratings adopt Standards ANSI/RESNET/ICC 301 and ANSI/RESNET/ICC 380 including all of their addenda and normative appendices. See 304 Normative References. Standards 301 and 380 Addenda are effective on the date they are approved by ANSI. The Standards Management Board may establish a Transition Period during which addenda may be used. If a Transition Period is authorized these addenda must be used after a Mandatory Compliance Date designated by the Standards Management Board. If no Transition Period is authorized they must be used beginning on the Mandatory Compliance Date established by the Standards Management Board. : : : (Exceptions 1, 2 and 3 are repealed when Addendum 42 becomes mandatory January 1, 2021 and the Exceptions below will be renumbered) : : Exception 4: RESNET Home Energy Ratings conducted in Puerto Rico and the US Virgin Islands shall comply with the provisions of ANSI/RESNET/ICC 301, except that Ratings of homes with a permit date prior to January 1, 2022 are permitted to use a default infiltration rate of 10 ACH50 in lieu of conducting an airtightness test in accordance with Standard ANSI/RESNET/ICC 380. In addition, for a home in the Tropical Climate Zone for which its Living Space is not serviced by a space heating mechanical system and not more than one-half of its Living Space is serviced by a space cooling mechanical system, the Conditioned Space Volume shall be defined as the volume of its Living Space and the Conditioned Floor Area shall be defined as the floor area of its Living Space. Exception 5: RESNET Home Energy Ratings shall comply with the requirements of ANSI/RESNET/ICC 301and its Addenda except that Ratings on homes with a building permit date, or alternate pursuant to Addendum 43, prior to January 1, 2021 are permitted to use the following exception: When the following condition is met and documented, duct leakage testing is not required. At a pre-drywall stage of construction, 100% of the distribution system and air handler shall be visible and visually verified to be contained inside the Conditioned Space Volume. At a final stage of construction, ductwork that is visible and the air handler shall again be verified to be contained in the Conditioned Space Volume. To calculate the energy impacts on the Rated Home, a DSE of 0.88 shall be applied to both the heating and cooling system efficiencies. Exception 6: RESNET Home Energy Ratings shall comply with the provisions of ANSI/RESNET/ICC 301, except during for dwelling units with a rating date on or up to 120 days after the effective date of this amendment established by the RESNET Standards Management Board. Due to the COVID pandemic. This exception shall remain in effect until thirty (30) days after the Presidential Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak is lifted. , dDwelling units with a “Date Rated” as reported to the Registry rated during that time are permitted to use default values in lieu of conducting air tightness testing of dwelling unit enclosures and duct systems as well as measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380. Ratings utilizing default test values must be compliant with RESNET’s Temporary Protocols for Alternative Testing During the COVID-19 Pandemic: ? Default values by Climate Zone below in table 3.1, OR ? Default values determined by the Rating Provider for a builder by metro-code area based on past 120 days performance (i.e. measured data from the 120 days immediately preceding the effective date of this exception), OR ? Other default values adopted by program sponsors -such as a building department, a utility program, or a program such as ENERGY STAR - as approved by RESNET. Default Values Table 3.1 CZ CFM25 per SF ACH50 1A 0.032 5.11 2A 0.033 4.91 2B 0.037 4.26 3A 0.036 5.08 3B 0.037 3.90 3C 0.033 3.99 4A 0.034 4.54 4B 0.051 5.00 4C 0.028 3.43 5A 0.033 4.01 5B 0.036 3.21 6A 0.033 3.35 6B 0.026 3.46 7B 0.023 2.99 ? Ventilation Airflow Rate Defaults o Installer-measured and documented ventilation airflow rate -OR- o HVI Rated equipment airflow rates
Comment #12Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 1-3Comment Intent: ObjectionComment Type: GeneralComment: I believe in allowing homes to be assigned default values instead of actual testing results would very much be a step in the opposite direction of which RESNET, and the industy as a whole are aiming towards. Not only that, but this practice would be very difficult to come back from, and would greatly hinder the future prospects of the HERS rating industry. With this we would almost be negating everything the HERS rating stands for, builders would start to build less effecient, and less safe homes, and ultimately home buyers would pay the price as well. This would also negatively affect utility programs, as homes would show less savings, so there would be a huge trickle effect that who knows how long it would take to recover from. All in all, builders are still building, and raters are still rating. Through be innovative and flexible everyone seems to have adapted to this new challenge that no one prepared for, but for the most part the industry is still going strong and has proven that drastic changes at this point just arent neccessary. In diluting the accuracy of the HERS rating like such we would be setting a dangerous precedent that would harm the industry as a whole, and even more so in the future.
I believe in allowing homes to be assigned default values instead of actual testing results would very much be a step in the opposite direction of which RESNET, and the industy as a whole are aiming towards. Not only that, but this practice would be very difficult to come back from, and would greatly hinder the future prospects of the HERS rating industry. With this we would almost be negating everything the HERS rating stands for, builders would start to build less effecient, and less safe homes, and ultimately home buyers would pay the price as well. This would also negatively affect utility programs, as homes would show less savings, so there would be a huge trickle effect that who knows how long it would take to recover from.
All in all, builders are still building, and raters are still rating. Through be innovative and flexible everyone seems to have adapted to this new challenge that no one prepared for, but for the most part the industry is still going strong and has proven that drastic changes at this point just arent neccessary. In diluting the accuracy of the HERS rating like such we would be setting a dangerous precedent that would harm the industry as a whole, and even more so in the future.
