Comment #1Amendment: Proposed MINHERS Addendum 28, Add a Definition of Confirmed Threshold RatingPage Number: 1Comment Intent: Not an ObjectionComment Type: GeneralComment: I've been a HERS Rater for about 7 years and samplling on multifamily projects most of that time, and after reading the definition I don't understand what a Confirmed Threshold Rating is. This is the first I have heard of it, and I feel like I'm missing some context. If field inspections are conducted on each home, then how is this different from a Confirmed Rating. Is it just that the actuall test results aren't entered into the Threshold Ratings? Is this just a time saving technique of not having to enter specific results into individual files and making it easier to batch duplicate ratings? Proposed Change: I would like to offer better language, but I'm not sure what you are getting at in the first place.
I've been a HERS Rater for about 7 years and samplling on multifamily projects most of that time, and after reading the definition I don't understand what a Confirmed Threshold Rating is. This is the first I have heard of it, and I feel like I'm missing some context.
If field inspections are conducted on each home, then how is this different from a Confirmed Rating. Is it just that the actuall test results aren't entered into the Threshold Ratings? Is this just a time saving technique of not having to enter specific results into individual files and making it easier to batch duplicate ratings?
I would like to offer better language, but I'm not sure what you are getting at in the first place.
Comment #2Amendment: Proposed MINHERS Addendum 28, Add a Definition of Confirmed Threshold RatingPage Number: 1Comment Intent: ObjectionComment Type: GeneralComment: I'm not quite understanding why the confimed threshold rating would only apply to confirmed ratings for homes that have been 100% inspected/tested. The language "with field inspections and testing accomplished on every home" leads to assume that this type of rating cannot be used for sampled ratings. What's the point of applying this type of rating if you have actual inspected/tested performance data? This is a shame because the most useful and beneficial circumstance for a threshold rating would be where sampling protocols are used to test a % of units and they all meet or are below their acceptable program thresholds. This way, the thresholds can be used for sampled ratings and not just confirmed ratings. For sampled ratings, the worst-case tested or threshold should be allowable for calculating the HERS Index. Proposed Change: Confirmed Threshold Ratings: A type of confirmed ratings for homes where the HERS Index is calculated using Threshold Specifications with field inspections and testing accomplished on every home. Threshold Ratings: A type of sampled or confirmed rating for homes where the HERS Index is calculated using Threshold Specifications, as determined by certain program criteria, with field inspections and testing accomplished on the minimum required units as per RESNET sampling protocol. Thresholds, or worst-case test results, should be used to represent sampled units that have not been confirmed/tested but are represented by units that have passed the Threshold Specifications.
I'm not quite understanding why the confimed threshold rating would only apply to confirmed ratings for homes that have been 100% inspected/tested. The language "with field inspections and testing accomplished on every home" leads to assume that this type of rating cannot be used for sampled ratings. What's the point of applying this type of rating if you have actual inspected/tested performance data? This is a shame because the most useful and beneficial circumstance for a threshold rating would be where sampling protocols are used to test a % of units and they all meet or are below their acceptable program thresholds. This way, the thresholds can be used for sampled ratings and not just confirmed ratings. For sampled ratings, the worst-case tested or threshold should be allowable for calculating the HERS Index.
Confirmed Threshold Ratings: A type of confirmed ratings for homes where the HERS Index is calculated using Threshold Specifications with field inspections and testing accomplished on every home.
Threshold Ratings: A type of sampled or confirmed rating for homes where the HERS Index is calculated using Threshold Specifications, as determined by certain program criteria, with field inspections and testing accomplished on the minimum required units as per RESNET sampling protocol. Thresholds, or worst-case test results, should be used to represent sampled units that have not been confirmed/tested but are represented by units that have passed the Threshold Specifications.
