Comment #1Amendment: Proposed MINHERS Addendum 58, Pre-Drywall Inspections QA, Draft PDS-02Page Number: 1Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: TechnicalComment: Of the 25 Minimum rated features listed in the standards (ANSI 301-2019 4.5.2(1)) , only 5 are typically available for full inspection at pre-drywall: floor and foundation assembly wall assembly construction type and insulation rim joist insulation (maybe) window specifications skylights. Therefore, pre-drywall QA Field Reviews only capture 20% of the minimum rated features in an ideal situation. In addition, those features which are available at pre-drywall have a much smaller impact on the HERS Index than the other 20 minimum rated features. The other 20 minimum rated features include the following items which are typically not available for full verification until final and have a very large impact on the HERS Score Ceiling insulation (because ceilings are not typically insulated until after drywall Doors (because construction doors are typically in place until final) Passive solar systems Air infiltration testing Distribution systems (duct systems may not be complete, especially where building cavities are used and equipment is not installed yet) Heating equipment Cooling equipment Control systems (thermostats are typically installed after drywall and paint) Service hot water equipment Solar hot water equipment Light fixtures Refrigerator Dishwasher Range/Oven Clothes Washer Clothes Dryer Ceiling Fans Mechanical ventilation systems Pre-conditioning systems On site power production Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition toFor QA Field reviews on completed homes, for ratings on new homes, the Quality Assurance Designee may perform one or more a pre-drywall QA Field reviews on each HERS Rater or RFI. Pre-drywall QA Field reviews can be used to meet no more than 25% of the reviews for all or part of the annual 1% QA Field review requirement for a HERS Rater or RFI. However, HERS Raters or RFIs needing less than 4 1% QA Field reviews per year may use 1 Pre-Drywall Field QA once every four years. with the following limitation: Pre-Drywall Field QA Reviews may NOT be used to satisfy the full field QA requirement for a given rater or RFI in consecutive years. in addition to the QA Field reviews on completed homes, and can replace 10%, but no more than 25%, of the total number of QA Field reviews (rounded up).
Of the 25 Minimum rated features listed in the standards (ANSI 301-2019 4.5.2(1)) , only 5 are typically available for full inspection at pre-drywall:
Therefore, pre-drywall QA Field Reviews only capture 20% of the minimum rated features in an ideal situation. In addition, those features which are available at pre-drywall have a much smaller impact on the HERS Index than the other 20 minimum rated features.
The other 20 minimum rated features include the following items which are typically not available for full verification until final and have a very large impact on the HERS Score
904.3.3.1.3 Pre-drywall QA Field reviews. In addition toFor QA Field reviews on completed homes, for ratings on new homes, the Quality Assurance Designee may perform one or more a pre-drywall QA Field reviews on each HERS Rater or RFI. Pre-drywall QA Field reviews can be used to meet no more than 25% of the reviews for all or part of the annual 1% QA Field review requirement for a HERS Rater or RFI. However, HERS Raters or RFIs needing less than 4 1% QA Field reviews per year may use 1 Pre-Drywall Field QA once every four years. with the following limitation: Pre-Drywall Field QA Reviews may NOT be used to satisfy the full field QA requirement for a given rater or RFI in consecutive years. in addition to the QA Field reviews on completed homes, and can replace 10%, but no more than 25%, of the total number of QA Field reviews (rounded up).
Comment #2Amendment: Proposed MINHERS Addendum 58, Pre-Drywall Inspections QA, Draft PDS-02Page Number: 1Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: Not an ObjectionComment Type: EditorialComment: “This comment is being issued on behalf of the QAD Committee of the North East Home Energy Rating Alliance, which represents more than 175 Raters and 9 Providers from New Jersey to Maine.” We appreciate the intention to simplify the language of this section. Our comment is a suggestion to reword the revised sentence. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition toFor QA Field reviews on completed homes, for ratings on new homes, the Quality Assurance Designee may perform one or more a pre-drywall QA Field reviews on each HERS Rater or RFI. Pre-drywall QA Field reviews can be used to meet all or part of the annual 1% QA Field review requirement for a HERS Rater or RFI with the following limitation: Pre-Drywall Field QA Reviews may NOT be used to satisfy the full total amount of field QA requirementd for a given Rater or RFI in consecutive years. For a Rater or RFI with an anticipated volume of 100 units or less annually, a Pre-Drywall Field QA review may onlly be performed every other year. in addition to the QA Field reviews on completed homes, and can replace 10%, but no more than 25%, of the total number of QA Field reviews (rounded up). 904.3.3.1.4 For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review can be on a completed home and one (1) additional QA Field review can be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review may be performed and can count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews may be performed and they can count towards two, but no more than two, of the QA Field reviews.
“This comment is being issued on behalf of the QAD Committee of the North East Home Energy Rating Alliance, which represents more than 175 Raters and 9 Providers from New Jersey to Maine.”
We appreciate the intention to simplify the language of this section. Our comment is a suggestion to reword the revised sentence.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition toFor QA Field reviews on completed homes, for ratings on new homes, the Quality Assurance Designee may perform one or more a pre-drywall QA Field reviews on each HERS Rater or RFI. Pre-drywall QA Field reviews can be used to meet all or part of the annual 1% QA Field review requirement for a HERS Rater or RFI with the following limitation: Pre-Drywall Field QA Reviews may NOT be used to satisfy the full total amount of field QA requirementd for a given Rater or RFI in consecutive years. For a Rater or RFI with an anticipated volume of 100 units or less annually, a Pre-Drywall Field QA review may onlly be performed every other year. in addition to the QA Field reviews on completed homes, and can replace 10%, but no more than 25%, of the total number of QA Field reviews (rounded up). 904.3.3.1.4 For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review can be on a completed home and one (1) additional QA Field review can be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review may be performed and can count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews may be performed and they can count towards two, but no more than two, of the QA Field reviews.
Return to Proposed MINHERS Addendum 58, Pre-Drywall Inspections QA, Draft PDS-02