Comment #1Amendment: Proposed Standard Amendment on Rating Software AccreditationPage Number: 1Paragraph / Figure / Table / Note: 103.2Comment Intent: Not an ObjectionComment Type: GeneralComment: There is no wording specifying that a HERS Rating in process can still use the version of software that it began in. I think this would cause undu hardship to builders who may have to make changes in the middle of the rating. Proposed Change: I think there should be a Section 103.3 103.3 Persistence. Once a Projected Rating has been made on a property, the version of the rating software that was used initially may be used for the Confirmed Rating on that property. Providers, at their option, may update to the latest software version for in-process ratings.
There is no wording specifying that a HERS Rating in process can still use the version of software that it began in. I think this would cause undu hardship to builders who may have to make changes in the middle of the rating.
I think there should be a Section 103.3
103.3 Persistence. Once a Projected Rating has been made on a property, the version of the rating software that was used initially may be used for the Confirmed Rating on that property. Providers, at their option, may update to the latest software version for in-process ratings.
Comment #2Amendment: Proposed Standard Amendment on Rating Software AccreditationPage Number: 1Paragraph / Figure / Table / Note: 103.2Comment Intent: Not an ObjectionComment Type: GeneralComment: Requesting the inclusion of language that homes may be submitted under the version of software they began in. Without this, the HERS index is subject to change for a home in the middle of the rating which not only will cause confusion but opens questions of validity. Proposed Change: Addition of Section 103.3 103.3 Persistence. Once a Projected Rating has been made on a property, the version of the rating software, used initially, may be used for the Confirmed Rating on that property. Providers, at their option, may update to the latest software version for in-process ratings.
Requesting the inclusion of language that homes may be submitted under the version of software they began in. Without this, the HERS index is subject to change for a home in the middle of the rating which not only will cause confusion but opens questions of validity.
Addition of Section 103.3
103.3 Persistence. Once a Projected Rating has been made on a property, the version of the rating software, used initially, may be used for the Confirmed Rating on that property. Providers, at their option, may update to the latest software version for in-process ratings.
Comment #3Amendment: Proposed Standard Amendment on Rating Software AccreditationPage Number: Rating SoftwareParagraph / Figure / Table / Note: 103.1Comment Intent: ObjectionComment Type: GeneralComment: I work as a rater on primarily federally and state tax credit funded low income housing. As you may know some of these projects can take nearly a year from the time they apply for funding to the time they start construction. During the funding application stage, developers get points or priority based on the HERS rating that the project will achieve. At this stage we run preliminary energy models to submit to the funding agency showing what features will be included in the project and the HERS rating they will achieve. My problem with this amendment is that budgets on these projects are very tight. If we are achieving a HERS rating of 60 during the application stage, and the budgets are based off of those preliminary energy models, then a new version of RemRate may make that exact same house score a 62 instead of a 60. If the developer has promised to achive a 60 then this could pose a very large issue at the end of the project when all of the sudden they have built the project in accordance with our preliminary energy models but are not achieving what I, as a rater, told them they would achieve. It will be very difficult to explain to the builder that although they built the project in accordance with our original plans, there has been an update in the software, and now they are not achieving the same score. Proposed Change: No change
I work as a rater on primarily federally and state tax credit funded low income housing. As you may know some of these projects can take nearly a year from the time they apply for funding to the time they start construction.
During the funding application stage, developers get points or priority based on the HERS rating that the project will achieve. At this stage we run preliminary energy models to submit to the funding agency showing what features will be included in the project and the HERS rating they will achieve.
My problem with this amendment is that budgets on these projects are very tight. If we are achieving a HERS rating of 60 during the application stage, and the budgets are based off of those preliminary energy models, then a new version of RemRate may make that exact same house score a 62 instead of a 60. If the developer has promised to achive a 60 then this could pose a very large issue at the end of the project when all of the sudden they have built the project in accordance with our preliminary energy models but are not achieving what I, as a rater, told them they would achieve. It will be very difficult to explain to the builder that although they built the project in accordance with our original plans, there has been an update in the software, and now they are not achieving the same score.
No change
Comment #4Amendment: Proposed Standard Amendment on Rating Software AccreditationPage Number: 1Paragraph / Figure / Table / Note: 103.2Comment Intent: ObjectionComment Type: GeneralComment: The Proposed Standard Amendment is ambiguous. It seems that the Amendment could affect the existing sections 103.2.1 Transition period and 103.2.3 Persistence, but it does not describe if and how they are affected. Please include in the Amendment a description of how those sections wil be affected.
The Proposed Standard Amendment is ambiguous. It seems that the Amendment could affect the existing sections 103.2.1 Transition period and 103.2.3 Persistence, but it does not describe if and how they are affected. Please include in the Amendment a description of how those sections wil be affected.