Comment #3Amendment: Proposed MINHERS Addendum 28, Add a Definition of Confirmed Threshold RatingPage Number: 1Paragraph / Figure / Table / Note: Appendix BComment Intent: ObjectionComment Type: TechnicalComment: I disagree with the need to distinguish this type of rating from other Sampled Ratings. This configuration of test data and energy models is currently permitted, and all Sampled Ratings are currently required to be posted to the RESNET Registry, so this definition does not change the application of the Sampling process. However, adding this definition suggests that this configuration is more precise than it actually is. Adding lot-specific test data to a worst-case home configuration doesn’t provide a much better representation of a specific lot’s energy performance. This definition is also unclear: are all minimum rated features required to be 100% inspected and/or tested for all homes within the sampled project? If blower door testing is performed in every home but duct leakage testing is sampled, would that combination of Sampling and 100% testing be forced into using Confirmed Threshold Ratings? Would they have the option of calling those ratings Confirmed Threshold Ratings? What are the implications for Confirmed Threshold Ratings for HERS Ratings, the RESNET Registry, ERIs, and code compliance? I propose that this definition not be adopted. I also propose that changes to Sampling only be implemented after the revised multifamily Sampling process is issued for public comment this fall. Proposed Change: Confirmed Threshold Ratings: A type of confirmed ratings for homes where the HERS Index is calculated using Threshold Specifications with field inspections and testing accomplished on every home.
I disagree with the need to distinguish this type of rating from other Sampled Ratings. This configuration of test data and energy models is currently permitted, and all Sampled Ratings are currently required to be posted to the RESNET Registry, so this definition does not change the application of the Sampling process.
However, adding this definition suggests that this configuration is more precise than it actually is. Adding lot-specific test data to a worst-case home configuration doesn’t provide a much better representation of a specific lot’s energy performance.
This definition is also unclear: are all minimum rated features required to be 100% inspected and/or tested for all homes within the sampled project? If blower door testing is performed in every home but duct leakage testing is sampled, would that combination of Sampling and 100% testing be forced into using Confirmed Threshold Ratings? Would they have the option of calling those ratings Confirmed Threshold Ratings? What are the implications for Confirmed Threshold Ratings for HERS Ratings, the RESNET Registry, ERIs, and code compliance?
I propose that this definition not be adopted. I also propose that changes to Sampling only be implemented after the revised multifamily Sampling process is issued for public comment this fall.
Comment #4Amendment: Proposed MINHERS Addendum 28, Add a Definition of Confirmed Threshold RatingPage Number: Amendment #2017- 04Comment Intent: ObjectionComment Type: EditorialComment: This Amendment seems contradictory to RESNET’s efforts to increase accuracy and oversight. Allowing “threshold specifications” will lead to more ambiguity in ratings. The purpose of this new definition and rating process is still not clear. Will this rating type replace sampling or is this a new type of rating altogether? What constitutes the “threshold specifications?” Is the threshold the worst case home of a particular plan type or is it essentially a projected rating that field data is compared against and then uploaded to the registry? If the main driver to adding a new rating type is to streamline the process of confirming ratings then I think that’s great, but until real and active 3rd party QA is implemented there can be no assurance that the inspections and testing are getting conducted on each home as specified. Changes appear to be out of sequence. There needs to be a higher level of quality and oversight (via active 3rd party QA) prior to this streamlined approach of uploading projected ratings as confirmed. If 3rd party QA does not come before confirmed threshold ratings then “drive by inspections” will become a larger issue. Also, what does QA look like for on a confirmed threshold rating? Are performance results required to be recorded at all, or is the only requirement going to be that a box is checked that the performance met or exceeded the threshold? Proposed Change: Confirmed Threshold Ratings: A type of confirmed ratings for homes where the HERS Index is calculated using Threshold Specifications. with field Field inspections and testing shall be accomplished on every home, and performance testing results shall be included in each energy model file.
This Amendment seems contradictory to RESNET’s efforts to increase accuracy and oversight. Allowing “threshold specifications” will lead to more ambiguity in ratings. The purpose of this new definition and rating process is still not clear. Will this rating type replace sampling or is this a new type of rating altogether? What constitutes the “threshold specifications?” Is the threshold the worst case home of a particular plan type or is it essentially a projected rating that field data is compared against and then uploaded to the registry?
If the main driver to adding a new rating type is to streamline the process of confirming ratings then I think that’s great, but until real and active 3rd party QA is implemented there can be no assurance that the inspections and testing are getting conducted on each home as specified. Changes appear to be out of sequence. There needs to be a higher level of quality and oversight (via active 3rd party QA) prior to this streamlined approach of uploading projected ratings as confirmed.
If 3rd party QA does not come before confirmed threshold ratings then “drive by inspections” will become a larger issue. Also, what does QA look like for on a confirmed threshold rating? Are performance results required to be recorded at all, or is the only requirement going to be that a box is checked that the performance met or exceeded the threshold?
