Proposed Substantive Changes to MINHERS Chapter 2

Comment #1

Amendment: Proposed Substantive Changes to MINHERS Chapter 2
Page Number: 4
Comment Intent: Objection
Comment Type: General

Comment:

Do not accept proposed amendment.  Only need to add a clear definition of a Probationary Rating as intended.  Three of the five ratings should stay as confirmed and entered into the Registry because they will be performed in the presence of a Candidate Field Assessor.  This is already stated in the amendment that will go into effect on January 1, 2018.  These ratings will also fall under the Quality Assurance requirements for the QA Provider.

With these probationary ratings being entered into the Registry, RESNET Staff will more easily be able to track when the status of a New Rater is eligible to change to Active.  Under the current system, it is self-reporting on the part of the Provider when the candidate’s status changes to Active.

Proposed Change:

Proposed Definition for Probationary Rating

Probationary ratings are ratings conducted by a Rater Candidate while supervised by a Candidate Field Assessor under the auspices of an Accredited RESNET Rating Provider.

Response:

Accept

Remove confirmed rating from section on probationary ratings


Comment #2

Amendment: Proposed Substantive Changes to MINHERS Chapter 2
Page Number: 3 & 4 of 5 (amendment document)
Paragraph / Figure / Table / Note: 205.2.3.3
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

The section that states, "with the exception that the work is not being performed by a currently Certified Rater." is a bit awkward and confusing. This is more clearly represented by the next sentence, "Probationary ratings shall not be
considered Confirmed Ratings." I propose deleting the awkward redundant language and just leave the second part.

Proposed Change:

205.2.3.3
   After passing the all of the RESNET tests, but prior to being certified, the candidate
shall complete five probationary ratings with a Rating Quality Assurance Provider overseen by a RESNET certified Candidate Field Assessor. At least three of the five probationary ratings shall be confirmed ratings accomplished using field data gathered and field verification of all rated features of the home in accordance with Section 303.8 and Chapter 8. ; with the exception that the work is not being performed by a currently Certified Rater.  Probationary ratings shall not be considered Confirmed Ratings.

Response:

Accept


Comment #3

Amendment: Proposed Substantive Changes to MINHERS Chapter 2
Page Number: 3 & 4 of 5 (amendment document)
Paragraph / Figure / Table / Note: 205.2.3.3
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

The proposed language is not clear or consistent about how the Candidate Field Assessor's oversight of the rater candidate's field probationary ratings shall be performed. It could loosely be interpreted to mean that a Candidate Field Assessor only need to perform a desk file review of the ratings submitted by the rater candidate and never actually provide any physical onsite training and mentoring whatsoever. Clearly, this is not the intent of the language or in accordance with RESNET's goals of improving the consistency of HERS rating. For example, in Section 205.2.3.4.2, it is made clear that the field probationary rating "shall be completed in the presence of a RESNET certified Candidate Field Assessor." In order to provide continuity and consistency, it should also state this in Section 205.2.3.3.

This clarifying language will ensure that rater candidates are receiving adequate field training and oversight, the lack of which is the most significant deficit in the current training and certification of raters and their subsequent understanding of how to perform HERS ratings. This is also possibly the most significant cause of the lack of consistency in general in the HERS industry. In keeping with RESNET's mantra of "improving the consistency of HERS ratings", let's solve the root of the problem and provide clear, consistent language that hands-on, in-person, onsite, physical field training and mentoring is required for the certification of raters. Three is obviously a very small number, but by making this the very minimum required for in-person field mentoring, it will be a significant improvement over the current interpretation of the language.

Therefore, I propose the addition of the clarifying language, "and shall be completed in the presence of a RESNET certified Candidate Field Assessor."

I also propose the additional language, "at least one of which shall be completed one-on-one." This will aid in avoiding "guerilla" training practices employed by some organizations where a group of rater candidates are rushed through the entire field training requirement in a single day, the intent of which is merely to meet the minimum intent of the standards language, not to actually provide a meaningful and beneficial training experience. This will provide an additional layer of assurance that rater candidates have received adequate field training and have been field verified by a Candidate Field Assessor to possess the minimum skills necessary to perform a HERS rating in full compliance with the RESNET Standards. A simulation is a great start as an initial training tool, but the field training component is where the real learning takes place.

