Comment #1Amendment: Proposed MINHERS Addendum 65f, 3rd Party HERS Ratings Ownership, Draft PDS-01Page Number: 9Paragraph / Figure / Table / Note: 502.7 & 502.7.1Comment Intent: ObjectionComment Type: GeneralComment: As written, proposed Section 502.7 and Section 502.7.1 may result in unintended consequences. Notably: This could allow for a scenario in which one energy model with two different Standards versions may be required for one home. Consider a case where a township has a RESNET HERS target requirement which requires the current Standards version, and a local Third Party Energy Efficiency Program that requires a previous Standards version. This raises multiple issues, notably: Many industry software tools do not allow changes to energy models, (including algorithm versions), after the model has been registered with the building registry without the review of the provider. This would result in a modeler having to run two analyses, and the provider having to review two documents as well as submit two models to the Building Registry, substantially increasing the cost and workload per home. A single address may now be issued two (2) confirmed HERS Certificates with different scores. This may confuse homeowners, builders, and others, as well as work towards undermining the perceived validity of the HERS Index. This would greatly increase the burden on Rating Providers and Quality Assurance Designees in a variety of ways, notably: Rating Providers would have to verify the program requirements of each Third Party Energy Efficiency Program to ensure the correct Standards version/software version were being used. For Providers covering large portions of the country, this burden would be substantial for both “real-time” guidance as well as for Quality Assurance requirements. Providers would have to register and/or review homes twice as part of the current software workflow for many industry software. This would lead to data inferiority as many programs are referred to by industry names, shorthand or abbreviated names, vague names, or their full legal name. Leaving this up to the individual user without a standardized selection list would increase the burden of Quality Assurance and decrease the data integrity of the Building Registry. No clear guidance is provided for Rating Companies and Rating Providers on how to “note” (as the current version of the amendment suggests) which Third Party Energy Efficiency Program is used inside the Rating file, which could lead to further inconsistencies with the data in the Registry. For these reasons we feel that this amendment should be further clarified and RESNET should provide more regulated oversight to this new process. This Public Comment was co-developed by members of the RENSET ELC Standards Working Group. Proposed Change: 502.7 Where a state or local energy code, green bond or other Third Party Energy Efficiency Program wishes to references a previously approved publication and/or addenda that version supersedes the Mandatory Compliance Date., they must alert and register their program with RESNET using an application process developed and maintained by RESNET. RESNET will keep and maintain a public record of the Third Party Energy Efficiency Program’s official name, and the corresponding approved software version for each of the RESNET Approved Softwares, so that Rating Companies and Rating Providers are able to identify when a rating is acceptable to be registered in a older version of a software, or when it would otherwise be past the Mandatory Compliance Date of the current version of the RESNET Standards as defined in Sections 502.5.1 through 502.5.3. This only applies to ratings required for compliance with energy code requirements or other Third Party Energy Efficiency Programs. 502.7.1 All ratings are permitted to be entered into the RESNET National Buildings Registry and will assumed to be in compliance with the current version of the RESNET Standards, or will identify which Third Party Energy Efficiency Program, from the RESNET managed list of approved Third Party Energy Efficiency Programs that the rating is intended to comply with.with a note stating compliance with RESNET’s program or identifying which Third Party Energy Efficiency Program the rating is intended to comply with. 502.7.2 RESNET shall create, maintain, and provide all RESNET Approved Softwares an updated schema of Project Level details to account for the list of approved Third Party Energy Efficiency Programs in their software. The list of approved Third Party Energy Efficiency Programs shall be shared with all RESNET Approved Softwares as updates are made so they are able to update their code accordingly. 502.7.3 RESNET shall ensure that the public search function of the HERS Index Score notes whether a rating was submitted under the current version of the RESNET Standards or the name of the approved Third Party Energy Efficiency Program.
As written, proposed Section 502.7 and Section 502.7.1 may result in unintended consequences. Notably:
For these reasons we feel that this amendment should be further clarified and RESNET should provide more regulated oversight to this new process.
This Public Comment was co-developed by members of the RENSET ELC Standards Working Group.
502.7 Where a state or local energy code, green bond or other Third Party Energy Efficiency Program wishes to references a previously approved publication and/or addenda that version supersedes the Mandatory Compliance Date., they must alert and register their program with RESNET using an application process developed and maintained by RESNET. RESNET will keep and maintain a public record of the Third Party Energy Efficiency Program’s official name, and the corresponding approved software version for each of the RESNET Approved Softwares, so that Rating Companies and Rating Providers are able to identify when a rating is acceptable to be registered in a older version of a software, or when it would otherwise be past the Mandatory Compliance Date of the current version of the RESNET Standards as defined in Sections 502.5.1 through 502.5.3. This only applies to ratings required for compliance with energy code requirements or other Third Party Energy Efficiency Programs.
502.7.1 All ratings are permitted to be entered into the RESNET National Buildings Registry and will assumed to be in compliance with the current version of the RESNET Standards, or will identify which Third Party Energy Efficiency Program, from the RESNET managed list of approved Third Party Energy Efficiency Programs that the rating is intended to comply with.with a note stating compliance with RESNET’s program or identifying which Third Party Energy Efficiency Program the rating is intended to comply with.
502.7.2 RESNET shall create, maintain, and provide all RESNET Approved Softwares an updated schema of Project Level details to account for the list of approved Third Party Energy Efficiency Programs in their software. The list of approved Third Party Energy Efficiency Programs shall be shared with all RESNET Approved Softwares as updates are made so they are able to update their code accordingly.
502.7.3 RESNET shall ensure that the public search function of the HERS Index Score notes whether a rating was submitted under the current version of the RESNET Standards or the name of the approved Third Party Energy Efficiency Program.
Comment #2Amendment: Proposed MINHERS Addendum 65f, 3rd Party HERS Ratings Ownership, Draft PDS-01Page Number: Ch 1Paragraph / Figure / Table / Note: 105.23Comment Intent: ObjectionComment Type: TechnicalComment: For a Standard update, still not specific enough of software version required. Software versions are released with 0-day bugs. For instance if version 8.0.4 is the fourth release(patch) within the current month alone, per this standard we may be out of compliance by someone simply forgetting to update their software for any number of reasons. Proposed Change: The most appropriate requirement of usage at the moment would be per major software update(version 8.x.x to 9.x.x vs minor or patch updates 8.1.4 to 8.1.5) or within a set window upon release(previously 6 months but 30-90 within reason). To add to this, we are now required to submit an appeal to the Standing Software Consistency Committee (SCC) for resolution, turning the user(us) into QC at our own expense while fearing compliance issues to simply maintain workflow.
For a Standard update, still not specific enough of software version required. Software versions are released with 0-day bugs. For instance if version 8.0.4 is the fourth release(patch) within the current month alone, per this standard we may be out of compliance by someone simply forgetting to update their software for any number of reasons.
The most appropriate requirement of usage at the moment would be per major software update(version 8.x.x to 9.x.x vs minor or patch updates 8.1.4 to 8.1.5) or within a set window upon release(previously 6 months but 30-90 within reason). To add to this, we are now required to submit an appeal to the Standing Software Consistency Committee (SCC) for resolution, turning the user(us) into QC at our own expense while fearing compliance issues to simply maintain workflow.
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