Comment #1Amendment: Proposed MINHERS Addendum 52f, Rater and RFI Eligibility Requirements for HVAC Installation Grading, Draft PDS-02Page Number: 3Paragraph / Figure / Table / Note: 102.1.10.1Comment Intent: ObjectionComment Type: EditorialComment: One hallmark of HERS ratings is the third-party verification completed by Raters and RFI’s. However, the proposed language would allow parties other than third-party verifiers, such as HVAC contractors, to verify their own HVAC installation quality, for the purpose of a HERS rating. While Std. 310 envisions such possibilities, it requires that the HVAC contractors or other parties operate under a third-party quality control program that has been approved for use by RESNET. In this construct, the third-party quality control program, such as one implemented by ACCA, would be responsible for overseeing the parties verifying their own work and would issue Independent Verification Reports on a job-by-job basis. The proposed edits reflect this alternative compliance structure. Proposed Change: 102.1.10 Ensure those individuals providing grading for equipment installations under ANSI/RESNET/ACCA Standard 310 that are reflected in HERS Ratings submitted by the Rating Quality Assurance Provider are eligible to do so. 102.1.10.1 The following individuals are eligible to conduct inspections for ANSI/RESNET/ACCA Standard 310: 102.1.10.1.1 Certified HERS Raters and Rating Field Inspectors confirmed as eligible per 102.1.10. 102.1.10.1.2 HVAC contractors or other individuals operating under a third-party quality control program, developed with ACCA or other industry partners and approved by RESNET, that issues Independent Verification Reports Individuals certified by EPA approved HVAC Quality Installation Training and Oversight Organizations (H-QUITO) 102.1.10.1.3 Individuals certified by the Air Conditioning Contractors of America HVAC Quality Assured Accreditation Program 102.1.10.1.4 Other Third Party Quality Assured HVAC Installation Programs approved by RESNET
One hallmark of HERS ratings is the third-party verification completed by Raters and RFI’s. However, the proposed language would allow parties other than third-party verifiers, such as HVAC contractors, to verify their own HVAC installation quality, for the purpose of a HERS rating.
While Std. 310 envisions such possibilities, it requires that the HVAC contractors or other parties operate under a third-party quality control program that has been approved for use by RESNET. In this construct, the third-party quality control program, such as one implemented by ACCA, would be responsible for overseeing the parties verifying their own work and would issue Independent Verification Reports on a job-by-job basis. The proposed edits reflect this alternative compliance structure.
102.1.10 Ensure those individuals providing grading for equipment installations under ANSI/RESNET/ACCA Standard 310 that are reflected in HERS Ratings submitted by the Rating Quality Assurance Provider are eligible to do so.
102.1.10.1 The following individuals are eligible to conduct inspections for ANSI/RESNET/ACCA Standard 310:
102.1.10.1.1 Certified HERS Raters and Rating Field Inspectors confirmed as eligible per 102.1.10.
102.1.10.1.2 HVAC contractors or other individuals operating under a third-party quality control program, developed with ACCA or other industry partners and approved by RESNET, that issues Independent Verification Reports Individuals certified by EPA approved HVAC Quality Installation Training and Oversight Organizations (H-QUITO)
102.1.10.1.3 Individuals certified by the Air Conditioning Contractors of America HVAC Quality Assured Accreditation Program
102.1.10.1.4 Other Third Party Quality Assured HVAC Installation Programs approved by RESNET
Comment #2Amendment: Proposed MINHERS Addendum 52f, Rater and RFI Eligibility Requirements for HVAC Installation Grading, Draft PDS-02Page Number: 7Paragraph / Figure / Table / Note: 206.2.3.2.1Comment Intent: Not an ObjectionComment Type: EditorialComment: While certified HERS Raters/RFIs will have previously demonstrated proficiency in performing testing associated with ANSI 380, this does not translate into proficiency in testing related to blower fan airflow, watt draw, or refrigerant charge. Certified HERS Raters/RFIs may also have had little to no experience in performing duct leakage testing. As such, we recommend a minimum of one mentored inspection relevant to the specific tasks of ANSI/ACCA 310. Proposed Change: 206.2.3.2??Maintaining?Eligibility:?? 206.2.3.2.1??Certified?HERS Raters and Rating Field Inspectors who have not completed any ANSI/RESNET/ACCA Standard 310 inspections?or successfully completed a RESNET HVAC graded field evaluation?within?their current HERS Rater or RFI Certification?period?shall successfully complete one mentored HVAC grading evaluation and one RESNET HVAC graded field evaluation to maintain eligibility. The RESNET HVAC graded field evaluation shall be performed under the observation and to the satisfaction of a Certified Quality Assurance Designee who has completed RESNET Required HVAC Grading training.? 206.2.3.2.2? Certified?HERS Raters and Rating Field Inspectors must?complete any additional training and/or attend additional?presentations as required by RESNET to maintain their eligibility after completion of their initial training?and graded field evaluation.? 206.2.3.2.3 Certified HERS Raters and Rating Field Inspectors agree to?File and Field QA requirements specific to these inspections as detailed in Chapter 9.
While certified HERS Raters/RFIs will have previously demonstrated proficiency in performing testing associated with ANSI 380, this does not translate into proficiency in testing related to blower fan airflow, watt draw, or refrigerant charge. Certified HERS Raters/RFIs may also have had little to no experience in performing duct leakage testing. As such, we recommend a minimum of one mentored inspection relevant to the specific tasks of ANSI/ACCA 310.
206.2.3.2??Maintaining?Eligibility:??
206.2.3.2.1??Certified?HERS Raters and Rating Field Inspectors who have not completed any ANSI/RESNET/ACCA Standard 310 inspections?or successfully completed a RESNET HVAC graded field evaluation?within?their current HERS Rater or RFI Certification?period?shall successfully complete one mentored HVAC grading evaluation and one RESNET HVAC graded field evaluation to maintain eligibility. The RESNET HVAC graded field evaluation shall be performed under the observation and to the satisfaction of a Certified Quality Assurance Designee who has completed RESNET Required HVAC Grading training.?
206.2.3.2.2? Certified?HERS Raters and Rating Field Inspectors must?complete any additional training and/or attend additional?presentations as required by RESNET to maintain their eligibility after completion of their initial training?and graded field evaluation.?
206.2.3.2.3 Certified HERS Raters and Rating Field Inspectors agree to?File and Field QA requirements specific to these inspections as detailed in Chapter 9.
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