Comment #13Amendment: Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02Page Number: 2Paragraph / Figure / Table / Note: Exception 6, 1st paragraphComment Intent: ObjectionComment Type: GeneralComment: Some of our members have expressed concern about this addendum and mentioned unintended consequences that might negatively impact the integrity and quality assurance of HERS ratings through an extension of this exception for onsite airtightness tests and duct leakage tests. From a customer perspective, having a rating that includes a COVID-19 asterisk may also significantly reduce their confidence in what’s been specified and installed behind the walls, ultimately tarnishing the reputation of builders and high-performance homes. Onsite testing is extremely important to fully diagnose and report real results. The use of too many defaults has the potential to tarnish the efficacy of HERS ratings that are used for code requirements, utility rebates, and federal/state tax credits. To perform onsite testing, safety protocols have been developed over the past 9 months and include: cleaning and disinfecting any surfaces that are touched by an inspector/rater, mandatory face coverings, frequent hand washing, and use of alcohol-based hand sanitizer. We have created jobsite safety resources for COVID-19, which could be applied to raters doing onsite testing, and include: • A Coronavirus preparedness and response plan for construction; • A COVID-19 jobsite checklist and toolbox talk; • A COVID-19 jobsite safety video; and • A jobsite sanitation video. Recognizing that there will be extenuating circumstances in which onsite testing is not possible, procedures should be created for these situations to be evaluated on a case-by-case basis. For instance, a customer might not feel comfortable being in their home with raters and might not always be able to vacate the location for a designated amount of time prior to a rater arriving onsite. Regardless if these exceptions are due to COVID-19 or some other reason, we recommend adding language to establish a review process for evaluating onsite testing exceptions. By following CDC protocols for safety and by effectively communicating the precautions that will be taken on-site with the customer, in many instances raters can safely conduct onsite testing to protect the rigor and quality assurance of HERS ratings. When there is a need for an exception to this protocol, however, we recommend considering the below language changes. Proposed Change: RESNET Home Energy Ratings shall comply with the provisions of ANSI/RESNET/ICC 301, except during for dwelling units with a rating date on or up to 120 days after the effective date of this amendment established by the RESNET Standards Management Board. Due to the COVID pandemic, to be determined on a case-by-case basis. This Approved exceptions, as determined by RESNET, shall remain in effect until thirty (30) days after the Presidential Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak is lifted. Extreme cases in which a customer is not able to vacate the testing site or does not feel safe having a rater onsite, may be approved by RESNET for onsite testing exceptions. , dDwelling units with a “Date Rated” as reported to the Registry rated during that time are permitted to use default values in lieu of conducting air tightness testing of dwelling unit enclosures and duct systems as well as measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380, if approved by RESNET in advance. Ratings utilizing default test values must be compliant with RESNET’s Temporary Protocols for Alternative Testing During the COVID-19 Pandemic:
Some of our members have expressed concern about this addendum and mentioned unintended consequences that might negatively impact the integrity and quality assurance of HERS ratings through an extension of this exception for onsite airtightness tests and duct leakage tests. From a customer perspective, having a rating that includes a COVID-19 asterisk may also significantly reduce their confidence in what’s been specified and installed behind the walls, ultimately tarnishing the reputation of builders and high-performance homes. Onsite testing is extremely important to fully diagnose and report real results. The use of too many defaults has the potential to tarnish the efficacy of HERS ratings that are used for code requirements, utility rebates, and federal/state tax credits.
To perform onsite testing, safety protocols have been developed over the past 9 months and include: cleaning and disinfecting any surfaces that are touched by an inspector/rater, mandatory face coverings, frequent hand washing, and use of alcohol-based hand sanitizer. We have created jobsite safety resources for COVID-19, which could be applied to raters doing onsite testing, and include:
• A Coronavirus preparedness and response plan for construction; • A COVID-19 jobsite checklist and toolbox talk; • A COVID-19 jobsite safety video; and • A jobsite sanitation video.
Recognizing that there will be extenuating circumstances in which onsite testing is not possible, procedures should be created for these situations to be evaluated on a case-by-case basis. For instance, a customer might not feel comfortable being in their home with raters and might not always be able to vacate the location for a designated amount of time prior to a rater arriving onsite. Regardless if these exceptions are due to COVID-19 or some other reason, we recommend adding language to establish a review process for evaluating onsite testing exceptions.
By following CDC protocols for safety and by effectively communicating the precautions that will be taken on-site with the customer, in many instances raters can safely conduct onsite testing to protect the rigor and quality assurance of HERS ratings. When there is a need for an exception to this protocol, however, we recommend considering the below language changes.
RESNET Home Energy Ratings shall comply with the provisions of ANSI/RESNET/ICC 301, except during for dwelling units with a rating date on or up to 120 days after the effective date of this amendment established by the RESNET Standards Management Board. Due to the COVID pandemic, to be determined on a case-by-case basis. This Approved exceptions, as determined by RESNET, shall remain in effect until thirty (30) days after the Presidential Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak is lifted. Extreme cases in which a customer is not able to vacate the testing site or does not feel safe having a rater onsite, may be approved by RESNET for onsite testing exceptions. , dDwelling units with a “Date Rated” as reported to the Registry rated during that time are permitted to use default values in lieu of conducting air tightness testing of dwelling unit enclosures and duct systems as well as measuring airflow of mechanical ventilation systems in accordance with Standard ANSI/RESNET/ICC 380, if approved by RESNET in advance. Ratings utilizing default test values must be compliant with RESNET’s Temporary Protocols for Alternative Testing During the COVID-19 Pandemic:
Return to Proposed MINHERS Addendum 48f, COVID-19 Pandemic Exception for Onsite Airtightness Tests, Draft PDS-02