Confirmed Threshold Ratings: A type of confirmed ratings for homes where the HERS Index is calculated using Threshold Specifications. with field Field inspections and testing shall be accomplished on every home, and performance testing results shall be included in each energy model file.
Comment #5Amendment: Proposed MINHERS Addendum 28, Add a Definition of Confirmed Threshold RatingPage Number: 1Paragraph / Figure / Table / Note: Appendix B - Glossary of TermsComment Intent: ObjectionComment Type: EditorialComment: The Standards Committee of the North East Home Energy Rating Alliance, which represents more than 350 Raters and 11 Providers, objects to this definition being considered at all. We do not see how this proposed language fits into the mission of RESNET in enhancing the accuracy of Ratings and improving the Quality Assurance Process. Therefore, our proposed change is to strike the entire definition of Confirmed Threshold Ratings. Further, we have some questions about how this came about and other considerations that are not at all clear. Our questions, are as follows: Under the proposed definition, how does a QA Provider evaluate the Threshold Ratings? Will there be a provision for reporting test results? Are QA Providers going to apply field QA to the buildings with threshold ratings or will there need to be another QA procedure applied? There may be other nuances or unintended consequences that become evident if this Rating methodology is allowed. How does one account for variations from a builder’s model such as different appliances, lighting schemes or HVAC installations? Sampling protocols were put in place to allow sampled ratings when appropriate which seem to be lacking in this proposal. Without similar guidelines and protocols, why would any production builder do anything else? This is the path of least resistance. Confirmed Threshold Ratings will “water down” the RESNET brand at a time when the integrity of Ratings and the HERS Index is now essential for Energy Code Compliance. Home buyers may not get the nuance of what the designations mean and therefore, there will never be a demand for confirmed ratings. If the building was rated with inspections and tests but the software wasn’t updated, where are the actual test results? Does the home buyer get to see them? An overarching trend that RESNET has been on since its inception is to improve accuracy and consistency in its standards, procedures, in the calculations and its face to the public. It is a solid brand. The Confirmed Threshold Rating does not advance any of these efforts and it weakens the brand significantly. Proposed Change: Confirmed Threshold Ratings: A type of confirmed ratings for homes where the HERS Index is calculated using the Threshold Specifications with field inspections and testing accomplished on every home.
The Standards Committee of the North East Home Energy Rating Alliance, which represents more than 350 Raters and 11 Providers, objects to this definition being considered at all. We do not see how this proposed language fits into the mission of RESNET in enhancing the accuracy of Ratings and improving the Quality Assurance Process. Therefore, our proposed change is to strike the entire definition of Confirmed Threshold Ratings. Further, we have some questions about how this came about and other considerations that are not at all clear. Our questions, are as follows:
An overarching trend that RESNET has been on since its inception is to improve accuracy and consistency in its standards, procedures, in the calculations and its face to the public. It is a solid brand. The Confirmed Threshold Rating does not advance any of these efforts and it weakens the brand significantly.
Confirmed Threshold Ratings: A type of confirmed ratings for homes where the HERS Index is calculated using the Threshold Specifications with field inspections and testing accomplished on every home.