I have heard about an analogy of rating homes being compared to flying an airplane and that since pilots are trained using simulators, that this could potentially be sufficient for HERS raters. Check out this link and see if you can find any validity to this fallacious argument: http://www.wikihow.com/Become-an-Airline-Pilot

This is an example of poor reasoning called a weak or false analogy, where an analogy is used to prove or disprove an argument, but the analogy is too dissimilar to be effective, that is, it is unlike the argument more than it is like the argument. However, many of us are unwittingly lured and convinced by such fallacious reasoning. The truth is that Boeing makes 5 commercial passenger aircraft, and pilots are required to log more than 1,500 hours before they are allowed in the cockpit, then at least 3,000 more as a co-pilot under the direct supervision of a seasoned licensed pilot, aka a Captain. Homes have an infinite number of variables, and therefore cannot be reasonably compared to the small handful of models of aircraft used to train pilots. The more significant fallacy of logic in this argument is that raters could be certified and have full comprehension of how to perform a rating with only a simulation based training. Would you ever sit in a commercial passenger jet with a pilot who has only had simulation training? Then why would we allow a rater candidate to perform Confirmed Ratings with the same basic and terse understanding of HERS ratings? The point is that simulation training just gets candidates to the point where the real training can begin, and it can never and should never take the place of hands-on field mentored training under the physical supervision and guidance of a seasoned, certified professional.

Proposed Change:

205.2.3.3
   After passing the all of the RESNET tests, but prior to being certified, the candidate
shall complete five probationary ratings with a Rating Quality Assurance Provider overseen by a RESNET certified Candidate Field Assessor. At least three of the five probationary ratings shall be confirmed ratings accomplished using field data gathered and field verification of all rated features of the home in accordance with Section 303.8 and Chapter 8 and shall be completed in the presence of a RESNET certified Candidate Field Assessor, at least one of which shall be completed one-on-one. ; with the exception that the work is not being performed by a currently Certified Rater. Probationary ratings shall not be considered Confirmed Ratings.

Response:

Accept as modified and change “overseen by” to “in the presence of”


Comment #4

Amendment: Proposed Substantive Changes to MINHERS Chapter 2
Page Number: 3 & 4 of 5 (amendment document)
Paragraph / Figure / Table / Note: 205.2.3.4.2
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

Additional language is needed to clarify that the initial five probationary ratings must be completed in any event. It could possibly be misinterpreted that if a rater candidate goes past 15 months without completing a single probationary rating, that all they need to do is pass the rater exam again and do three probationary ratings.

Therefore, I propose adding the clarifying language, "in addition to the initial (5) probationary ratings required for certification."

The section that states, "with the exception that the work is not being performed by a currently Certified Rater." is a bit awkward and confusing. This is more clearly represented by the next sentence, "Probationary ratings shall not be
considered Confirmed Ratings."

I propose deleting the awkward redundant language and just leave the second part.

Proposed Change:

205.2.3.4.2
Complete three (3) additional probationary ratings in addition to the initial (5) probationary ratings required for certification. One of the three (3) additional probationary ratings shall be a Confirmed Rating accomplished using field data gathered and field verification of all rated features of the home in accordance with Section 303.8 and Chapter 8; with the exception that the work is not being performed by a currently Certified Rater and shall be completed in the presence of a RESNET certified Candidate Field Assessor. Probationary ratings shall not be considered Confirmed Ratings.

Response:

Reject

this amendment does not address the number of additional probationary rating required if a rater candidate does not complete the probationary ratings in the required timeframe so that section is not subject to comment


Comment #5

Amendment: Proposed Substantive Changes to MINHERS Chapter 2
Page Number: 3 of 5 (amendment document)
Paragraph / Figure / Table / Note: 205.2.3.3
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

This is not actually part of the proposed changes, but needs to be fixed. I am confident this one will be approved. :)

Please delete the word "the".

Proposed Change:

205.2.3.3
   After passing the all of the RESNET tests, but prior to being certified, the candidate
shall complete five probationary ratings with a Rating Quality Assurance Provider overseen by a RESNET certified Candidate Field Assessor.

Response:

Reject

this comment was made on a section that was not open for public comment. However, the proposed changes will be made as a SDC 900 initiative since they are editorial only.


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