Comment #5Amendment: Proposed Standard Amendment on Rating Software AccreditationPage Number: 103Paragraph / Figure / Table / Note: 103Comment Intent: Not an ObjectionComment Type: TechnicalComment: It would cause hardship to change the version of the software to the most current version. Alternatively, I’d suggest a sunset date to phase out the oldest software versions over time. This would provide rater with sufficient time to coordinate with project teams while holding all ratings to a fairly common standard. This is also more practical to enforce and track. Proposed Change: This amendment appears to have inadvertently omitted the current section 103.2 Rating Software Changes. This proposed change address that omission and adds the inclusion of a sunset date, which would facilitate tracking of projects that are using the section on Peristence. 103 Rating Software 103.1 Accreditation All HERS Software Tools shall be accredited by RESNET. 103.12 Version Requirement For the purposes of conducting Home Energy Ratings, as defined in these standards, QA Providers shall be required to use the most current version of one of the RESNET approved rating Accredited HERS sSoftware programs contained Tools listed in the “National Registry of Accredited Rating Software Programs” posted on the RESNET website. 103.23 Rating Software Changes Should changes that affect the calculated results of the home energy rating occur in the engineering algorithms of a RESNET approved home energy rating software program, QA Providers shall be required to do the following: 103.23.1 Transition period. On announcement of a new software version release, QA Providers have a maximum of 60 days to begin all new ratings with the new version. 103.23.2 This requirement only applies to changes mandated by the technical standard or otherwise affecting the calculations of the rating score or projected energy savings. 103.23.3 Persistence. Once a Projected Rating has been made on a property, the version of the rating software that was used initially may be used for the Confirmed Rating on that property until the version’s sunset date. Once the sunset date has been reached, the Confirmed Rating shall update to the next eligible version, which is not required to be the most current software version. For example, a Projected Rating may begin using a software version if uploaded as a Confirmed Rating prior to the sunset date for that version. If uploaded after the sunset date, the Confirmed Rating must update to a version that has not reached its sunset date. Providers, at their option, may update to the latest software version for in-process ratings.
It would cause hardship to change the version of the software to the most current version. Alternatively, I’d suggest a sunset date to phase out the oldest software versions over time. This would provide rater with sufficient time to coordinate with project teams while holding all ratings to a fairly common standard. This is also more practical to enforce and track.
This amendment appears to have inadvertently omitted the current section 103.2 Rating Software Changes. This proposed change address that omission and adds the inclusion of a sunset date, which would facilitate tracking of projects that are using the section on Peristence.
103 Rating Software 103.1 Accreditation All HERS Software Tools shall be accredited by RESNET.
103.12 Version Requirement For the purposes of conducting Home Energy Ratings, as defined in these standards, QA Providers shall be required to use the most current version of one of the RESNET approved rating Accredited HERS sSoftware programs contained Tools listed in the “National Registry of Accredited Rating Software Programs” posted on the RESNET website. 103.23 Rating Software Changes Should changes that affect the calculated results of the home energy rating occur in the engineering algorithms of a RESNET approved home energy rating software program, QA Providers shall be required to do the following:
103.23.1 Transition period. On announcement of a new software version release, QA Providers have a maximum of 60 days to begin all new ratings with the new version.
103.23.2 This requirement only applies to changes mandated by the technical standard or otherwise affecting the calculations of the rating score or projected energy savings.
103.23.3 Persistence. Once a Projected Rating has been made on a property, the version of the rating software that was used initially may be used for the Confirmed Rating on that property until the version’s sunset date. Once the sunset date has been reached, the Confirmed Rating shall update to the next eligible version, which is not required to be the most current software version. For example, a Projected Rating may begin using a software version if uploaded as a Confirmed Rating prior to the sunset date for that version. If uploaded after the sunset date, the Confirmed Rating must update to a version that has not reached its sunset date. Providers, at their option, may update to the latest software version for in-process ratings.
Comment #6Amendment: Proposed Standard Amendment on Rating Software AccreditationPage Number: 1Paragraph / Figure / Table / Note: 103.12Comment Intent: ObjectionComment Type: TechnicalComment: The most current proposed amendment of 103 Rating Software should clarify that the most current software should only apply at the time of the preliminary rating. Some buildings take many months, or even years, to complete the building cycle. Using different versions of software for the preliminary and confirmed rating will produce ratings that are unpredictable. That is bad from a market perspective and bad from a quality assurance perspective. Proposed Change: 103.12 Version Requirement For the purposes of conducting Home Energy Ratings, as defined in these standards, QA Providers shall, at the time of the preliminary rating, be required to use the most current version of one of the RESNET approved rating Accredited HERS sSoftware programs contained Tools listed in the “National Registry of Accredited Rating Software Programs” posted on the RESNET website.
The most current proposed amendment of 103 Rating Software should clarify that the most current software should only apply at the time of the preliminary rating. Some buildings take many months, or even years, to complete the building cycle. Using different versions of software for the preliminary and confirmed rating will produce ratings that are unpredictable. That is bad from a market perspective and bad from a quality assurance perspective.
103.12 Version Requirement For the purposes of conducting Home Energy Ratings, as defined in these standards, QA Providers shall, at the time of the preliminary rating, be required to use the most current version of one of the RESNET approved rating Accredited HERS sSoftware programs contained Tools listed in the “National Registry of Accredited Rating Software Programs” posted on the RESNET website.
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