Comment #6Amendment: Proposed MINHERS Addendum 28, Add a Definition of Confirmed Threshold RatingPage Number: 1Paragraph / Figure / Table / Note: 102.1.4.10, 303Comment Intent: ObjectionComment Type: TechnicalComment: Adding the definition for Confirmed Threshold Rating is a necessary step, but appears insufficient in itself to clarify the application of this new rating type. RESNET’s e-mail announcing the proposed amendment said that the board voted that tested envelope and duct leakage values be reported to the registry for Confirmed Ratings that use Threshold Specifications. That requirement is not included in the definition of Confirmed Threshold Rating so we propose to include this requirement, and several related clarifications, as an exception to section 303.1 (Technical Requirements), though it would more naturally be accomplished as a change to ANSI/RESNET 301-2014. RESNET’s announcement also stated that Sampled Ratings that use Threshold Specifications should report the tested envelope and duct leakage values to the registry. We propose an option for including this requirement as an exception to section 303.1 (Applicable Standards). Relatedly, we propose adding Confirmed Threshold to the Rating Type in Section 102.1.4.10.1.1.7. Without this, neither RESNET nor QAD’s will be able to assess whether a Confirmed or Confirmed Threshold Rating was reported. Relatedly, we propose adding the envelope and duct leakage values to the list of minimum registry reporting requirements in section 102.1.4.10.1. Relatedly, in Section 303.2, we clarify that all rating types – Confirmed, Confirmed Threshold, and Sampled – must be reported to the registry. Since Confirmed Threshold ratings are a subset of Confirmed Ratings this is technically redundant, but we feel it is worth being explicit since this question has arisen in the past. Finally, while we do not address it in our proposed change to the amendment, the working group and board might want to consider creating a separate category of confirmed rating, perhaps called Confirmed Individual Rating, that would be a counterpart to the Confirmed Threshold Rating in which the field-verified values are entered into the rating software for all features. Previously this type of rating was widely referred to as a “Confirmed Rating” but this amendment turns that name into a penumbra term, leaving us without a name specifically for ratings that do not use Threshold Specifications. Proposed Change: 102.1.4.10 National RESNET Registry. The National RESNET Registry shall be maintained by RESNET and made available for use by accredited Home Energy Rating Quality Assurance Providers, their certified Raters and other parties in accordance with RESNET Board policy. Each accredited Home Energy Rating Quality Assurance Provider shall be included in the National RESNET Registry. Each accredited Home Energy Rating Quality Assurance Provider shall be responsible for maintaining a current and accurate listing of their Certified Raters using the National RESNET Registry. Each accredited Home Energy Rating Quality Assurance Provider shall be responsible for registering each Home Energy Rating conducted under the auspices of said Home Energy Rating Quality Assurance Provider in the National RESNET Registry in accordance with Sections 102.1.4.10.1 and 102.1.4.10.2. 102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include: 102.1.4.10.1.1 The Rated Home characteristics, including but not limited to the following: 102.1.4.10.1.1.1 Physical location of the home, including street address, city, state and zip code 102.1.4.10.1.1.2 IECC climate zone of the home 102.1.4.10.1.1.3 Certified Rater ID 102.1.4.10.1.1.4 Accredited Rating Quality Assurance Provider ID 102.1.4.10.1.1.5 Date of the Rating 102.1.4.10.1.1.6 Status of the Rated Home (new or existing) 102.1.4.10.1.1.7 Rating Type for the home (cConfirmed, Confirmed Threshold or sSampled) 102.1.4.10.1.1.8 Home Type (single-family, duplex, low-rise Multi-family) 102.1.4.10.1.1.9 Conditioned Floor Area of the home 102.1.4.10.1.1.10 Number of bedrooms in the home 102.1.4.10.1.1.11 The name and version number of the accredited software rating tool that created the Rating 102.1.4.10.1.1.12 Field-verified envelope leakage and duct leakage values of the home ------------------------------------------- 303 Technical Requirements 303.1 Applicable Standards All RESNET Home Energy Ratings conducted in accordance with this Standard shall comply with the provisions of ANSI/RESNET 301-2014, “Standard for the Calculation and Labeling of the Energy Performance of Low-Rise Residential Buildings using the HERS Index.” Exception: RESNET Home Energy Ratings conducted on dwelling units in multi-family buildings four and five stories above grade that are certified through EPA’s ENERGY STAR certified homes program shall comply with the provisions of ANSI/RESNET 301-2014, notwithstanding the limit on stories, and Sections 303.2 and 303.3. Exception: For Confirmed Threshold Ratings in accordance with Sections 5.1.4.1 of ANSI/RESNET 301-2014: 1) All Minimum Rated Features of the Rated Home shall be field-verified to meet or exceed the Threshold Specification through inspection and testing in accordance with ANSI/RESNET 301-2014 Section 4.4. 2) Field-verified envelope leakage and duct leakage values of the Rated Home shall be entered into the Approved Software Rating Tool that generates the Home Energy Rating instead of the Threshold Specifications for those Minimum Rated Features. For the remaining Minimum Rated Features of the Rated home, either Threshold Specifications or field-verified values shall be entered into the Approved Software Rating Tool. The Home Energy Rating shall report the HERS Index that comports with these inputs. Exception: For Sampled Ratings in accordance with Sections 5.1.4.2 of ANSI/RESNET 301-2014, field-verified envelope leakage and duct leakage values of the Rated Home shall be entered into the Approved Software Rating Tool that generates the Home Energy Rating instead of the Threshold Specifications for those Minimum Rated Features. 303.2 Sampled Ratings Registration All Confirmed, Confirmed Threshold and Sampled RESNET Ratings shall be registered with the National RESNET Registry in accordance with Sections 102.1.4.10 and 102.1.4.12.
Adding the definition for Confirmed Threshold Rating is a necessary step, but appears insufficient in itself to clarify the application of this new rating type.
Finally, while we do not address it in our proposed change to the amendment, the working group and board might want to consider creating a separate category of confirmed rating, perhaps called Confirmed Individual Rating, that would be a counterpart to the Confirmed Threshold Rating in which the field-verified values are entered into the rating software for all features. Previously this type of rating was widely referred to as a “Confirmed Rating” but this amendment turns that name into a penumbra term, leaving us without a name specifically for ratings that do not use Threshold Specifications.
102.1.4.10 National RESNET Registry. The National RESNET Registry shall be maintained by RESNET and made available for use by accredited Home Energy Rating Quality Assurance Providers, their certified Raters and other parties in accordance with RESNET Board policy. Each accredited Home Energy Rating Quality Assurance Provider shall be included in the National RESNET Registry. Each accredited Home Energy Rating Quality Assurance Provider shall be responsible for maintaining a current and accurate listing of their Certified Raters using the National RESNET Registry. Each accredited Home Energy Rating Quality Assurance Provider shall be responsible for registering each Home Energy Rating conducted under the auspices of said Home Energy Rating Quality Assurance Provider in the National RESNET Registry in accordance with Sections 102.1.4.10.1 and 102.1.4.10.2.
102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include:
102.1.4.10.1.1 The Rated Home characteristics, including but not limited to the following:
102.1.4.10.1.1.1 Physical location of the home, including street address, city, state and zip code 102.1.4.10.1.1.2 IECC climate zone of the home 102.1.4.10.1.1.3 Certified Rater ID 102.1.4.10.1.1.4 Accredited Rating Quality Assurance Provider ID 102.1.4.10.1.1.5 Date of the Rating 102.1.4.10.1.1.6 Status of the Rated Home (new or existing) 102.1.4.10.1.1.7 Rating Type for the home (cConfirmed, Confirmed Threshold or sSampled) 102.1.4.10.1.1.8 Home Type (single-family, duplex, low-rise Multi-family) 102.1.4.10.1.1.9 Conditioned Floor Area of the home 102.1.4.10.1.1.10 Number of bedrooms in the home 102.1.4.10.1.1.11 The name and version number of the accredited software rating tool that created the Rating 102.1.4.10.1.1.12 Field-verified envelope leakage and duct leakage values of the home
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303 Technical Requirements
303.1 Applicable Standards
All RESNET Home Energy Ratings conducted in accordance with this Standard shall comply with the provisions of ANSI/RESNET 301-2014, “Standard for the Calculation and Labeling of the Energy Performance of Low-Rise Residential Buildings using the HERS Index.”
Exception: RESNET Home Energy Ratings conducted on dwelling units in multi-family buildings four and five stories above grade that are certified through EPA’s ENERGY STAR certified homes program shall comply with the provisions of ANSI/RESNET 301-2014, notwithstanding the limit on stories, and Sections 303.2 and 303.3.
Exception: For Confirmed Threshold Ratings in accordance with Sections 5.1.4.1 of ANSI/RESNET 301-2014: 1) All Minimum Rated Features of the Rated Home shall be field-verified to meet or exceed the Threshold Specification through inspection and testing in accordance with ANSI/RESNET 301-2014 Section 4.4. 2) Field-verified envelope leakage and duct leakage values of the Rated Home shall be entered into the Approved Software Rating Tool that generates the Home Energy Rating instead of the Threshold Specifications for those Minimum Rated Features. For the remaining Minimum Rated Features of the Rated home, either Threshold Specifications or field-verified values shall be entered into the Approved Software Rating Tool. The Home Energy Rating shall report the HERS Index that comports with these inputs.
Exception: For Sampled Ratings in accordance with Sections 5.1.4.2 of ANSI/RESNET 301-2014, field-verified envelope leakage and duct leakage values of the Rated Home shall be entered into the Approved Software Rating Tool that generates the Home Energy Rating instead of the Threshold Specifications for those Minimum Rated Features.
303.2 Sampled Ratings Registration All Confirmed, Confirmed Threshold and Sampled RESNET Ratings shall be registered with the National RESNET Registry in accordance with Sections 102.1.4.10 and 102.1.4.12.
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